Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly as „data“) that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and in particular on our websites as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as the „online offering“).

The terms used are not gender-specific.

As of: May 18, 2022

 

Controller

Sternwald Systems GmbH
Pohlandstraße 19
01309 Dresden
Germany

Authorized representatives: Ard Meier, Ronny Günther

Email address: verwaltung@sternwald.com

Phone: +49 30 403 69 59 02

Legal notice: https://www.prd.sternwald.cloud/impressum

 

Contact Data Protection Officer

Robert Wersch
external data protection officer
mobilplus Systemhaus GmbH
Am Wüsteberg 3
01723 Wilsdruff OT Kesselsdorf
Germany

Tel.: +49 35204 270 318
Email: robert.wersch@mobilplus.it
Web: www.datenschutz-genie.de

 

Overview of processing activities

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects concerned.

Types of data processed

  • Master data.

  • Payment data.

  • Contact data.

  • Content data.

  • Contract data.

  • Usage data.

  • Meta/communication data.

  • Applicant data.

Categories of data subjects

  • Customers.

  • Prospects.

  • Communication partners.

  • Users.

  • Applicants.

  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and customer support.

  • Contact requests and communication.

  • Administrative and organisational procedures.

  • Application procedures.

  • Feedback.

  • Marketing.

  • Provision of our online offering and user-friendliness.



 

Applicable legal bases

In the following, you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or registered office. If, in individual cases, more specific legal bases are relevant, we will inform you of them in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of the personal data concerning them for one or more specific purposes.

  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

  • Application process as a pre-contractual or contractual relationship (Art. 9(2)(b) GDPR) – Where, in the course of the application process, special categories of personal data within the meaning of Art. 9(1) GDPR are requested from applicants (e.g., health data such as severe disability status or ethnic origin), so that the controller or the data subject can exercise the rights and fulfil the obligations arising for them from employment law and the law of social security and social protection, their processing is carried out pursuant to Art. 9(2)(b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR or for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision or treatment in the health or social sector or for the administration of systems and services in the health or social sector pursuant to Art. 9(2)(h) GDPR. In the case of voluntary disclosure of special categories of data based on consent, their processing is carried out on the basis of Art. 9(2)(a) GDPR.

In addition to the data protection regulations of the General Data Protection Regulation, national data protection rules apply in Germany. These include in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer as well as automated decision-making in individual cases including profiling. It also regulates data processing for employment purposes (§ 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships as well as employee consent. Furthermore, state data protection laws of the individual federal states may apply.

 

Security measures

In accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying likelihoods of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input into, disclosure of, securing of availability of and separation of the data concerned. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data compromise. We also take into account the protection of personal data already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.

Data center: Our website is hosted in a data center in Germany. The data center is certified according to DIN ISO/IEC 27001, the internationally recognized standard for information security.

 

Transfer of personal data

In the course of our processing of personal data, it may happen that the data is transferred to other locations, companies, legally independent organisational units or persons, or disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with the statutory requirements and in particular conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfers within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to such data. If this disclosure takes place for administrative purposes, the disclosure of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual obligations or if there is consent from the data subjects or a legal permission.

 

Deletion of data

The data processed by us will be deleted in accordance with legal requirements as soon as the consent permitted for processing is withdrawn or other permissions cease to apply (e.g., if the purpose of processing these data ceases to apply or they are no longer necessary for the purpose).

If the data are not deleted because they are required for other legally permissible purposes, their processing will be restricted to those purposes. This means the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person.

Within the scope of our privacy notices, we may provide users with additional information on the deletion and retention of data that applies specifically to the respective processing processes.

 

Providers and services used in the course of business activities

In the course of our business activities, and in compliance with legal requirements, we use additional services, platforms, interfaces or plugins from third-party providers (hereinafter briefly referred to as „services“) that may process user data. In this context, the privacy notices of the respective services apply in addition to our privacy notices.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, users' data are processed for the provision of our business services or, if this is not necessary for the performance of the contract, on the basis of our legitimate interests (i.e., interest in efficient, economical and user-friendly services).

  • Types of data processed: Master data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); contract data (e.g., subject matter of the contract, term, customer category).

  • Data subjects: Customers; prospects; users (e.g., website visitors, users of online services); business and contractual partners.

  • Purposes of processing: Provision of contractual services and customer support; administrative and organisational procedures.

  • Legal bases: Consent (Art. 6(1)(a) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

 

Provision of the online offering and web hosting

In order to provide our online offering securely and efficiently, we make use of the services of one or more web hosting providers, whose servers (or servers managed by them) make the online offering available for retrieval. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed in the context of providing the hosting service may include all information relating to users of our online offering that arises in the course of use and communication. This regularly includes the IP address, which is necessary to deliver the contents of online offerings to browsers, and all entries made within our online offering or on websites.

  • Types of data processed: Content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Provision of our online offering and user-friendliness.

  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Email sending and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders as well as other information relating to the email transmission (e.g., the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server.

  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the retrieved websites and files, date and time of retrieval, transferred data volumes, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, for example to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilisation of the servers and their stability; Deletion of data: log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is required for evidential purposes are exempt from deletion until the final clarification of the respective incident.

  • DEEP CONTENT: Web hosting/server; Service provider: DEEP CONTENT GbR
    Gutenbergplatz 3
    04103 Leipzig
    GermanyEmail: hallo@deep-content.de; Website: https://deep-content.io/;
    Privacy policy: https://deep-content.io/datenschutz/.

 

DC Data – Web analytics

Scope of personal data processing

We use the DC Data web analytics software on this website, a service provided by our IT service provider DEEP CONTENT GbR, Georg-Speyer-Straße 4, 60487 Frankfurt am Main, Germany. When pages of our website are accessed, the following data are collected and stored:

– the user's IP address, truncated by the last 2 bytes (anonymised)

– the accessed subpage and the time of access

– the website from which the user reached our website (referrer)

– the pages accessed from the visited subpage

– links to external domains that were clicked

– the length of stay on the website

The collected data are stored on the servers of our IT service provider DEEP CONTENT GbR. The server location is Germany. The data are evaluated by us as the website operator. They are not passed on to third parties.

Legal basis

The legal basis on which we process personal data using DC Data is Art. 6(1)(f) GDPR.

 

Purpose of data processing

We require the data in order to analyse user behaviour and obtain information about the use of individual components of the website. This enables us to continuously optimise the website and its user-friendliness and to ensure the website remains accessible. These purposes constitute our legitimate interest within the meaning of Art. 6(1)(f) GDPR. By anonymising the IP address, we take account of users' interest in the protection of personal data. We also refrain from using cookies. The data are never used to personally identify the website user. No data collection via recognition (fingerprinting) takes place. The data remain in Germany and are not merged with other data and services.

Retention period

The data are deleted after 180 days.

Right to object

You can object to the recording of the data. To do so, you can create the so-called opt-out cookie below with a mouse click, which remains permanently valid. As a result, DC Data will no longer record your further use. Please note that the opt-out cookie is deleted when you delete your browser cookies.



Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter referred to as the „publication medium“). Reader data are processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers or for security reasons. In all other respects, we refer to the information on the processing of visitors to our publication medium within the scope of these privacy notices.

  • Types of data processed: Master data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Provision of contractual services and customer support; feedback (e.g., collecting feedback via online form).

  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

 

Contact and inquiry management

When contacting us (e.g., by contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the details of the inquiring persons are processed to the extent necessary to answer the contact requests and any requested measures.

The response to contact requests as well as the management of contact and inquiry data within the scope of contractual or pre-contractual relationships takes place for the fulfilment of our contractual obligations or for the response to (pre-)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

  • Types of data processed: Master data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms).

  • Data subjects: Communication partners.

  • Purposes of processing: Contact requests and communication; provision of contractual services and customer support.

  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR); legal obligation (Art. 6(1)(c) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to handle the matter raised. For this purpose, we process personal data within the scope of pre-contractual and contractual business relationships to the extent necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in the response to the matters raised and our statutory retention obligations.

 

Application process

The application process requires applicants to provide us with the data necessary for their assessment and selection. Which information is required is determined by the job description or, in the case of online forms, by the information provided there.

As a rule, the required information includes personal details such as name, address, a means of contact as well as evidence of the qualifications required for a position. Upon request, we will also be happy to inform you which details are required.

If available, applicants may submit their applications via an online form. The data are transmitted to us in encrypted form in accordance with the state of the art. Applicants may also send us their applications via email. In this case, however, please note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.

Applicants are welcome to contact us regarding the manner in which the application is to be submitted or to send the application to us by post.

Processing of special categories of data: Where, in the course of the application process, special categories of personal data within the meaning of Art. 9(1) GDPR (e.g., health data, such as severe disability status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights and fulfil the obligations arising for them from employment law and the law of social security and social protection, their processing takes place pursuant to Art. 9(2)(b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR or for the purposes of preventive or occupational medicine, for the assessment of the employee's working capacity, for medical diagnosis, for the provision or treatment in the health or social sector or for the administration of systems and services in the health or social sector pursuant to Art. 9(2)(h) GDPR. In the case of disclosure of special categories of data based on voluntary consent, their processing takes place on the basis of Art. 9(2)(a) GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job opening is unsuccessful, the applicant data will be deleted. The applicant data are also deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified revocation by the applicants, deletion takes place no later than after the expiry of a period of six months so that we can answer any follow-up questions regarding the application and comply with our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, takes place on the basis of consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application process and that they may revoke their consent at any time for the future.

Retention period of data in the applicant pool in months: 6

  • Types of data processed: Applicant data (e.g., personal details, postal and contact addresses, the application documents and the information contained therein, such as cover letter, CV, references, as well as other information about their person or qualifications communicated by applicants in relation to a specific position or voluntarily).

  • Data subjects: Applicants.

  • Purposes of processing: Application procedures (establishment and any later implementation as well as possible later termination of the employment relationship).

  • Legal bases: Application process as a pre-contractual or contractual relationship (Art. 9(2)(b) GDPR).

Further information on processing operations, procedures and services:

 

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to provide information about us.

We would like to point out that user data may be processed outside the territory of the European Union. This may result in risks for users because, for example, the enforcement of users' rights could be made more difficult.

Furthermore, user data within social networks are usually processed for market research and advertising purposes. For example, usage profiles may be created based on users' usage behaviour and resulting interests. These usage profiles may in turn be used to place advertisements within and outside the networks that are likely to match users' interests. For these purposes, cookies are generally stored on users' computers in which users' usage behaviour and interests are stored. Furthermore, usage profiles may also store data independent of the devices used by users (in particular if users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective processing operations and the opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we also point out that these can be most effectively asserted with the providers. Only the providers have access to the users' data in each case and can directly take appropriate measures and provide information. If you still need assistance, you can contact us.

  • Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Contact requests and communication; feedback (e.g., collecting feedback via online form); marketing.

  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

 

Amendment and updating of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We adjust the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require any action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and we ask you to check the information before making contact.

 

Rights of data subjects

As a data subject under the GDPR, you have various rights, which arise in particular from Arts. 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you that is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.

  • Right of access: You have the right to request confirmation as to whether data concerning you are being processed and to obtain access to those data as well as further information and a copy of the data in accordance with legal requirements.

  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively to request a restriction of the processing of the data in accordance with legal requirements.

  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller in accordance with legal requirements.

  • Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

 

Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The explanations below are intended primarily to aid understanding. The terms are listed alphabetically.

  • Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • Controller: The natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data is referred to as the „controller“.

  • Processing: „Processing“ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and in practice includes virtually any handling of data, whether collection, analysis, storage, transmission or deletion.