DEUBLIN welcomes your visit to our website as well as your interest in our company and our products.

Data protection has a high priority for DEUBLIN (hereinafter also referred to as "we", "us"). Therefore, the principle applies: Where personal data is processed, a high level of data protection and data security must be guaranteed. This applies to data from customers, suppliers and business partners as well as employee data.

As a global company we want to comply with the different legal requirements that apply worldwide to the collection and processing of personal data. The European Data Protection Regulation (GDPR) establishes a common European standard supplemented by existing national regulations.

In the following, we will inform you about how we implement this standard within the company.

 

Privacy Policy

 

The use of the Internet pages of DEUBLIN is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to DEUBLIN. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, DEUBLIN has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1.

Definitions

 

The data protection declaration of DEUBLIN is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a.

Personal data

 

Personal data means any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b.

Data subject

 

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c.

Processing

 

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d.

Restriction of processing

 

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e.

Profiling

 

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f.

Pseudonymizing

 

Pseudonymizing is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g.

Controller or controller responsible for the processing

 

Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h.

Processor

 

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i.

Recipient

 

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j.

Third party

 

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k.

Consent

 

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2.

Name and Address of the controller

 

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

DEUBLIN GmbH
Florenzallee 1
55129 Mainz
Germany
Phone: +49 6131 4998-0
E-Mail: receptionde@deublin.eu

3.

Cookies

 

The Internet pages of DEUBLIN use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, DEUBLIN can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4.

Collection of general data and information

 

The website of DEUBLIN collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, DEUBLIN does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, DEUBLIN analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5.

Subscription to our newsletters

 

On the website of DEUBLIN, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

DEUBLIN informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

6.

Newsletter-Tracking

 

The newsletter of DEUBLIN contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, DEUBLIN may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. DEUBLIN automatically regards a withdrawal from the receipt of the newsletter as a revocation.

7.

Contact possibility via the website

 

The website of DEUBLIN contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

8.

Routine erasure and blocking of personal data

 

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

9.

a.

Rights of the data subject

Right of confirmation

 

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b.

Right of access

 

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing
  • the categories of personal data concerned
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
  • the existence of the right to lodge a complaint with a supervisory authority
  • where the personal data are not collected from the data subject, any available information as to their source
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c.

Right to rectification

 

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d.

Right to erasure (Right to be forgotten)

 

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by DEUBLIN , he or she may, at any time, contact any employee of the controller. An employee of DEUBLIN shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of DEUBLIN will arrange the necessary measures in individual cases.

e.

Right of restriction of processing

 

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by DEUBLIN, he or she may at any time contact any employee of the controller. The employee of DEUBLIN will arrange the restriction of the processing.

f.

Right to data portability

 

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the DEUBLIN GmbH.

g.

Right to object

 

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

DEUBLIN shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If DEUBLIN processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to DEUBLIN to the processing for direct marketing purposes, DEUBLIN will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by DEUBLIN for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of DEUBLIN. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h.

Automated individual decision-making, including profiling

 

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, DEUBLIN shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of DEUBLIN.

i.

Right to withdraw data protection consent

 

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of DEUBLIN.

10.

Data protection provisions about the application and use of Facebook

 

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/ During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

11.

Data protection provisions about the application and use of Google Analytics (with anonymization function)

 

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons. Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

12.

Data protection provisions about the application and use of Google+

 

On this website, the controller has integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.

The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the Internet browser on the information technology system of the data subject automatically downloads a display of the corresponding Google+ button of Google through the respective Google+ button component. During the course of this technical procedure, Google is made aware of what specific sub-page of our website was visited by the data subject. More detailed information about Google+ is available under https://developers.google.com/+/.

If the data subject is logged in at the same time to Google+, Google recognizes with each call-up to our website by the data subject and for the entire duration of his or her stay on our Internet site, which specific sub-pages of our Internet page were visited by the data subject. This information is collected through the Google+ button and Google matches this with the respective Google+ account associated with the data subject.

If the data subject clicks on the Google+ button integrated on our website and thus gives a Google+ 1 recommendation, then Google assigns this information to the personal Google+ user account of the data subject and stores the personal data. Google stores the Google+ 1 recommendation of the data subject, making it publicly available in accordance with the terms and conditions accepted by the data subject in this regard. Subsequently, a Google+ 1 recommendation given by the data subject on this website together with other personal data, such as the Google+ account name used by the data subject and the stored photo, is stored and processed on other Google services, such as search-engine results of the Google search engine, the Google account of the data subject or in other places, e.g. on Internet pages, or in relation to advertisements. Google is also able to link the visit to this website with other personal data stored on Google. Google further records this personal information with the purpose of improving or optimizing the various Google services.

Through the Google+ button, Google receives information that the data subject visited our website, if the data subject at the time of the call-up to our website is logged in to Google+. This occurs regardless of whether the data subject clicks or doesn’t click on the Google+ button.

If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of his Google+ account before calling up our website.

Further information and the data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. More references from Google about the Google+ 1 button may be obtained under https://developers.google.com/+/web/buttons-policy.

13.

Data protection provisions about the application and use of Google-AdWords

 

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.com/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

14.

Data protection provisions about the application and use of YouTube

 

On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google

15.

Legal basis for the processing

 

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company 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. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

16.

The legitimate interests pursued by the controller or by a third party

 

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

17.

Period for which the personal data will be stored

 

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

18.

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

 

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

19.

Existence of automated decision-making

 

As a responsible company, we do not use automatic decision-making or profiling.

 

Data Protection Policy

 

 

Präambel

 

DEUBLIN is the leading manufacturer of Unions – mechanical devices used to transfer fluid from a stationary source into a rotating piece of machinery. Rotating Unions are used in numerous manufacturing processes to cool, heat, or transfer fluid (pneumatic or hydraulic) power.

We sell our products to national and international customers and are positioned within the relevant market as supplier of innovative and customer-focused solutions with high-quality products.

Data protection has a high priority for DEUBLIN. It applies to us the principle: Where personal data is processed, a high degree of data protection and data security must be guaranteed. This applies to data from customers, prospects and business partners as well as employee data. Any personal information provided to us will be processed in accordance with applicable regulations and always with a specific purpose.

As a global company we want to comply with the different legal requirements that apply worldwide to the collection and processing of personal data. The EU GDPR creates a common European standard, which we implement in the company with this privacy policy.

1.

Scope

 

This Data Protection Policy applies to DEUBLIN. It applies, whenever DEUBLIN acts as the processor or as the controller of personal data, for their employees as well as for persons with equivalent functions as employees, such as temporary workers. It covers all processing of personal data in the company.

This Privacy Policy applies to DEUBLIN and its employees (or employees of functional equivalents, such as temporary workers, interns, etc.) who process personal data themselves as "responsible persons" or on behalf of "processors". It covers all work steps and processes that affect personal data. Anonymized data (such as statistical evaluations) as well as company data or data of legal persons are not subject to the Data Protection Policy, unless they permit conclusions to a certain person.

Rules deviating from this data protection policy may only be made in consultation with the data protection officer and the management.

2.

Definitions

 

Personal data is any information that relates to an identified or identifiable natural person (hereinafter referred to as "the data subject"); a natural person is identified as being identifiable directly or indirectly, in particular by means of assignment to an identifier such as a name, identifier, location data, an online identifier or one or more particular features.

Special categories of personal data include information on racial and ethnic origin, political opinion, trade union affiliation, political opinion, religious or ideological conviction, genetic data, biometric data for definite identification of a person, health, sexual life, or sexual orientation. These are subject to special protection regulations.

Processing of personal data is any process carried out with or without the help of automated procedures or any such series of operations in connection with personal data such as collection, gathering, organization, ordering, storage, adaptation or modification, reading, use, disclosure by transmission, publishing or any other form of providing information, matching or linking, limitation, deletion or destruction.

Anonymization: Data are anonymized when a no personal reference is possible permanently and by anyone, or if the reference can only be recovered with a disproportionate amount of time, costs and labor power. An essential part of the anonymization is, in any case, the deletion of explicit or direct identification features, such as names and addresses, person identifiers, account numbers.

Data transmission is the transfer of data to a third party (other controller), including the retrieval of the data. The Controller is any entity or person outside DEUBLIN, even if the recipient belongs to DEUBLIN group.

An order processing is carried out when an (external) contractor is charged with the processing of personal data and he processes these data strictly according to the instructions of DEUBLIN as a customer (e.g. storage of data in the data center, printing / sending of salary statements, destruction of data media or paper waste, possible data access from maintenance work). There is no transfer of responsibility for the associated business process to the contractor. DEUBLIN has to select a processor, in particular, according to compliance with data protection regulations.

3.

Responsibilities

 

Management

The managing directors of DEUBLIN are responsible for data processing in their area of responsibility. It is the responsibility of the management to ensure a legally compliant data processing through organizational, technical and personnel measures and guidelines.

Employees

Each employee is responsible for the compliance and implementation of these requirements in his area and must ensure that the data protection requirements comply with in the selection of any contractors who are to be employed, by means of appropriate selection and monitoring.

Employees, who maintain customer contacts due to their role, only collect data essential for the conduct of the business.

Data Protection Officer (DPO)

If a company data protection officer is required under European or national law, a data protection officer (DPO) shall be appointed in writing. The DPO is responsible in particular for informing and advising management and employees of DEUBLIN in regard to operation of the data processing, monitoring of compliance with data protection requirements, as well as cooperation with the supervisory authority. The DPO shall monitor, where necessary, the legal basis of all procedures and contracts which contain personal data in cooperation with the Legal Department.

The DPO monitors compliance with the laws and regulations on data protection as well as the company's strategies for the protection of personal data, including the awareness and training of employees involved in the processing operations and the relevant monitoring. The DPO reports directly to the management and is to be provided with the resources necessary to fulfill its tasks. The data protection officer acts independently and is not to be bound by any instructions.

The DPO advises DEUBLIN GmbH on data protection impact assessments as well as on the planned processing of special categories of personal data. The DPO is the point of contact for the supervisory authority for all questions relating to the processing of personal data and prior consultation in the context of data protection impact assessments.

To this end, he shall be duly informed at an early stage by the management about any plans for the automated processing of personal data and shall be provided with the resources necessary for the fulfillment of these tasks and the access to personal data and processing as well as the resources necessary to maintain his expertise.

The DPO works in applying his expertise in regard of data protection without instructions on the exercise of his duties. The DPO shall draw up an annual activity report, report to the management as necessary and advise necessary measures.

HR Manager

Regarding personnel data, the "HR managers" are responsible for compliance with data protection. They handle personal files and data (any records of the company about employees) strictly confidential. It must be ensured at all times that no unauthorized persons have access to these data.

On request, the employee is to be granted access to all records made about him. If a request is made electronically and is not requested otherwise, the copy shall be issued in a common electronic form.

The "HR Manager" ensures the signing of the required commitments to data secrecy for new hires.

The transmission of personnel data within the DEUBLIN group is only permissible in accordance with the provisions of the General Data Protection Regulation (GDPR) and other national legislation on data protection as well as the existing works council agreements. New projects for the transmission of employee data within the DEUBLIN group are to be reported to the Data Protection Supervisor in advance.

All evaluations of personal data are to be coordinated with the responsible works councils and the DPO.

4.

Data Protection Principles

 

Personal data may only be processed if there is a statutory permit list pursuant to Article 6 of the General Data Protection Regulation (GDPR).

4.1.

Admissibility and Legality of Data Processing

 

In principle, the use of personal data is prohibited. Personal data may in particular be processed only if:

  • by consent of the data subject for one or more specific purposes, or
  • it is necessary for the fulfillment of a contract of which the data subject is a contractor or for the implementation of pre - contractual measures which are carried out at the request of the data subject or
  • the processing is necessary to fulfill a legal obligation to which DEUBLIN is subject as a company, or
  • the processing is necessary to protect the vital interests of the data subject or any other person, or
  • it is necessary to safeguard the legitimate interests of DEUBLIN or a third party and does not violate the interests or fundamental rights and fundamental freedoms of the person concerned.

The personal data is to be collected from the person concerned.

4.2.

Transparency

 

As a company, DEUBLIN is obliged to inform affected persons in a clear, understandable form, in a clear, easy and accessible manner whether and how their personal data is processed. The data subject must be informed prior to the collection of the data and before consent is given. The person concerned must be informed:

  • Who collects, processes or uses the data. The name and contact details of DEUBLIN as well as the data protection officer must be mentioned,
  • Why the data are collected. The purpose of the collection, processing, use of its data as well as the legal basis for this are to be communicated,
  • When applying the balancing of interest's clause, the legitimate interests of DEUBLIN or of the third party must be communicated,
  • Which data is collected and the extent of the personal data processed,
  • Where the data is processed. In the case of data transmission, the data subject shall be informed of further recipients or categories of recipients, for example other DEUBLIN companies, to which the data are transmitted, the purpose of the transmission and, where appropriate, the third country including information about an appropriate level of data protection,
  • How long the personal data is stored (storage time) or how the criteria for the storage period are,
  • The rights of the data subject, see point 8.

If the data has not been collected by the person concerned, the affected person must be informed within one month after obtaining his personal data.

In principle, a declaration of consent is to be obtained in writing and, if possible, not coupled with general terms and conditions. In exceptional cases, e.g. in case of telephone advice or a customer complaint, the consent may also be given orally. A consent given in this way must be documented.

The consent of the person concerned must be given voluntarily without any compulsion, for a specific situation, in knowledge of the facts and unambiguously in the form of a written declaration or other clear action.

Consent is not given as voluntary if personal data are used for different processing operations without a separate consent, although this is appropriate in the individual case. A consent shall be invalid if the performance of a contract or the provision of a service is made conditional upon the person concerned consenting to a data processing, even though this is not necessary for the performance of the contract or the service (non-coupling obligation).

Thus, the customer's consent to the processing of his personal data in the case of a customer request may not be linked to the fact that his personal data is used for the sending of a newsletter.

The person concerned has the right to revoke his consent at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. The data subject is informed of this prior to submitting consent. The revocation of the consent must be documented in writing.

4.3.

Purpose Limitation and Deletion Obligation

 

Personal data may only be collected for established, unambiguous and legal purposes and may not be further processed in a manner incompatible with these purposes. The data shall be stored in a form which allows the identification of the persons concerned, at most for as long as necessary and to the extent necessary for the purposes for which they are processed. After this purpose, they shall be deleted.

The purposes shall be communicated to the data subject prior to data collection. Changes of the purpose are permissible only within strict legal limits. For example, data collected for contractual purposes may not be used for advertising purposes. The person concerned is to be informed about a change of purpose.

4.4.

Data Minimization

 

In principle, the less data is processed, the better. Only the data may be collected, used and processed, which are necessary for achieving the respective purpose. Therefore, the collection and storage of personal data must be limited to the necessary extent and the data processing systems must be designed accordingly. In input masks, only those fields that are actually required for the purpose being pursued should be mandatory for input.

Anonymized or pseudonymized data are preferably to be used as long as the purpose pursued can be achieved in this way without undue additional effort.

Personal data which is no longer required for the achievement of a purpose, e.g. the fulfillment of the contract is to be deleted. If the deletion contains a legal retention period, the data may be kept for this purpose, but must be blocked for other purposes. Appropriate deletion, anonymization and archiving concepts must be introduced in the respective DEUBLIN affiliates.

4.5.

Design of Information Technology

 

IT systems must be designed in such a way as to effectively implement the objectives of this Policy, in particular, it is important to ensure that they only collect as much data as is necessary to fulfill the objective pursued. This is to be ensured, in particular, by means of data-protecting presets.

The requirements of data protection must be taken into account when developing, designing and implementing new IT systems and applications.

4.6.

Correctness and Timelines

 

Personal data are to be stored correct, complete and, where necessary, kept up-to-date. Adequate measures must be taken to ensure that the data is regularly updated in databases, and that non-relevant or obsolete data is deleted.

4.7.

Confidentiality, Availability and (Data) Integrity

 

Confidentiality: Personal data is subject to data secrecy and must always be handled confidentially. Any unauthorized processing as well as the use or disclosure for purposes other than the original and approved, especially for private or commercial purposes, is prohibited. Any employee as well as persons with equivalent functions as employees shall be obligated to the data secrecy in writing. The Need-to-know principle shall be applied: Employees may only have access to personal data as far as this is necessary for their respective tasks. This applies irrespective of whether the data processing is done electronically or in paper form.

Availability: Personal data is to be protected at all times against unauthorized access, unlawful processing or disclosure, as well as against loss, falsification or destruction.

(Data) Integrity: personal data must be processed in such a way that the original entries can be stored unaltered or that changes / updates can be tracked.

DEUBLIN GmbH shall take appropriate technical and organizational measures (TOMs) in order to achieve these objectives. Owing to the fact that company and business secrets are processed using the same IT systems and processes, the "maximum principle" (= the stricter rule from both worlds) should be applied.

These TOMs are to be introduced and documented by DEUBLIN GmbH on the basis of a risk analysis. The TOMs are to be checked regularly once a year and also before the introduction of new applications or IT systems and, if necessary, adapted to the current situation / threat situation.

4.8.

Accountability

 

The management is responsible for compliance with the data protection principles and must be able to verify their compliance.

In addition, the management has to verify the implementation of the necessary prerequisites for complying with data protection regulations in account reports.

5.

5.1.

Handling of Certain Groups of Personal Data

Data Processing for the Employment Relationship and Employment Data

 

In the recruitment process or in employment relationship, personal data may only be processed if necessary for the initiation, basis, execution and termination of the employment relationship. After rejection, the data of the applicant must be deleted, taking into account evidence deadlines, unless the applicant has agreed to a further storage for a subsequent selection process in writing.

Personal data may only be used for the purpose of detecting criminal offenses in the case of a justified suspicion, that is, if actual evidence (to be documented) give rise to the suspicion that the person concerned has committed a criminal offense in the employment relationship and does not prejudge the legitimate interest of the person concerned. In the case of this type of data use, the persons concerned must be informed about this after the completion of the measures, of the fact that the collected data are to be handed over to the investigating authorities in a logged form.

5.2.

Customers, Prospective Customers, Business Partners

 

Personal data from customers, business partners or interested parties may only be processed for initiating, justifying, conducting or terminating a contract or legal transaction as well as for customer support. Corresponding restrictions imposed by the interested party or business partners must be observed as well as the obligation to delete the data after the end of the business relationship (unless a different retention requirement exists).

There are separate legal requirements for customer loyalty or advertising measures. The processing of personal data for advertising purposes is permitted provided that this is compatible with the original purpose of the data collection. If data is collected exclusively for advertising purposes, the person concerned may disclose their data voluntary. The person concerned is to be informed about the voluntary nature and the use of his data for advertising purposes, a consent of the person concerned is to be obtained.

If the advertisement is to be made electronically (e.g. in the case of advertising newsletters), an explicit, verifiable consent of the person concerned is required. In the case of electronic consent, the so-called "double opt-in procedure" must always be applied. All advertising mails must be accompanied by a note that the person concerned can refuse to obtain advertising mail in future at any time.

If the advertising approach is made by telephone, an explicit consent of the person concerned is also required. A presumed consent is required in the case of telephone advertising addressed to traders or legal persons. This is the case if the sending of the advertising is objectively in the interests of the person concerned and so far, he has not given or rejected explicit consent. The caller’s phone number must always be visible to the person concerned.

Advertising by means of letters or advertising mails (handouts, brochures, etc.) is, in principle, possible provided that the person concerned has not expressed any contrary will.

5.3.

User Data on the Internet and Social Media

 

Should personal data be processed on corporate websites or in apps, the affected persons are to be informed of this in privacy statements and, if necessary, by cookie notes. These are to be integrated in such a way that they are easily recognizable, directly accessible and constantly available to those concerned.

If usage profiles are generated to evaluate the user behavior of websites and apps (tracking), affected persons must be informed of this in the data protection notes. Furthermore, an order processing agreement must be concluded with the provider of the tracking solution, as long as it works with any reference to persons. If the tracking is carried out under a pseudonym, the person concerned is to be offered a possibility of objecting in the data protection instructions.

If access to personal data is permitted in the case of websites or apps in a domain that is subject to registration, the authentication of the data subjects shall be designed in such a way as to ensure appropriate protection for the respective access. It is always necessary to apply a double-opt-in method.

The processing or combination of personal data from social media platforms and existing customer data always requires the consent of the user. For example, if a user is a fan of a Facebook business page, the user does not automatically have permission to use his or her data for advertising or data collation.

6.

Transfer of Personal Data to Third Parties

 

The transmission of personal data is subject to special risks. A distinction must be made between a data transfer to third parties and the transfer of data within the scope of order processing.

6.1

Order Processing

 

In the case of order processing, the conclusion of a written data protection agreement with both external contractors as well as between companies within the DEUBLIN group is compulsory.

As part of the selection process, the project owner has to make sure of contractor’s compliance with the contractual obligations before commissioning and to document this accordingly. In particular, it must be considered that the Contractor is able to ensure the required level of data protection. Compliance with the data security requirements can be demonstrated by a contractor in particular by providing a suitable certification, e.g. by ISO27001 test certificates, audit reports by competent supervisory authorities, etc. Depending on the risk of data processing, the controls must be repeated regularly during the contract period, audit results must be documented in writing.

6.2

Transfer of Personal Data

 

Any transfer of data to recipients within or outside the DEUBLIN group needs a legal basis; either a law or a contract must permit data transmission or the consent of the data subject must be available.

A data transfer or data exchange, including the processing of personal data of customers and employees, may be carried out for internal administrative purposes within the DEUBLIN group, provided that the legitimate interests of the data subject are not infringed. The transfer of employment data is subject to special examination, the necessity in regard to the employment relationship must be proofed. The recipient of the data must be contractually obliged to use it only for the purposes specified.

When transferring data to a recipient outside the European Union or the European Economic Area, it must be ensured that an equivalent level of data protection recognized by the EU is ensured. (SCC, Privacy Shield, BCRs)

7.

Rights of the Data Subject

 

Any data subject may exercise the following rights against DEUBLIN. Any assertion of rights by data subjects must be forwarded immediately to the DPO. The DPO will process the request with the responsible department and meet specific deadlines and requirements. The exercise of their rights must not lead to any disadvantages for the data subjects.

Right of access: The person concerned may at any time request from DEUBLIN, if and which personal data concerning him for which purposes is processed and/or transferred. In particular, he has in particular a right of information about:

  • The processing purposes,
  • The categories of personal data,
  • The recipients or categories of recipients to which his / her personal data has been disclosed,
  • The planned duration for which the personal data is stored or, if this is not possible, the criteria for determining this duration,
  • The existence of a right to rectify or delete the personal data concerning him or to restrict the processing or a right of objection to such processing,
  • The existence of an infringement right with the competent supervisory authority,
  • If the personal data is not collected by the data subject, all available information on the origin of the data
  • The appropriate guarantees under Article 46 of the GDPR when personal data is transferred to a third country or an international organization.

If the information is not available online, the first copy must be free of charge. As far as the inquiry of the person concerned is done electronically, the information is provided by a read-only PDF file. The information is always sent to the (electronic) address, that has been stored at DEUBLIN.

The granting of information is excluded or may be restricted if these rights and freedoms of other persons, in particular business secrets or intellectual property rights, would be affected.

In case of doubt as to the identity of the applicant concerned, DEUBLIN must request additional information. If these are not sufficient, a statement can be refused with justification, until the necessary proof has been given.

If, in accordance with the respective labor law, extended access rights are provided in employment documents (for example personnel records), these remain unaffected.

Right to Copy and Sata Portability: A person concerned may request a copy of the relevant personal data which he has provided to DEUBLIN. This presupposes that the processing was carried out by means of automated procedures and on the basis of the consent of the data subject or the execution of a contract. The copy must be made available in a structured, standard and machine-readable form or, if required, to be transmitted to third parties, if this is technically feasible. A copy must be made available to the person concerned free of charge.

The rights and freedom of other persons shall not be affected by this right. In the case of justified doubts about the identity of the person asking, additional information must be requested. If these are not sufficient, a statement can be refused with justification, until the necessary proof has been given.

Right to Object: The person concerned is entitled at any time to oppose the processing of his data, which is necessary for the performance of a task or to safeguard the legitimate interests of DEUBLIN or a third party, as far as interests or fundamental rights and fundamental freedoms of the data subject which require the protection of personal data, do not prevail. In the event of an objection, the personal data may not be processed unless DEUBLIN can give proof that the processing of the data prevail over the interests, rights and freedoms of the data subject or the processing serves to assert, exercise or defend legal claims.

The data subject may object to the processing of his personal data for the purposes of direct advertising. In that case, the data may not be processed for these purposes any more.

The person concerned must be informed of his / her right of objection at the earliest time of communication, in an understandable form and separate form from other information.

In addition, he may request the restriction of the processing of his data under the following conditions:

  • The accuracy of the personal data is disputed by the person concerned (for a period of time which allows DEUBLIN to verify the correctness of the personal data),
  • The processing is unlawful and the person concerned rejects the deletion of the personal data and instead requests the restriction of the use of the personal data,
  • DEUBLIN GmbH no longer needs the personal data for the purpose of processing, but the person concerned requires it to assert, exercise or defend legal claims, or
  • The data subject has filed an objection against the data processing, as long as it is not yet clear whether the legitimate reasons of the DEUBLIN-company are superior to those of the person concerned

In cases of limitation of processing, DEUBLIN may initially only store and no longer process the data in any other way, unless statutory or official requirements stipulate otherwise. Exceptions from this are, next to a consent of the person affected, only possible for assertion, exercise or defense legal claims or to protect the rights of another natural or legal persons. The data subject shall be informed if the processing is carried out on the basis of one of the abovementioned exceptions.

Right of Rectification: Should personal data be incorrect or incomplete, the person concerned may immediately request their correction or supplement, provided that this is appropriate with regard to the respective processing purposes.

Right to Restriction of Processing: The person concerned is entitled to demand the blocking of his personal data. The data shall be blocked if the person concerned disputes the data on the assertion, exercise or defense of legal claims, or if he has opposed the processing and has not yet determined whether the data must be deleted. Use of the blocked data by DEUBLIN is only permitted to assert, exercise or defend legal claims, to protect the rights of another natural or legal person or for reasons of a major public interest. In case the data blocking is lifted, the affected person must be informed beforehand.

Right to Restriction / Right to be Forgotten: The data subject is entitled to demand the deletion of his / her data. A basis for the claim for cancellation exist if the legal basis for the processing of the data is missing or omitted or if the data subject revokes his consent to data processing and there is no other legal basis for the processing. The same applies if the purpose of the data processing is limited by time sequence or for other reasons, in particular if it is no longer necessary. A sample for an application for deletion shall be made available to the person concerned.

Where personal data that has to be deleted or has been made public by DEUBLIN, appropriate measures, including those of a technical nature, must be taken, taking into account the available technology and the implementation costs, in order to inform the third parties who are now processing the personal data that the person concerned has requested the deletion of all links to these personal data or of copies or replication of these personal data.

Existing retention obligations and the protection of interests which are contrary to a deletion must be taken into account.

8.

Data Protection Breaches, Reporting Obligations

 

In the case of a breach of the protection of personal data it is irrelevant whether this occurred unintentionally or unlawfully. To avoid or limit damage to the company and to pay fees up to millions, data protection transactions must be reported immediately and efficiently to the data protection officer and to the supervisory authorities.

Each employee is obliged to report immediately to his or her supervisor or data protection officer any violations of this Privacy Policy or other rules for the protection of personal data. Responsible management is obligated to inform the data protection officer immediately about data protection incidents.

In cases of unauthorized transfer of personal data to third parties, unauthorized access by third parties to personal data, or loss of personal data, the notifications provided in the company must be carried out without delay so that existing reporting obligations of data protection incidents to the competent supervisory authority (deadline within 72 hours) can be met.

If the violation of personal data is likely to lead to a high risk for the personal rights and freedoms of natural persons, next to competent supervisory authority, the person concerned must also be informed without delay of the nature of the infringement and of the countermeasures taken.

9.

Records of Processing Activities

 

DEUBLIN must create records of processing activities, the purpose of the records of processing activities is to create a documentation,

  • Which personal data,
  • On which legal basis,
  • Using what automated procedures,
  • are processed in what way and
  • Which data protection measures are implemented.

The purpose of the records of processing activities is to provide transparency for the processing of personal data both within the company and (at the request of) the data protection officer and the data protection supervisory authority. The records must be sufficiently informative to enable a preliminary assessment of the adequacy of technical and organizational data protection measures. In particular, the list shall contain information on:

  • Names and contact details of DEUBLIN as well as the data protection officer,
  • Definition and documentation of the purpose of processing,
  • Description of the persons affected by the processing,
  • Description of the categories of processed personal data,
  • Description of categories of recipients of personal data,
  • Documentation of third countries, as far as these personal data are passed on,
  • Documentation of deletion periods, as well as
  • Description of the technical and organizational measures.

The list shall be updated at least once a year by DEUBLIN in collaboration with the DPO.

If necessary, the records have to be updated of scheduled changes, in particular

  • New business processes / procedures (e.g. employee assessment, competencies, recruiting, customer support, etc.)
  • Significant changes to procedures
  • Projects / requirements of DEUBLIN, for which a transfer of personal data of DEUBLIN is required
  • Planned customer projects involving processing of personal data.

New procedures should be described in accordance with the present outline and must be reported to the DPO. The data protection officer examines and releases the procedures.

10.

Data Protection Impact Assessment

 

Where automated processing, especially when using new technologies, entails a high risk for the rights and freedoms of the person concerned, they are subject to the examination before the start of processing (data protection impact assessment). A data protection impact assessment shall be carried out by DEUBLIN GmbH if:

  • systematic and comprehensive assessment of personal aspects of natural persons based on automated processing, including profiling, which in turn serves as the basis for decisions, which unfold or substantially affect legal action against natural persons, or
  • special categories of personal data or personal data on criminal convictions are extensively processed, or
  • a systematic, extensive monitoring of publicly accessible areas.

In the implementation of the data protection impact assessment, the Council of the DPO is to be sought.

11.

Data Protection Training

 

At the beginning of the employment relationship with DEUBLIN, each employee has to sign a commitment to data protection (LINK).

Data protection training for employees must take place at least every third year. These trainings are organized by the relevant HR departments. (With responsible management and data protection officer)

In addition, according to the requirements or in the case of comprehensive legal changes, separate training courses are organized for the departments IT, HR and XXX, initiated by the data protection officer. All training courses on data protection are compulsory. Compliance is provided by participants' lists, which are signed by the employees. These lists are stored and managed by the responsible HR department.

In addition, all employees of LINK have detailed information on data protection.

12.

Documentation und Control of Data Protection

 

As a data processing company, the companies of the DEUBLIN group must be able to prove their processing of personal data is in accordance with the data protection laws. The DPO must therefore be informed in time before the introduction of new procedures for the processing of data, in particular new IT systems or automated processing of personal data. In consultation with the data protection officer, technical and organizational measures for the protection of personal data are to be defined, implemented and documented. These measures must be based on the state of the art, the risks arising from the processing and the need to protect the data.

Compliance with the guidelines on data protection and applicable data protection laws is regularly checked by data protection audits and other controls. The implementation is the responsibility of the data protection officer. The management of the company must be informed of any significant results within the scope of the respective reporting requirements.

 

Information on data processing for Customers, Suppliers, Partners

 

Preamble

The processing of your personal data – e.g. name, home address or contact details as phone number or mail address – will always be executed in accordance with the European General Data Protection Regulation (GDPR) and in accordance with national data protection regulations.

With this data protection information we inform you about the type, scope and purpose of the collected and processed data and about your data protection rights.

1.

Affected persons

 

The present data protection information is valid for all natural persons that are customers, suppliers or business partners of DEUBLIN or employees of the customers, suppliers or business partners of DEUBLIN and informs you in which way DEUBLIN (hereinafter to be referred to as “we”, “us”) and their affiliated companies and subsidiaries will collect and process your personal data related to business relation.

2.

Categories of personal data

 

DEUBLIN collects, processes and uses the following categories of your data related to our relationship:

  • Name
  • Titel / position
  • Name of the employer (if applicable)
  • Business contact data (address, phone and fax number, mail address)
  • Content of the communication (e.g. mails)
  • Contract details
  • Services or products rendered or offered
  • Billing and payment information
  • Data concerning the business relation
  • Data concerning the use of websites

Information for the use of our websites

When you visit our website it is possible that we collect certain data relating to the user, which your web-browser automatically submits to us, whenever you call up a website on the internet or an application on your mobile device.

This data will automatically be recorded by our servers. Some of these include the IP-address, browser type and -language, date and time of your visit as well as the internet addresses (URL), that you have called up shortly before or after the visit of our websites.

Depending on the abode of the user and the concerned data in each case, this may involve technical or personal data.

In relation to this, please also make a note of the Data Protection Declaration on our internet presence.

Information for the use of our newsletters

The information provided to us with your consent to our newsletter according to Art. 6 par. 1 lit. a GDPR collected personal data will only be used for our communication with you and the sending of our newsletter.

3.

Purpose of the data processing

 

Where required, we only process your personal data to provide an effective implementation of our relationship. This includes

  • the processing of your requests and complaints
  • the implementation of precontractual measures
  • the implementation of the contractual relation
  • the invoice processing
  • the communication between you and DEUBLIN
  • the documentation of the business realtion
  • the sending of information on advertising and offers
  • the guarantee of the security of our IT-Systems
  • the correction of previously transmitted data due to changes of contact data or similar reasons

4.

Legal bases for data processing

 

We always process your personal data in accordance with the European General Data Protection Regulation (GDPR) and the relevant data protection regulations of the Federal Data Protection Act (BDSG).

Below you find a description of the legal basis, in accordance to which we process your personal data. Please note that these information are only examples and cannot present a complete or final list of possible legal bases for the data processing.

a.

Consent (Art. 6 Par. 1 lit.a GDPR)

 

We use certain personal data only with your expressed and free previous consent. You may withdraw this consent at any time in order to terminate a future processing.

b.

Performance of a contract with you (Art. 6 Par. 1 lit.b GDPR)

 

We process certain personal data related to your contract. This amongst others includes the administrative processing of your personal data in order to process, plan and organize goods and services according to your contract.

c.

Fulfillment of legal obligations (Art. 6 Par. 1 lit.c GDPR)

 

DEUBLIN is subject to a series of legal requirements e. g. to ensure the fulfillment of legal obligations within DEUBLIN (Compliance). Legal obligations as these may require the processing of certain sensitive personal data.

d.

Protection of legitimate interests of DEUBLIN or a third party (Art. 6 Par. 1 lit.f GDPR)

 

DEUBLIN uses certain personal data for the protection of legitimate interests of the company or third parties. This only applies in cases that your personal interests as the affected person do not take precedence over DEUBLIN’s interests.

5.

Recipients or categories of recipients of personal data

 

DEUBLIN principally ensures that only a limited amount of authorized persons has access to your personal data, who need to have access to this data for the above mentioned administrative purposes.

Your personal data will not be passed on, sold or otherwise transferred to any third party, unless required for the fulfilment of the contract or you have expressively agreed to it.

Within the processing of your queries and your use of our services we also engage external contractors. These service providers are bound by contract to comply with the data protection regulations and only process personal data according with our instructions.

Subject to these conditions recipients of personal data may be service providers, processors or other third parties for the following purposes:

  • Support and maintenance of IT applications
  • Data destruction
  • Payment processing
  • Customer administration
  • Marketing
  • Website-management
  • Purchasing/procurement

The processing of the data will in principle take place in Germany or other states of the European Union. If some of your personal data, which we collect and process, should be forwarded to recipients outside the European Economic Area, we have taken appropriate measures to ensure the requirements of the Data Protection Regulation, e. g. the conclusion of appropriate EU-model contracts, privacy shield certifications (US), accepted code of conduct rules or accepted accreditation mechanisms according to article 42 GDPR.

6.

Duration of data processing

 

Your personal data will be deleted routinely according to Art. 17 par. 1 lit. a GDPR, if they are no longer necessary for the fulfilment of the contract and are no longer subject to legal storage periods.

The deletion shall be replaced by the blocking of the personal data stored where legal or factual obstacles stand counter to deletion, e. g. existence of special commercial or tax laws, to keep evidence subject to statutes of limitation or outstanding claims.

7.

Automate decision making

 

For the purpose of establishing our business relationship we in principle do not use automate decision making according to Art. 25 GDPR. If we should use this procedure in exceptional cases, we will inform you about it in advance, as far as it is prescribed by law.

8.

Data security

 

DEUBLIN has taken technical and organizational measures that are appropriate to prevent your personal data from unprofessional or unauthorized use or access and to protect your personal data from accidental or unlawful loss, destruction, alteration or damage. Such measures shall ensure a level of security appropriate to the risks of processing and the nature of the personal data to be protected.

Our security measures are continuously improved in line with technological progress.

9.

Rights of the individuals affected

 

As an individual affected you have legal rights concerning your personal data, that DEUBLIN collects and processes.

According to the law you have the following rights:

  • the right of access to your personal data (right to information),
  • the right of rectification in case of errors or wrong data,
  • the right of completion of incomplete data considering the purpose of the processing (right of rectification)

and, as far as certain reasons apply and the legal requirements are fulfilled,

  • the right of deletion of your personal data (cancellation right),
  • the right of limitation of the processing of your personal data (right of restriction),
  • the right of reception and transmission of the personal data you have provided to us to a different person responsible (right of data portability) and
  • the right to contradict to the processing of your personal data (right of objection).

Furthermore you have the right to appeal to the responsible authority for data protection at any time.

10.

Validity of the information on data privacy

 

This information on data privacy is currently valid and dates from May 25, 2018.

 

Information on data processing for Applicants

 

Preamble

The processing of your personal data – e.g. name, home address or contact details as phone number or mail address – will always be executed in accordance with the European General Data Protection Regulation (GDPR) and in accordance with national data protection regulations.

With this data protection information we inform you about the type, scope and purpose of the collected and processed data and about your data protection rights.

1.

Affected persons

 

The present data protection information is valid for all natural persons that apply for a job at DEUBLIN and informs you in which way DEUBLIN (hereinafter to be referred to as “we”, “us”) and their affiliated companies and subsidiaries will collect and process your personal data related to your application.

2.

Categories of personal data

 

DEUBLIN collects, processes and uses the following categories of your data related to your application:

  • Identification data: Name, your nationality and date of birth;
  • Contact data: Home address, private phone number and mail address;
  • Application data: Your professional experience (including information of your performance provided by former employers), qualifications and professional career, previous schooling, language skills, professional knowledge and talents, certificates, memberships of professional associations, social commitment
  • Communication data (e-mail, correspondence)

3.

Purpose of the data processing

 

Where required, we only process your personal data to provide an effective implementation of your application. This includes

  • Application and recruitment activities
  • Administration of your application documents
  • Evaluation of qualifications
  • Conducting of professional job interviews
  • Making of a hiring decision
  • Planning of the hiring and training process
  • Communication with the applicant

4.

Legal bases for data processing

 

We always process your personal data in accordance with the European General Data Protection Regulation (GDPR) and the relevant data protection regulations of the Federal Data Protection Act (BDSG).

Below you find a description of the legal basis, in accordance to which we process your personal data. Please note that these information are only examples and cannot present a complete or final list of possible legal bases for the data processing.

a.

Consent (Art. 6 Par. 1 lit.a GDPR)

 

We use certain personal data only with your expressed and free previous consent. You may withdraw this consent at any time in order to terminate a future processing.

b.

Performance of a contract with you (Art. 6 Par. 1 lit.b GDPR)

 

We process certain personal data related to your employment contract. This amongst others includes the administrative processing of your personal data in order to process, plan and organize your activity and your working place.

c.

Fulfillment of legal obligations (Art. 6 Par. 1 lit.c GDPR)

 

DEUBLIN is subject to a series of legal requirements e. g. to ensure the fulfillment of legal obligations within DEUBLIN (Compliance). Legal obligations as these may require the processing of certain sensitive personal data.

d.

Protection of legitimate interests of DEUBLIN or a third party (Art. 6 Par. 1 lit.f GDPR)

 

DEUBLIN uses certain personal data for the protection of legitimate interests of the company or third parties. This only applies in cases that your personal interests as the affected person do not take precedence over DEUBLIN’s interests.

5.

Recipients or categories of recipients of personal data

 

DEUBLIN principally ensures that only a limited amount of authorized persons has access to your personal data, who need to have access to this data for the above mentioned administrative purposes.

Our mother company, the DEUBLIN Company located in Waukegan, Illinois, USA, as well as all our affiliated companies may receive your personal data which is necessary for the processing of your application, depending on the kind of job you apply for.

Within the processing of your queries and your use of our services we also engage external contractors. These service providers are bound by contract to comply with the data protection regulations and only process personal data according to our instructions.

Subject to these conditions recipients of personal data may be service providers, processors or other third parties for the following purposes:

  • Support and maintenance of IT applications
  • Data destruction
  • Personnel service providers

The processing of the data will in principle take place in Germany or other states of the European Union. If some of your personal data, which we collect and process, should be forwarded to recipients outside the European Economic Area, we have taken appropriate measures to ensure the requirements of the Data Protection Regulation, e. g. the conclusion of appropriate EU-model contracts, privacy shield certifications (US), accepted code of conduct rules or accepted accreditation mechanisms according to Art. 42 GDPR.

6.

6. Duration of data processing

 

We delete your applicant details 3 months after a negative hiring decision by DEUBLIN or after you have declined an offer by DEUBLIN. DEUBLIN may keep your applicant data for 2 years if you have agreed to it in order to be considered for a different position at DEUBLIN or another company of the DEUBLIN group.

If you accept an offer by DEUBLIN, we will keep your applicant details for the duration of your employment.

7.

Automate decision making

 

For the purpose of establishing employment we in principle do not use automate decision making according to Art. 25 GDPR. If we should use this procedure in exceptional cases, we will inform you about it in advance, as far as it is prescribed by law.

8.

Data security

 

DEUBLIN has taken technical and organizational measures that are appropriate to prevent your personal data from unprofessional or unauthorized use or access and to protect your personal data from accidental or unlawful loss, destruction, alteration or damage. Such measures shall ensure a level of security appropriate to the risks of processing and the nature of the personal data to be protected.

Our security measures are continuously improved in line with technological progress.

9.

Rights of the individuals affected

 

As an individual affected you have legal rights concerning your personal data, that DEUBLIN collects and processes.

According to the law you have the following rights:

  • the right of access to your personal data (right to information),
  • the right of rectification in case of errors or wrong data,
  • the right of completion of incomplete data considering the purpose of the processing (right of rectification)

and, as far as certain reasons apply and the legal requirements are fulfilled,

  • the right of deletion of your personal data (cancellation right),
  • the right of limitation of the processing of your personal data (right of restriction),
  • the right of reception and transmission of the personal data you have provided to us to a different person responsible (right of data portability) and
  • the right to contradict to the processing of your personal data (right of objection).

Furthermore you have the right to appeal to the responsible authority for data protection at any time.

10.

Validity of the information on data privacy

 

This information on data privacy is currently valid and dates from May 25, 2018.