Table of contents

1    Responsibilities

1.1     Responsible in terms of data protection

1.2     Our data protection officer

1.3     Competent supervisory authority

2    General information on data protection

2.1     What data do we process from you?

2.2     For what purposes do we process your data and on what legal basis

2.2.1     On the basis of your consent

2.2.2     For the fulfilment of contractual obligations

2.2.3     Due to legal obligations

2.2.4     Due to legitimate interests

2.3     Who do we share your data with?

2.3.1     Companies, agencies and partners of the VDH|GROUP

2.3.2     Processors and third parties

2.4     Information on the transfer of data to third countries

2.5     Storage duration

3    Your rights as a data subject

3.1     Information, correction and deletion

3.2     Right to restriction of processing

3.3     Right to data portability

3.4     Right to object to data collection in special cases

3.5     Revocation of your consent to data processing

3.6     Contact option for exercising your rights as a data subject

3.7     Right to lodge a complaint

4    Data processing on our website

4.1     General information on the legal basis for data processing on this website

4.2     External hosting

4.3     SSL or TLS encryption

4.4     Cookies

4.5     Consent with Borlabs Cookie

4.6     BBQ firewall

4.7     Server log files

4.8     Contact form

4.9     YouTube with enhanced data protection

4.10     Google Fonts (local hosting)

4.11     IONOS WebAnalytics

5    Data processing as part of the application process

5.1     Scope and purpose of data collection

5.2     Online application interviews

5.3     Data retention period

5.4     Inclusion in the applicant pool

6    Data processing in other cases

6.1     Enquiry by e-mail, telephone or fax

6.2     Data processing in the context of audio and video conferences

6.2.1     Purpose and legal basis

6.2.2     Storage duration

6.2.3     Conference tool used - Microsoft Teams

6.3     Dispatch of product information

6.4     Newsletter to existing customers

6.5     Christmas and New Year greetings

7    Our social media presence

7.1     Data processing by social networks

7.2     Legal basis

7.3     Responsible party and assertion of rights

7.4     Storage duration

7.5     Social networks in detail

7.5.1     LinkedIn

7.5.2     YouTube

7.5.3     XING

Information on data protection

For us - as part of the VDH|GROUP - data protection-compliant handling and security in the context of processing your personal data is an important concern. With this data protection information, we would like to inform you about how we handle personal data in general and in particular.

1         Responsibilities

1.1        Responsible in terms of data protection

The controller within the meaning of data protection law is the natural or legal person who - alone or jointly with others - determines the purposes and means of the processing of personal data.

The controller in terms of data protection is the:

https://www.vdh-group.de/

Mehldau & Steinfath Umwelttechnik GmbH

Alfredstrasse 279

D-45133 Essen

Phone: +49 201 / 43783 - 0

Fax: +49 201 / 43783 - 33

E-mail: zentrale@vdh-group.de

https://www.ms-umwelt.de/

Mehldau & Steinfath Umwelttechnik GmbH

Alfredstrasse 279

D-45133 Essen

Phone: +49 201 / 43783 - 0

Fax: +49 201 / 43783 - 33

E-mail: zentrale@vdh-group.de

https://www.hkl-anlagentechnik.de/

HKL Anlagentechnik GmbH

Haßlinghauser Street 156

58285 Gevelsberg

Phone: +49 2332 / 8461 - 0

e-mail: hkl@vdh-group.de

https://www.drysotec.de/

DrySoTec GmbH

Alfredstrasse 279

D-45133 Essen

Phone: +49 201 / 43783 - 0

Fax: +49 201 / 43783 - 33

E-mail: info@drysotec.de

hereinafter referred to as "VDH|GROUP" or "we".

1.2        Our data protection officer

We have appointed an external data protection officer for our organisation, who can be contacted using the following contact details:

Boris Nicolaj Willm

Resilien[i]T GmbH
Monschauer Straße 12
40549 Düsseldorf

Phone: +49 211 695289 92

E-mail: dsb.vdh-group@resilienit.de

1.3        Competent supervisory authority

You can contact the supervisory authority responsible for us at

State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia

Kavalleriestr. 2-4
40213 Düsseldorf
Phone: +49 211 38424-0
Fax: +49 211 38424-999
E-mail: poststelle@ldi.nrw.de

2         General information on data protection

2.1        What data do we process from you?

Depending on the specific processing situation and necessity, we collect and process different types of personal data. We provide detailed information on this in this and / or separate data protection information or in the context of data collection from the respective data subjects.

2.2        For what purposes do we process your data and on what legal basis?

We collect and process various personal data depending on the specific processing situation. The processing is always carried out in accordance with the provisions of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) or other legal requirements The legal bases relevant to us result from Art. 6 para. 1 as follows:

2.2.1        On the basis of your consent

If you have given us your consent for the specific processing of your personal data, we will process your personal data on this basis. Consent may, for example, relate to the transfer of data to partner companies, the analysis of your data for targeted advertising measures or the sending of newsletters.

Consent is always voluntary. Refusal or withdrawal of consent will not have any negative consequences for you.

2.2.2        For the fulfilment of contractual obligations

We process your personal data to fulfil contractual or quasi-contractual obligations or to establish a contract, for example for existing customer support or to answer questions from a prospective customer.

If you apply to us by post or electronically and provide us with personal data, we process this data exclusively for the purpose of initiating a future employment relationship.

2.2.3        Due to legal obligations

As part of our legal obligations, we process your personal data if this is provided for or required by law. This may include, for example, the disclosure of your data to government authorities in the context of tax or criminal prosecution proceedings, the evaluation of your data to comply with regulatory requirements or the provision of certain information to statutory bodies.

The processing of your data on this basis is always necessary. The legal obligation to which we are subject as an organisation cannot be impaired by any refusal or restriction on your part. We assure you that your personal data will be processed in accordance with the law and that it will be comprehensively protected.

2.2.4        Due to legitimate interests

We also process your personal data to protect our legitimate interests, unless your interests or fundamental rights and freedoms, which require the protection of your personal data, prevail.

Subject to a balancing decision to be made in individual cases, we regularly assume that our legitimate interests prevail in the context of the following non-exhaustive list of processing situations:

• for existing customer support;
• to inform you about offers for services and products if we have received your name, e-mail address or postal address from you in connection with the provision of our services and/or the sale of our products;
• Optimisation of our offers and services;
• Maintaining a customer and supplier database in our group of companies to improve customer service and maintain supplier relationships;
• in the context of legal prosecution;
• to ensure the security, confidentiality and integrity of our IT systems;

2.3        Who do we share your data with?

2.3.1        VDH|GROUP companies, agencies and partners

In principle, we only pass on your personal data if this is necessary for the establishment, execution or termination of a contract or contract-like relationship. In these cases, data is only passed on to companies affiliated with us or to partners and representatives. Partners and agencies are, in particular, independent commercial agents for the distribution of our goods and services in Germany and abroad. When you contact us, for example, we share the information you provide us with the relevant regional VDH|GROUP company so that they can offer you our products and services in an optimised manner, depending on the requirements and regional nature of your enquiry.

The VDH|GROUP companies include

• Mehldau & Steinfath Umwelttechnik GmbH, Alfredstraße 279, D-45133 Essen
• HKL Anlagentechnik GmbH, Haßlinghauser Straße 156, 58285 Gevelsberg, Germany
• DrySoTec GmbH, Alfredstraße 279, D-45133 Essen
• M&S Environmental technologies s.r.o., Vratimovská 624/11, 718 00 Ostrava
• vysion-aset GmbH, Franz-Schubert Straße 2, D-03050 Cottbus

2.3.2        Processors and third parties

On our instructions, your personal data may be processed by processors if their involvement is necessary for processing. In these cases, we ensure that your personal data is processed in accordance with the provisions of the GDPR. Processors in this case are, for example, IT service providers, waste disposal companies, etc.. In addition, these processors are contractually obliged to either delete or return the data to us in accordance with the legal requirements when their services are terminated.

Your data will only be transferred and passed on to external recipients if this is permitted or required by law, if the transfer is necessary for the processing and fulfilment of the business relationship or service used or if you have given your consent to the transfer of data.

Personal data may be passed on to the following external recipients:

• Public bodies and institutions that receive data due to legal regulations (e.g. tax office, courts, customs, etc.);
• Tax consultant, auditor or legal advisor;
• Payment service provider, for processing a payment transaction (e.g. financial institutions, payment services);
• Debt collection service providers or credit agencies, insofar as necessary to exercise our rights;
• IT and other service providers, suppliers;
• Insurances;
• Printing and logistics companies, telecommunications service providers, delivery services;

2.4        Information on the transfer of data to third countries

In our organisation, we use services from providers based in countries outside the European Economic Area where there is no level of data protection comparable to that in the EU. When using these services, your personal data may be transferred to these countries and processed there. We guarantee that this transfer will only take place within the framework of compliance with Art. 44ff of the General Data Protection Regulation (GDPR) in order to ensure an adequate level of protection for your data.

2.5        Storage duration

Unless an explicit or statutory storage period is specified at the time of collection, your personal data will be deleted as soon as it is no longer required to fulfil the purpose for which it was stored and there are no statutory retention obligations or legal justifications for storage.

If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.

3         Your rights as a data subject

In accordance with data protection regulations, we would like to inform you of your rights as a data subject. These rights are essential components of data protection and guarantee you control over your personal data. It is important to us that you are aware of your rights and understand how you can assert them to protect your privacy and the integrity of your data. Below you will find a detailed breakdown of your rights and how you can exercise them if necessary.

3.1        Information, correction and deletion

You have the right to obtain information about your personal data processed by us at . This includes information about the source of the data, the recipients and the purpose of processing. You also have the right to have this data corrected or deleted if necessary.

3.2        Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. This right is applicable under the following conditions:

• Accuracy of the data: If you dispute the accuracy of your personal data and verification is required.
• Unlawful processing: If the processing is unlawful, but you refuse erasure and instead request restriction of use.
• The purpose of processing no longer applies but is required for legal claims: If the controller no longer needs the data for the purposes of processing, but you need them for the establishment, exercise or defence of legal claims.
• Objection to processing: If you have objected to the processing pursuant to Art. 21 para. 1 GDPR and it is still being examined whether the legitimate reasons of the controller outweigh your reasons.

During the restriction period, your data, apart from being stored, may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3.3        Right to data portability

You have the right to receive your personal data that you have provided to us in a structured, widely used and machine-readable format in accordance with the existing legal provisions. This right also enables you to have this data transferred directly from one controller to another, where technically feasible. This applies in cases where the processing is based on consent or a contract and is automated.

3.4        Right to object to the collection of data in special cases

You have the right to object to the processing of your personal data at any time if it is based on Article 6(1)(f). This provision permits data processing on the basis of the legitimate interests of the controller or a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail.

You have the unrestricted right to object to the processing of your personal data for advertising purposes at any time. This includes direct marketing. As soon as you object, the processing of your data for these purposes will cease. This right is absolute and will result in the immediate cessation of the relevant data processing.

Individuals have the right not to be subject to decisions based solely on automated processing which produces legal effects concerning them or similarly significantly affects them.

The right to object also extends to profiling insofar as it is associated with direct marketing.

3.5        Revocation of your consent to data processing

You have the right to revoke processing based on your explicit consent at any time for the future. However, this revocation does not affect the legality of the data processing that took place before your revocation.

3.6        Contact option for exercising your rights as a data subject

You can declare the assertion of your rights and, if applicable, your objection informally by post or e-mail, addressed to:

Mehldau & Steinfath Umwelttechnik GmbH

Area: Data protection

Alfredstrasse 279

D-45133 Essen

E-mail: datenschutz@vdh-group.de

3.7        Right to lodge a complaint

If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a data protection supervisory authority of your choice in accordance with Art. 77 (1) GDPR. This also includes the supervisory authority responsible for us.

4         Data processing on our website

4.1        General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of Section 25 (1) TDDDG. Consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfil a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

4.2        External hosting

We host our websites externally. The personal data collected on our websites is stored on the hoster's servers. This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

Our hoster will only process your data to the extent necessary to fulfil its performance obligations and follow our instructions with regard to this data.

We use the following hoster:

IONOS SE

Elgendorfer Str. 57

56410 Montabaur

The website is maintained by the :

COMMUNICATION REWARDING

Design | Brand | Advertising

Krablerstrasse 28-30

45326 Essen

We have concluded a data processing agreement (DPA) with the service provider for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that the service provider will only process the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

4.3        SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, we use SSL or TLS encryption for our website(s). You can recognise an encrypted connection by the fact that the web address begins with "https://" and a lock symbol is displayed in your browser. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4.4        Cookies

Our Internet pages use so-called "cookies". Cookies are small data packets and do not cause any damage to your end device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies can be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping basket function) or to optimise the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG); the consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

You can find out which cookies and services are used on this website in this data protection information.

4.5        Consent with Borlabs Cookie

Our website uses Borlabs Cookie consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document these in compliance with data protection regulations. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter referred to as Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected will be stored until you ask us to delete it or delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.

4.6        BBQ firewall

We have integrated the BBQ firewall on this website. This plugin does not collect or store any user data. It does not set cookies and does not connect to third-party sites. Therefore, this plugin does not affect the privacy of users in any way.

The use of BBQ Firewall is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website as effectively as possible against cyberattacks.

4.7        Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website - the server log files must be recorded for this purpose.

4.8        Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your enquiry 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 processing of the enquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions - in particular retention periods - remain unaffected.

4.9        YouTube with extended data protection

This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. The YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalise surfing on YouTube. Ads that are played in extended data protection mode are also not personalised. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user's browser, which contain personal data similar to cookies and can be used to recognise the user. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.

After activating a YouTube video, further data processing operations may be triggered over which we have no influence.

The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user's end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Further information about data protection at YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=de.

The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active

4.10   Google Fonts (local hosting)

This site uses so-called Google Fonts, which are provided by Google, for the standardised display of fonts. The Google fonts are installed locally. There is no connection to Google servers.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=de.

4.11   IONOS WebAnalytics

This website uses the analytics services of IONOS WebAnalytics (hereinafter: IONOS). The provider is 1&1 IONOS SE, Elgendorfer Straße 57, D - 56410 Montabaur. As part of the analyses with IONOS, visitor numbers and behaviour (e.g. number of page views, duration of a website visit, bounce rates), visitor sources (i.e. which page the visitor comes from), visitor locations and technical data (browser and operating system versions) can be analysed. IONOS stores the following data in particular for this purpose:

• Referrer (previously visited website)
• requested web page or file
• Browser type and browser version
• Operating system used
• Device type used
• Time of access
• IP address in anonymised form (only used to determine the location of access)

According to IONOS, data collection is completely anonymised so that it cannot be traced back to individual persons. Cookies are not stored by IONOS WebAnalytics.

The data is stored and analysed on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the statistical analysis of user behaviour in order to optimise both its website and its advertising. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Further information on data collection and processing by IONOS WebAnalytics can be found in the IONOS privacy policy at the following link: https://www.ionos.de/terms-gtc/datenschutzerklaerung/

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

5         Data processing as part of the application process

We offer you the opportunity to apply to us (e.g. by e-mail or post). In the following, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

Please note that we only accept e-mail applications via the mailbox bewerbung@vdh-group.de.

An incorrect application, e.g. by e-mail, may be processed, but we cannot guarantee that the documents will actually be deleted in full within the deadline.

In order to ensure a data protection-compliant application process, we therefore ask you to always apply via our recruiting page.

5.1          Scope and purpose of data collection

If you send us an application, we will process your associated personal data (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is Art. 6 para. 1 lit. b GDPR (general contract initiation) in conjunction with § 26 BDSG under German law (initiation of an employment relationship) and - if you have given your consent - Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time for the future. Your personal data will only be passed on within our company to persons who are involved in processing your application.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of Art. 6 para. 1 lit. b GDPR and § 26 BDSG for the purpose of implementing the employment relationship.

5.2        Online application interviews

As part of the application process, we offer interested parties the opportunity to conduct job interviews via a video conferencing tool. This enables contactless interaction and overcoming geographical distances. The video or audio material will not be recorded or saved at any time. Applicants are free to switch off the camera function in advance or during the interview. The applicant can decline the video interview without giving reasons. In this case, a mutually acceptable alternative will be sought.

If a video conferencing tool is used, the transfer of data to a third country (in particular the USA) cannot be ruled out. The legal basis for processing is consent pursuant to Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time.

5.3        Data retention period

If we are unable to make you a job offer, you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The retention serves in particular as evidence in the event of a legal dispute. If it is evident that the use of the data will be necessary after the 6-month period has expired (e.g. due to an impending or pending legal dispute), the data will only be deleted when the purpose for further storage no longer applies.

Data may also be stored for longer if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations prevent deletion.

5.4        Inclusion in the applicant pool

If we do not make you a job offer, you may have the opportunity to be included in our applicant pool. If you are accepted, all documents and details from your application will be transferred to the applicant pool so that you can be contacted in the event of suitable vacancies.

Inclusion in the applicant pool is based exclusively on your express consent (Art. 6 para. 1 lit. a GDPR). Giving consent is voluntary and is not related to the current application process. The data subject can withdraw their consent at any time. In this case, the data will be deleted from the applicant pool immediately, provided there are no statutory retention reasons.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

6         Data processing in other cases

6.1        Enquiry by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your enquiry including all personal data (name, enquiry) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your enquiry 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 processing of the enquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.

The data you send to us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

6.2        Data processing in the context of audio and video conferences

We use online conferencing tools, among other things, to communicate with our customers. The individual tools we use are listed below. If you communicate with us by video or audio conference via the internet, your personal data will be collected and processed by us and the provider of the respective conference tool.

The conference tools collect all data that you provide/enter to use the tools (email address and/or your telephone number). The conference tools also process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other "contextual information" in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required to handle online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

If content is exchanged, uploaded or provided in any other way within the tool, it is also stored on the tool provider's servers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the service.

Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the company policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection information of the tools used, which we have listed below this text.

6.2.1        Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). If consent has been requested, the tools in question are used on the basis of this consent; consent can be withdrawn at any time with effect for the future.

6.2.2        Storage duration

The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

6.2.3        Conference tool used - Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Details on data processing can be found in the Microsoft Teams data protection information: https://privacy.microsoft.com/de-de/privacystatement.

The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000KzNaAAK&status=Active

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that the service will only process the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

6.3        Dispatch of product information

If we provide you with information as part of pre-contractual measures or an existing business relationship, we only process the data that is required. These are

• Personal details (first name and surname);
• Name of the company;
• Contact details (telephone number, e-mail address)

6.4        Newsletter to existing customers

If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter. You can cancel the sending of this newsletter at any time. There is a corresponding link in every newsletter for this purpose. In this case, the legal basis for sending the newsletter is Art. 6 para. 1 lit. f GDPR in conjunction with Section 7 para. 3 UWG.

After you unsubscribe from the newsletter distribution list, we may store your e-mail address in a blacklist to prevent future mailings to you. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

6.5        Christmas and New Year greetings

We may send Christmas/New Year greetings to customers and business partners at the end of the year. Your name and address will be collected and processed in order to send you these.

The processing of the data is based on a business purpose in accordance with Art. 6 para. 1 lit. f GDPR. The controller has a legitimate interest in thanking and promoting the customer and business relationship.

Your data will not be passed on to third parties.

If you do not wish to receive greeting cards from us, you can object to receiving them. You can send us your objection without giving reasons, as described in the section on data subject rights. Your data will then no longer be used for the stated purpose.

7         Our social media presence

7.1        Data processing by social networks

We maintain publicly accessible profiles on social networks. The individual social networks we use are listed below.

Social networks can generally analyse your user behaviour comprehensively when you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). Visiting our social media presences triggers numerous data protection-relevant processing operations. In detail:

• If you are logged into your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, your personal data may also be collected if you are not logged in or do not have an account with the respective social media portal. In this case, this data collection takes place, for example, via cookies that are stored on your end device or by recording your IP address.
• With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you inside and outside the respective social media presence. If you have an account with the respective social network, the interest-based advertising can be displayed on all devices on which you are logged in or were logged in.
• Please also note that we cannot track all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and data protection provisions of the respective social media portals.

7.2        Legal basis

Our social media presence is intended to ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which must be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6 para. 1 lit. a GDPR).

7.3        Responsible party and assertion of rights

If you visit one of our social media sites (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during this visit. You can assert your rights (information, rectification, erasure, restriction of processing, data portability and complaint) both against us and against the operator of the respective social media portal (e.g. against Facebook).

Please note that, despite our joint responsibility with the social media portal operators, we do not have full control over the data processing operations of the social media portals. Our options are largely determined by the company policy of the respective provider.

7.4        Storage duration

The data collected directly by us via the social media presence will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory provisions - in particular retention periods - remain unaffected.

We have no influence on the storage period of your data that is stored by the operators of the social networks for their own purposes. For details, please contact the operators of the social networks directly (e.g. in their data protection information, see below).

7.5        Social networks in detail

7.5.1        LinkedIn

We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you wish to deactivate LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs

Details on how they handle your personal data can be found in LinkedIn's data protection information: https://www.linkedin.com/legal/privacy-policy

7.5.2        XING

We have a profile on XING. The provider is New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany. Details on how they handle your personal data can be found in XING's privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

7.5.3        YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in YouTube's data protection information: https://policies.google.com/privacy?hl=de

The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active

Status 03.06.2024