The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website and/or use any of our services herein. The term “personal data” comprises all data that can be used to personally identify you.
The data controller on this website is:
sportwetten.de GmbH
Kaistr. 4
40221 Düsseldorf
Phone: 0211781782-30
Email: [email protected]
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, email addresses, etc.).
We have appointed a data protection officer for our company.
NetX Betting Ltd.
170, Pater House, Level 1 (Suite A168)
Psaila Street
Birkirkara BKR9077 Malta
Phone: +49 211 781782-30
Email: [email protected]
We need to collect data from you to be able to provide you with the service of remote gaming. This may include the need to share these data with our partner companies and service providers, with whom we would have established safeguards to protect your data, for the purpose of providing you with our services as requested when you signed up and accepted the terms and conditions.
When we provide remote gaming services to our customers, we must collect personal data from you so that we can comply with our legal obligations related to our remote gaming licence requirements, as Kommentiert [VDG1]: The website URL should be specified. Kommentiert [CL2R1]: We will amend this in the final version Kommentiert [VDG3]: Include company details of the data controller (NetX Betting). Kommentiert [CL4R3]: We will amend this in the final version Kommentiert [VDG5]: Details of the DPO to be updated - Please do not publish name and surname of DPO, as this is not a requirement. Kommentiert [CL6R5]: We will amend this in the final version per the Malta Gaming Authority’s Regulations and Guidelines, for company tax reporting obligations to the tax authorities, and to meet our obligation to assist authorities, when requested, in the investigation of potential criminal activity. Failure to provide us with the requested personal data will preclude us from providing you with our services.
We also have a legitimate interest to protect our services from promotion abuse, fraudulent activities, and internet security risks. This also allows us to ensure the security, integrity, accessibility and availability of our data and services.
We may offer marketing communications so that you are constantly kept updated with news about new products, bonuses, special offers and other similar promotions. When this happens, we will ask for your consent to receive such communications. You will have the right at all times and at no cost to withdraw your consent either through your account profile privacy settings or by sending us an email at [email protected].
Other data shall be collected by our IT systems automatically or after you consent to its recording during your website visit. These data comprise primarily of technical information (e.g., web browser, operating system or time the site was accessed). For further information, please read our Cookie Notice.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analysed when your visit this website. Such analyses are performed primarily with cookies and with what we refer to as analysis programs.
We may collect and process the following categories of personal data:
We do not collect special categories of data on a regular basis; however, we may receive such data from you if you tell us that you have a problem controlling your betting activity. We would treat such data as equivalent to health data and protect it accordingly.
We herewith advise you that the transmission of data via the Internet (i.e., through email communications) may be prone to security gaps. It is not possible to completely protect data against third party access.
We use your personal data to:
When you explicitly consent to marketing, we use your data to provide you with information about site changes, new services, offers and promotions. In case you do not wish to no longer receive marketing information, you have the right to opt-out of this service. You can opt in again to receiving marketing communications by emailing our support department or by updating your preferences on your user profile.
To provide our services, and for the purpose of preventing illegitimate use of our services, we carry out profiling of our customers and their activities using automated processes. However, any decisions taken based on these profiles and information are taken by natural persons.
To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the email address provided during the registration process. These are service communications you cannot opt out of, as they form part of the service We provide to You.
Marketing Communications
If you would like to subscribe to the newsletter offered on this website, we will need from you an email address as well as information that allow us to verify that you are the owner of the email address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the email address and the use of this information for the sending of the newsletter at any time, by clicking on the “Unsubscribe” link in the newsletter, or by sending us an email at [email protected]. This shall be without prejudice to the lawfulness of any data processing that have occurred prior to your revocation.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not 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). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
In the event of the need of supply of personal data to third parties, a specific opt-in for transfer of your data to these third parties will be provided where the names of such parties and the purpose such persons may use your data will be disclosed. Such events may include for example marketing.
The Company may, however, disclose or transfer data you provide to us, or inferred data based on your data for multiple purposes such as to provide you with our services including but not limited to payment processing, customer support and Anti-Fraud / Anti-Money Laundering checks.
The Company may disclose or transfer data you provide to us, or inferred data based on your data for multiple purposes as described in the following sections.
A list of our third-party suppliers can be provided upon request.
Disclosures to third parties to provide you with services
Your personal data is transferred to some companies to carry out the following processes:
All mandatory information along with additional requested one, provided by players or potential players during the registration process may be processed for anti-money laundering (AML) purposes.
According to regulations in the German Glücksspielstaatsvertrag, sportwetten.de is obliged to transfer information to the nationwide gaming evaluation system LUGAS, in particular to monitor the cross-provider deposit limit and to prevent parallel gaming at multiple gambling providers
We ensure that data transfers with service providers are covered with appropriate controller-processor contracts and safeguards as specified by the General Data Protection Regulation (EU2016/679). Such contracts include confidentiality, strict processing rules, security safeguards, breach notification requirements and provision of assistance to the Company so that any exercise of your rights is satisfied.
In the event of a sale or purchase of any business, asset or share, we will attempt to inform you of it, as well as of the identity of the new Data Controller either by directly contacting you, by placing public notices on our website and potentially by using other appropriate media.
Disclosures to third parties to satisfy regulatory obligations and legitimate interests
When processing your betting account and its associated transactions, the Company and its contracted processors may need to appeal to credit rating agencies, fraud detection agencies and money laundering agencies to be able to comply with its regulatory and statutory obligations.
The purpose of such communications would be to:
Where such information is requested by payment providers in relation to enquiries regarding fraud, we shall also provide such personal data as long as the request for information is aimed to protect your rights and/or, the legitimate interest of the company to protect itself from fraud.
We ensure that data transfers outside of NetX Betting are covered by appropriate controller-processor contracts and safeguards as specified by the General Data Protection Regulation (EU 2016/679).
Disclosures to regulatory authorities
To satisfy our legal obligations, we may be requested to disclose your data to the:
This can include transferring of all personal details, verification documents, payment and betting transaction history, communications history, and any other information we have about you. The methods of transfer of such data may be prescribed by the relevant authority, over which we do not have control.
Disclosures for marketing purposes
The Company may share personal data with marketing partners only based on a freely given, specific, informed, and unambiguous consent from you. Such partners would be limited to receive contact information such as email address and sports preferences for marketing reasons.
You can withdraw your consent at all times through your account profile or by contacting us on [email protected].
Should you withdraw your consent, the company will inform marketing partners to stop their marketing communications to you as soon as we receive your request.
The company may share your personal data to third parties located outside of the European Economic Area (EEA). We will always ensure a similar degree of protection when transferring personal data outside the EEA, using measures such as transferring to countries deemed to hold an adequate level of data protection by the European Commission, and/or Standard Contractual Clauses issued by the European Commission.
You have the right to:
Your rights may be exercised in accordance with the Law, which might include restrictions on when you can exercise these rights.
You can exercise these rights by accessing your Privacy Dashboard or by contacting us at [email protected].
We will do our best to comply with your request within a month from confirmation of your identity; such period may be extended to two months, in the event of complex, repetitive or excessive requests. We will notify you if such case occurs, explaining the reason for the delay. We may also charge you a reasonable fee in the case of repetitive requests.
Right to log a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses. You can find a list of Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members.en
After the closure of any account, we will retains certain elements of personal data for a period of up to 10 years to meet our legal obligations towards Anti-Money Laundering and Countering Finance of Terrorism, Company and Taxation record-keeping obligations. Specifically:
We will also keep personal data for the purpose of presenting and processing in case of a litigation or a legal process which you, the relevant authorities or us may be party to, due to our provision of services to you.
If your account, in any of the above cases is not active, then we will not process the data further except for complying with the above legal obligations. All this information is stored in accordance with this Privacy Notice.
External Hosting
This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a website.
The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).
Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption programme. You can recognise an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Encrypted payment transactions on this website
If you are under an obligation to share your payment information (e.g., account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.
Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognise an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.
In some cases, it is possible that third party cookies are stored on your device once you enter our site (third party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.
Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping cart function) or those that are necessary for the optimization of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
In the event that third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
Cookie Consent with Usercentrics
Our website uses the Usercentrics cookie consent technology to obtain your consent to the storage of certain cookies on your device and data protection legislation compliant documentation of the former.
The party offering this technology is Usercentrics GmbH, Rosental 4, 80331 München, Germany, website: https://usercentrics.com/ (hereinafter referred to as “Usercentrics”).
Whenever you visit our website, the following personal data will be transferred to Usercentrics:
Moreover, Usercentrics shall store a cookie in your browser to be able to allocate your declaration(s) of consent or any revocations of the former. The data that are recorded in this manner shall be stored until you ask us to eradicate them, delete the Usercentrics cookie or until the purpose for archiving the data no longer exists. This shall be without prejudice to any mandatory legal retention periods.
Usercentrics uses cookies to obtain the declarations of consent mandated by law. The legal basis for the use of such cookies is Art. 6 Sect. 1 Sentence 1 lit. c GDPR.
Contract data processing agreement
Our company has executed a Contract Data Processing Agreement with Usercentrics. This is an Agreement mandated by data privacy protection legislation that warrants that Usercentrics processes all personal data of our website visitors exclusively in compliance with our instructions and in compliance with the GDPR.
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
Request by email, telephone or fax
If you contact us by email, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g., after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses so-called cookies. Cookies are text files, which are stored on your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this website is usually transferred to a Google server in the United States, where it is stored.
The storage of Google Analytics cookies and the utilization of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
For our application we use Firebase, a tool for analysis and monitoring. The provider of the service is the US company Google Inc. For the European area, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services.
Your data is also processed by Google in the USA, among other places. We would like to point out that in the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may result in various risks to the legality and security of data processing.
Google uses so-called standard contractual clauses (Article 46 (2) and (3) of the GDPR) as the basis for data processing for recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular in the USA) or a data transfer there. The Standard Contractual Clauses are templates provided by the European Commission. They are intended to ensure that your data complies with European data protection standards even if it is transferred to and stored in third countries (such as the USA). With these clauses, Google undertakes to comply with the European level of data protection when processing your relevant data, even if this data is stored, processed and managed in the USA. The basis for these clauses is an implementing decision of the EU Commission. The decision and the corresponding standard contractual clauses can be found here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en
The Google Ads Data Processing Terms referring to the standard contractual clauses can be found at https://business.safety.google/intl/en/adsprocessorterms/.
IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyse your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.
Browser plug-in
You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that in this case you may not be able to use all of the functions of this website to their fullest extent. Moreover, you have the option prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Objection to the processing of data by Google Analytics
You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation. For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Order processing
We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Google Analytics e-commerce measurement
This website uses the "e-commerce measurement" function of Google Analytics. With the help of e-commerce measurement, the website operator can analyze the purchasing behavior of website visitors to improve its online marketing campaigns. This involves recording information such as orders placed, average order values, shipping costs and the time from viewing to purchasing a product. This data can be summarized by Google under a transaction ID, which is assigned to the respective user or his device.
Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.
Demographic parameters provided by Google Analytics
This website uses the function “demographic parameters” provided by Google Analytics. It makes it possible to generate reports providing information on the age, gender and interests of website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.
Archiving period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details, please click the following link: https://support.google.com/analytics/answer/7667196?hl=en
Sportradar
We have integrated Sportsradar on this website. The provider is Sportradar Group AG, Feldlistr. 2, 9000 St. Gallen (hereinafter “ Sportradar”)
Sportsradar enables us to display targeted adverts on third-party websites based on information about bets placed with us (e.g., location data, type of sport and interests; target group targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing how many advertisements have led to corresponding clicks.
The use of this analysis and advertising tool is based on Art. 6 (1)(f) GDPR. We have a legitimate interest in analyzing user behavior in order to optimize both our advertising and our sports betting offer. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (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 details can be found in the provider's privacy policy at https://sportradar.com/privacy-notice/.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Newsleter data
If you would like to receive the newsletter offered on our website, we will need your email address and information that allows us to check that you are the owner of the email address you have provided and that you consent to receiving the newsletter. Further data are not collected or only done so on a voluntary basis. We use the newsletter service providers described below to process the newsletters.
Sendinblue
This website uses the services of Sendinblue to send out newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany. Sendinblue is a service that dispatches and analyses newsletters, amongst other things. The data you enter for the purpose of subscribing to the newsletter will be stored on the Sendinblue servers in Germany.
Data analysis by Sendinblue
Sendinblue allows us to analyse our newsletter campaigns and to determine whether a newsletter message has been opened and which links have been clicked on. Amongst other things, this allows us to determine which links were clicked particularly often. We can also see whether certain previously defined actions were performed after opening/clicking (conversion rate). For example, we can tell whether you made a purchase after clicking on the newsletter. Sendinblue also allows us to subdivide (“cluster”) newsletter recipients into different categories. For example, newsletter recipients can be subdivided according to age, gender or place of residence. In this way, the newsletters can be better adapted to the respective target groups.
If you do not wish your data to be analysed by Sendinblue, you should unsubscribe from the newsletter. To this end, we provide a link in every newsletter message.
For detailed information on the features of Sendinblue, please visit the following link: https://de.sendinblue.com/newsletter-software/.
Legal basis
We only process data on the basis of your consent (GDPR Article 6(1)(a)). You may revoke your consent at any time. The legality of any data processing already completed remains unaffected by the revocation.
Retention period
We and the newsletter service provider will store the data you provide us for the purpose of subscribing to the newsletter until you unsubscribe from the newsletter. It will be deleted from the newsletter distribution list after you unsubscribe from the newsletter. Any data stored by us for other purposes remains unaffected.
After you unsubscribe from the newsletter distribution list, we and the newsletter service provider may store your email address in a blacklist if this is required to prevent future mailings. The blacklist data is used only for this purpose and not 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(1)(f) of the GDPR). Storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
You can find detailed information in the Sendinblue privacy policy at: https://de.sendinblue.com/datenschutz-uebersicht/.
Commision data processing
We have concluded a commissioned data processing contract (DPC) with the above-mentioned provider. This contract is prescribed under data privacy law, and guarantees that the provider only processes the personal data of visitors to our website in accordance with our instructions and in compliance with the GDPR.
Google Web Fonts
To ensure that fonts used on this website are uniform, this website uses so-called Web Fonts provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts.
To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access this website. The use of Google Web Fonts is based on Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in a uniform presentation of the font on the operator’s website. If a respective declaration of consent has been obtained (e.g., consent to the archiving of cookies), the data will be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. Any such consent may be revoked at any time.
If your browser should not support Web Fonts, a standard font installed on your computer will be used.
For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyses the behaviour of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.
reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.
Data are stored and analyzed on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If a respective declaration of consent has been obtained (e.g., consent to the archiving of cookies), the data will be processed exclusively on the basis of Art. 6 Sect. 1 lit. a DGDPR. Any such consent may be revoked at any time.
For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms Of Use under the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en
Contact Form/Live Chat
Scope of processing personal data
The data you enter in our contact form or live chat.
The legal basis for the processing of this personal data is Art. 6 para. 1 lit.f of the GDPR (legitimate interest). If you use the contact form or chat, we assume that you have an interest in contacting us and exchanging information.
Purpose of data processing
We will use the data recorded via our contact form or chat to process the specific information request.
Duration of storage
If data is no longer required for further fulfilment of the contract or for provision of services or if there are storage obligations, then the collected data will be deleted after the request for information has been processed.
Option to object and delete
The options to object to data processing and to delete data are based on the general legislation.
Processing of data (customer and contract data)
We collect, process and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or precontractual actions. We collect, process and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them.
The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.
Data transfer upon closing of contracts for services and digital content
We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.
Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.
The basis for the processing of data is Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.
Klarna
Among other options, we offer payment through the services of Klarna on this website. The provider is Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter referred to as “Klarna”).
Klarna offers a wide spectrum of payment options (e.g., payment by instalment). If you should decide to pay through Klarna (Klarna checkout solution), Klarna will collect personal data from you. For specifics, please review Klarna’s Data Protection Declaration by following this link: https://www.klarna.com/us/privacy-policy/.
Klarna uses cookies to optimise the use of Klarna checkout solutions. The optimisation of the checkout solution constitutes a legitimate interest as defined in Art. 6 Sect. 1 lit. f GDPR. Cookies are small text files that can be stored on your device and that do not cause any damage to your device. The information stays on your device until you delete it. For details concerning the use of Klarna cookies, please follow this link: Klarna cookie policy.
The legal basis for the sharing of your data with Klarna is Art. 6 Sect. 1 lit. a GDPR (consent) as well as Art. 6 Sect. 1 lit. b GDPR (processing for the fulfilment of a contract). You have the option to at any time revoke your consent to the processing of your data. Such a revocation shall not have any impact on the effectiveness of data processing transactions that occurred in the past.
Instant transfer Sofort
Among other options, we offer the payment service called “instant transfer Sofort” on this website. The provider of this payment option is the Sofort GmbH, Theresienhöhe 12, 80339 München, Germany (hereinafter referred to as “Sofort GmbH”).
With the assistance of the “instant transfer Sofort” tool, we receive a payment confirmation from the Sofort GmbH in real time, which allows us to instantly start to fulfil our obligations to you.
When you choose the “instant transfer Sofort” payment option, you must send a PIN and a valid TAN to the Sofort GmbH, which allows the company to log into your online banking account. Upon logging in, the Sofort GmbH will verify your account balance and will execute the bank transfer to us with the assistance of the TAN you provided. Subsequently, the company sends us an immediate transaction confirmation. After Sofort GmbH has logged in, the system will also automatically verify your revenues and check the credit limit of your pre-approved overdraft credit line and the existence of other accounts along with their balances.
Along with the PIN and TAN numbers, the system also transfers the payment information you entered along with personal data to the Sofort GmbH. Your personal data comprise your first and last name, address, phone number(s), email address, IP address as well as any other data required for the processing of the payment transaction. This data must be transferred in order to be able to determine your identity with absolute certainty and to prevent attempts to commit fraud.
The legal basis for the sharing of your information with the Sofort GmbH is Art. 6 Sect. 1 lit. a GDPR (consent) as well as Art. 6 Sect. 1 lit. b GDPR (processing for fulfilment of a contract). You have the option to at any time revoke your consent to the processing of your data. Such a revocation shall not have any impact on the effectiveness of data processing transactions that occurred in the past.
For details on payments made with the instant transfer option, please follow these links: https://www.sofort.de/datenschutz.html and https://www.klarna.com/sofort/.
We offer you the opportunity to apply to us (e.g. by email, post or online application form). Below 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.
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 interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG under German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and - if you have given your consent - Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.
In addition to the recipients mentioned above, your application data may be passed on to other affiliated companies within our Group if necessary. This transfer takes place exclusively for internal purposes in the context of application management and is in accordance with Art. 6 para. 1 lit. f GDPR. The legitimate interest here lies in the efficient and Group-wide use of applicant data in order to identify and offer potential employment opportunities within the Group.
If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship
Retention period of the data
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 apparent that the data will be required 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.
Longer storage may also take place if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations prevent deletion.
Inclusion in the applicant pool
If we do not make you a job offer, you may have the opportunity to join our applicant pool. If you are accepted, all documents and information from your application will be transferred to the applicant pool in order to contact you in the event of suitable vacancies.
Inclusion in the applicant pool takes place exclusively on the basis of 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 irrevocably deleted from the applicant pool, provided there are no legal grounds for retention.
The data from the applicant pool will be irrevocably deleted no later than two years after consent has been given.
HRworks
We use HRworks for our application management. The provider is HRworks GmbH, Waldkircher Str. 28, 79106 Freiburg.
HRworks is a comprehensive software solution for personnel management that offers functions for efficient application management, among other things. By using HRworks in the application process, applicant data can be managed in a structured and secure manner, which supports both efficiency and compliance with data protection regulations. HRworks is used on the basis of Art. 6 para. 1 lit. f GDPR. The legitimate interest for the processing of personal data via HRworks in the context of application management lies in the optimization and professionalization of the recruitment process, which is in the interest of both the company and the applicants.
You can find details about HRworks here: https://www.hrworks.de/unternehmen/datenschutz/
Order processing contract
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 ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
Any changes we may make to our Privacy Notice in the future will be published from this page on the site and will be effective from the time of their posting. You can request previous versions of this document by sending us an email at [email protected].
Last date: 31.05.2022