In the following, we provide information about the collection of personal data when using
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Group Caliber ApS, Magstræde 10a, 1204 København, Denmark, email: [email protected]. We are legally represented by Shahar Silbershatz, Vladimir Verchinine.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: [email protected].
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.
In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party.
According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data.
These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion.
If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes.
This applies, for example, to data that must be retained for commercial or tax law reasons.
Data subjects have the following rights against us with regard to their personal data:
Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect.
Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.
As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship.
Should we use these procedures in individual cases, we will inform of this separately if this is required by law.
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions.
The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case.
It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR.
We delete the data when the results of the surveys have been evaluated.
We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means about our offers, if they have not objected to this.
The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR).
Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.
Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter.
Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR.
Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.
Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.
We send newsletters with the tool Mailchimp of the provider Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (privacy policy: https://mailchimp.com/legal/privacy/). The provider processes content, usage, meta/communication data and contact data in the process in the USA.
We send newsletters with the tool HubSpot of the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/privacy-policy).
The provider processes content, usage, meta/communication data and contact data in the process in the EU.
Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.
This storage and access is based on the following provisions:
The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.
During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
These data are:
This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.
Our website is hosted by DigitalOcean. The provider is Digitalocean LLC, 101 Avenue of the Americas 10th Floor, New York, NY 10013, USA.
In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA.
Further information can be found in the provider’s privacy policy at https://www.digitalocean.com/legal/privacy-policy.
It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
The legal basis of the transfer to a country outside the EEA are adequacy decision.
The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
When contacting us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR.
We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.
We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.
The processing of the data provided as part of the application is carried out for the purpose of implementing the application process.
Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para.
GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them.
If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).
We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application.
If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter.
Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).
Finally, we process the applicants’ data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.
We pass on the applicants’ data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.
If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended.
Otherwise, we delete the data no later than six months after rejecting an applicant.
If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.
Users can log in to our website using one or more single sign-on methods. In doing so, they use the login data already created for a provider.
The prerequisite is that the user is already registered with the respective provider. When a user logs in using a single sign-on procedure, we receive information from the provider that the user is logged in to the provider and the provider receives information that the user is using the single sign-on procedure on our website.
Depending on the user’s settings in his account on the provider’s site, additional information may be provided to us by the provider. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f GDPR.
We have a legitimate interest in providing users with a simple log-in option. At the same time, the interests of the users are safeguarded, as use is only voluntary.
Providers of the offered method(s) are:
We use Cookiebot to manage consents. The provider is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. c DSGVO. The processing is necessary for the fulfillment of a legal obligation to which we are subject.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.cookiebot.com/en/privacy-policy/.
We use Appcues to onboard customers to our product. The provider is Appcues, Inc., 177 Huntington Ave Ste 1703, PMB 94414, Boston, MA 02115 USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in making the onboarding for our product easier.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.appcues.com/privacy.
We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.
The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance.
At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.
As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy.
We use Piwik Pro for conversion analytics. The provider is Piwik PRO SA, ul. Św. Antoniego 2/4, 50-073 Wrocław, Poland. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://piwikpro.de/datenschutz/.
We use Dealfront for conversion analytics. The provider is Dealfront Group GmbH, Durlacher Allee 73, D-76131 Karlsruhe, Germany. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.dealfront.com/privacy-notice/.
We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users’ data for advertising purposes.
Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users.
To this end, the operators of the networks store information on user behavior in cookies on the users’ computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below.
It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.
If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook.
However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.
We maintain a profile on X. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.
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