Data protection policy - Trivadis Training

Data protection policy.

Thank you for your interest in our company. Data protection is particularly important for the management of Trivadis AG. The websites of Trivadis AG can generally be used without disclosing any personal data. However, if someone wishes to use certain specific services that our company offers via its website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, always takes place in accordance with the General Data Protection Regulation and the specific national data protection legislation applicable to Trivadis AG. By means of this data protection policy our company would like to notify the general public about the type, scope and purpose of the personal data that we collect, use and process. Furthermore, this data protection policy notifies data subjects of their rights.

As the controller, Trivadis AG has implemented numerous technical and organisation measures to ensure that the personal data processed via this website are protected as comprehensively as possible. Despite this, the transfer of data via the internet has security vulnerabilities, so that absolute protection cannot be guaranteed. For this reason, all data subjects are at liberty to communicate personal data to us using alternative methods, e.g. by telephone.

1. Definitions

The Trivadis AG data protection policy is based on the definitions used by the European legislative bodies for the General Data Protection Regulation. Our data protection policy is intended to be easy to read and understand for the general public and for our customers and business partners. To ensure that this is the case, we would first like to clarify the terms used.

In this data protection policy we use 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 means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, 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 means 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation
Pseudonymisation means 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

g) Controller
Controller means 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 means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

i) Recipient
Recipient means 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.

j) Third party
Third party means 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 authorised to process personal data.

k) Consent
Consent of the data subject means 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 contact details of the controller

The controller within the meaning of the General Data Protection Regulation, the Swiss Data Protection Act, other data protection legislation in the Member States of the European Union and other data protection provisions is:
Trivadis AG
Sägereistrasse 29
8152 Glattbrugg
Switzerland
Tel.: +41 58 459 55 55
Email: [email protected]
Website: www.trivadis.com and www.trivadis-karriere.com

3. Name and address of the data protection officer

The controller’s data protection officer is:
Christian Golz
Trivadis AG
Sägereistrasse 29
8152 Glattbrugg
Switzerland
Tel.: +41 58 459 55 55
Email: [email protected]

Any data subject can contact our data protection officer directly with questions or suggestions at any time.

4. Cookies

The websites of Trivadis AG use cookies. Cookies are text files that are set and stored on a computer system by an internet browser.

Many websites and servers use cookies. Many cookies contain what is known as a cookie-ID; a unique identifier for the particular cookie. It consists of a sequence of characters by which websites and servers can be assigned to the specific internet browser in which the cookie is stored. This enables the websites and servers visited to distinguish between the individual browser of the data subject and other internet browsers which have other cookies. The unique cookie-ID enables a particular internet browser to be recognised and identified.

By using cookies, Trivadis AG is able to provide the users of this website with more convenient services, which would not be possible without setting the cookies.

Cookies enable us to optimise the information and services on our website in the interests of users. As mentioned above, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for them to use our website. The user of a website that sets cookies does not have to enter their data every time they visit the website to register for a download, for instance, because this is done by the website and the cookie stored on the user’s computer system. Another example is the cookie for a shopping basket in an online shop. The online shop uses the cookie to remember the articles that the customer has placed in the virtual shopping basket.

The data subject can prevent our website from storing cookies at any time by setting their internet browser accordingly and so permanently withhold their consent to the use of cookies. Cookies that have already been set can also be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates cookies in the internet browser it may mean that not all the functions of our website can be used in full.

5. Collection of general data and information

Every time a data subject or an automated system accesses the Trivadis AG website, the website collects a range of general data and information. These general data and information are stored in the server logfiles. The data collected may include (1) browser type and version, (2) operating system used by the accessing system, (3) the website from which the accessing system is transferred to our site (referrer), (4) the pages of our website that the accessing system visits, (5) the date and time the website is accessed, (6) the internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) any similar data and information that may be used in the event of attacks on our IT systems.

Trivadis AG does not identify the data subject when using these general data and information. The data are used to (1) supply the contents of our website correctly, (2) optimise the contents of our website, (3) ensure the permanent functionality of our IT systems and our website technology, and (4) provide law enforcement agencies with the necessary information in the event of a cyber attack. These anonymised data are used by Trivadis AG for statistical purposes and to improve data protection and data security in our company, ultimately in order to ensure an optimal level of protection for the personal data that we process. The anonymous data in the server logfiles are stored separately from all the personal data provided by a data subject.

6. Use of the marketing tool HubSpot

Trivadis AG uses HubSpot on its website for online marketing activities. This is an integrated software solution with which the controller carries out various online marketing tasks. They include:

Content management for the website and the Trivadis blog
Email marketing, newsletters and automated mailings, to provide downloads, for example, see also 6 b), c), e), g) and h)
Publishing and reporting on social media such as Xing, Twitter, LinkedIn, Youtube
Contact management to user segments and tracking of their interests, see also 6 h)
Landing pages and contact forms, see also 6 d)

This information and some of our website content are stored on servers of our software partner HubSpot. We can use them to make contact with visitors to our website and to determine which of our services could interest them.

We use all the information gathered exclusively to optimise our marketing.
HubSpot is a software company from the USA with a branch office in Ireland.

Contact:
HubSpot
2nd Floor 30 North Wall Quay
Dublin 1, Ireland,
Telephone: +353 1 5187500

HubSpot is certified under the terms of the “EU – U.S. Privacy Shield Framework” and complies with the TRUSTe ‘s Privacy Seal and the “Swiss-U.S. Privacy Shield Framework”.

More information about HubSpot’s data protection policies can be found at: https://legal.hubspot.com/privacy-policy
More information from HubSpot concerning the EU data protection provisions can be found at: https://legal.hubspot.com/data-privacy
More information about the cookies used by HubSpot can be found at: https://knowledge.hubspot.com/articles/kcs_article/reports/what-cookies-… & https://knowledge.hubspot.com/articles/kcs_article/account/hubspot-cooki…

a) Registration on our website for an event
Data subjects are able to register with the controller’s website by providing personal data. Which personal data are transferred to the controller and its processor HubSpot can be seen from the input fields used for the registration. The personal data entered by the data subject are used and stored solely for its own internal purposes by the controller and its subsidiaries (Trivadis Germany GmbH, Industriestrasse 4, 70565 Stuttgart, Germany; Trivadis Delphi GmbH, Handelskai 94-96, 1200 Vienna, Austria; Trivadis A/S, Lautruphøj 1-3, 2750 Ballerup, Denmark; OIO – Orientation in Objects GmbH, Weinheimer Strasse 68, 68309 Mannheim, Germany). The controller may transfer the data to one or more processors, such as a parcel delivery service, which also only uses the personal data for its own internal purposes, which are attributable to the controller.

By registering on the controller’s website the IP address assigned by the data subject’s internet service provider (ISP), the date and the time of registration are also stored. These data are stored because this is the only way to prevent the misuse of our services and the data may be needed to investigate any criminal offences committed. To this extent the storage of the data are necessary for the controller’s own protection. The data are not transferred to third parties unless there is a statutory obligation to do so or they are transferred for law enforcement purposes.

The registration of data subjects, who voluntarily provide personal data, enable the controller to offer the data subjects contents or services that by the nature of things can only be offered to registered users. Registered users have the opportunity to alter the personal data provided in the course of registration at any time or to have it completely erased from the controller’s database.

The controller will tell the data subject at any time which personal data it has stored concerning the data subject. In addition, the controller will erase personal data concerning the data subject at the data subject’s request, unless there is a statutory obligation to retain the data. Data subjects can approach any of the controller’s employees with a request for information in this context.

b) Subscription to our newsletter
Data subjects have the opportunity to subscribe to our company newsletter on the Trivadis AG website. The personal data transferred to the controller and its subsidiaries (Trivadis Germany GmbH, Industriestrasse 4, 70565 Stuttgart, Germany; Trivadis Delphi GmbH, Handelskai 94-96, 1200 Vienna, Austria; Trivadis A/S, Lautruphøj 1-3, 2750 Ballerup, Denmark; OIO – Orientation in Objects GmbH, Weinheimer Strasse 68, 68309 Mannheim, Germany) and the processor HubSpot when the newsletter is ordered can be seen from the input fields used for the registration.

Trivadis AG informs its customers and business partners at regular intervals by way of a newsletter about offers from the company. Our company newsletter can only be received when (1) the data subject has a valid email address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation email for a double opt-in is sent to the email address first provided by the data subject for receiving the newsletter. This confirmation email is used to check that the data subject is the owner of the email address and authorises the distribution of the newsletter.

When the data subject subscribes for the newsletter we also store the IP address assigned by their ISP, the computer system used by them at the time of registration, and the date and time of registration. Collection of these data is required in order to reconstruct any misuse of a data subject’s email address at a later date and so to ensure the legal protection of the controller.

c) Newsletter tracking
Newsletters from Trivadis AG contain what are known as tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails sent in HTML format, to enable them to be recorded and analysed in logfiles. This enables the success or failure of online marketing campaigns to be determined by means of statistical analysis. By using the embedded tracking pixel, Trivadis AG can see whether and when an email was opened by a data subject and which links in the email the data subject clicked on.

Such personal data that are collected by the tracking pixels embedded in the newsletters are stored and analysed by the controller in order to optimise the mailing of its newsletters and to adapt the content of future newsletters even better to the interests of the data subject. These personal data are collected in our marketing tool Hubspot. Data subjects are entitled to withdraw their consent obtained separately via the double opt-in at any time. After consent has been withdrawn, the controller erases the personal data. Trivadis AG automatically treats the cancellation of the newsletter as the withdrawal of consent.

d) Contact form on the website
In line with statutory provisions, the Trivadis AG website includes information enabling rapid electronic contact to be made to our company and direct communication with us, which also includes an electronic mail or email address. When a data subject makes contact with the controller by email or by using the contact form, the personal data provided by the data subject are stored automatically. The personal data provided voluntarily to the controller by a data subject are stored for the purpose of processing or for making contact with the data subject.

e) Registration to download information material
Once they have registered, data subjects are able to download information material from the controller’s website by providing personal data on specific subjects. Which personal data are transferred to the controller and its processor HubSpot can be seen from the input fields used for the registration. The personal data entered by the data subject are used and stored solely for its own internal purposes by the controller and its subsidiaries (Trivadis Germany GmbH, Industriestrasse 4, 70565 Stuttgart, Germany; Trivadis Delphi GmbH, Handelskai 94-96, 1200 Vienna, Austria; Trivadis A/S, Lautruphøj 1-3, 2750 Ballerup, Denmark; OIO – Orientation in Objects GmbH, Weinheimer Strasse 68, 68309 Mannheim, Germany). The controller may transfer the data to one or more processors, such as a parcel delivery service, which also only uses the personal data for its own internal purposes, which are attributable to the controller.

f) Comment function in the website blog
Trivadis AG gives users the opportunity of posting individual comments on entries made in a blog located on the controller’s website. A blog (short for weblog) is an online forum where one or more persons, known as bloggers or web-loggers, can post articles or present their thoughts. Comments on the blog posts can generally be made by third parties.

When a data subject leaves a comment in the blog published on this website, the date and time of the comment, and the name, surname and email address of the data subject are also stored and published, as well as the comment itself. The IP address of the data subject assigned by the ISP is also logged. The IP address is recorded for security reasons and in case the data subject’s comments infringe on third-party rights or constitute unlawful posts. The storage of these personal data by the processor Hubspot is therefore in the interests of the controller, so that it can exonerate itself in the event of any legal infringements.

g) Subscribing for comments in the website blog
Third parties can generally subscribe for comments posted on the Trivadis AG blog. In particular there is an option for commentators to subscribe for subsequent comments in the thread relating to a certain article in the blog.

If a data subject decides to subscribe for subsequent comments, the controller sends an automatic confirmation email to ensure that the owner of the email address has really chosen this option. The subscription to comments can be cancelled at any time. The personal data collected are stored in our marketing tool and used for analytical purposes.

h) Profiling
Trivadis AG uses the data collected under 6 a) – g) and 7 to create a business profile. This primarily entails recording and analysing a person’s interests in technological subjects. The controller uses this information to continuously improve its contents and offers and to provide the data subject with personalised contents.

7. Registration on our website for a webinar

Data subjects are able to register with the controller’s website for webcasts (TriCasts) by providing personal data. Which personal data are transferred to the controller can be seen from the input fields used for the registration. The personal data entered by the data subject are used and stored solely for its own internal purposes by the controller and its subsidiaries (Trivadis Germany GmbH, Industriestrasse 4, 70565 Stuttgart, Germany; Trivadis Delphi GmbH, Handelskai 94-96, 1200 Vienna, Austria; Trivadis A/S, Lautruphøj 1-3, 2750 Ballerup, Denmark; OIO – Orientation in Objects GmbH, Weinheimer Strasse 68, 68309 Mannheim, Germany). To provide TriCasts the controller uses the processor LogMeIn and its product GoToWebinar and sends it the name, surname and email address of participants. Registrations are also recorded by the processor Hubspot.

LogMeIn is a software company from the USA with a branch office in Ireland.

Contact:
LogMeIn Ireland Limited
Bloodstone Building Block C
70 Sir John Rogerson’s Quay
Dublin 2, Ireland,
Telephone: 0800 836785

LogMeIn is certified under the terms of the “EU – U.S. Privacy Shield Framework” and the “Swiss-U.S. Privacy Shield Framework”.

More information about LogMeIn’s data protection policies can be found at: https://www.logmeininc.com/legal/privacy
More information from LogMeIn concerning the EU data protection provisions can be found at: https://www.logmeininc.com/legal/privacy-shield

8. Contact via the chat function on the website

The website of Trivadis AG gives visitors the option of making direct contact with the controller via a website chat function, so that the data subject can receive advice and support on products and services as quickly as possible. To provide the service the controller uses the processor SnapEngage.

SnapEngage is a software company from the USA.

Contact:
SnapEngage, LLC
ATTN: Customer Service Department
1722 14th Street, Suite 220
Boulder, CO 80302
USA
Telephone: +1 855 667 6268

SnapEngage is certified under the terms of the “EU – U.S. Privacy Shield Framework” and the “Swiss-U.S. Privacy Shield Framework”.

More information about SnapEngage’s data protection policies can be found at: https://www.snapengage.com/privacy-policy/
More information from SnapEngage concerning the EU data protection provisions can be found at: https://www.snapengage.com/privacy-policy

By using the website chat function the IP address assigned by the data subject’s internet service provider (ISP), the date and the time are also stored. These data are stored because this is the only way to prevent the misuse of our services and the data may be needed to investigate any criminal offences committed. To this extent the storage of the data are necessary for the controller’s own protection. The data are not transferred to third parties unless there is a statutory obligation to do so or they are transferred for law enforcement purposes.

9. Webshop to order training material

Trivadis AG gives data subjects the opportunity to order training material on the controller’s website by providing personal data. Which personal data are transferred to the controller can be seen from the input fields. The personal data entered by the data subject are used and stored solely for its own internal purposes by the controller and its subsidiaries (Trivadis Germany GmbH, Industriestrasse 4, 70565 Stuttgart, Germany; Trivadis Delphi GmbH, Handelskai 94-96, 1200 Vienna, Austria; Trivadis A/S, Lautruphøj 1-3, 2750 Ballerup, Denmark; OIO – Orientation in Objects GmbH, Weinheimer Strasse 68, 68309 Mannheim, Germany).

The data essential for delivery or performance of the contract are transferred to third-party providers. When the storage of your data is no longer necessary or required by law, they are erased.

10. Routine erasure and blocking of personal data

The controller only processes and stores the data subject’s personal data for as long as necessary to achieve the purpose of storage or insofar as it is required by European legislation or other legislation in the form of statutes or regulations to which the controller is subject.

If the purpose of storage no longer applies or storage period stipulated by European legislation or other applicable legislation expires, the personal data are routinely blocked or erased in accordance with statutory provisions.

11. Rights of data subjects

a) Right to confirmation
Every data subject has the right granted by European legislation to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right, they can ask an employee of the controller for confirmation at any time.

b) Right of access
Every data subject has the right granted by European legislation to obtain from the controller access to the personal data stored on them free of charge at any time and a copy of the personal data. Furthermore, European legislation has given data subjects the right to the following information:

the purpose of processing
the categories of personal data that are processed;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, especially recipients in third countries or international organisations
the planned retention period for the personal data, or if no concrete information is possible, the criteria for defining the retention period
the existence of a right to rectify or erase personal data relating to you, a right to restrict processing by the controller and a right to object to this processing
the existence of a right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject: all available information about the source of the data
the existence of automatic decision-making, including profiling referred to in Art. 22(1) and (4) GDPR and – at least in those cases – meaningful information about the logic involved, as well as the significance and the 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 organisation. 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 exercise this access right, they can ask an employee of the controller for confirmation at any time.

c) Right to rectification
Every data subject has the right granted by European legislation to obtain the rectification without undue delay of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject also has 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, they can approach an employee of the controller at any time.

d) Right to erasure (right to be forgotten)
Every data subject has the right granted by European legislation to obtain from the controller the erasure of personal data concerning them without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies and the processing is not necessary:

The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
The data subject withdraws the consent on which the processing is based according to point (a) of Art. 6(1), or point (a) of Art. 9(2) GDPR, and there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data have to 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 Art. 8(1) GDPR.

If one of the aforementioned grounds applies and a data subject wishes to request the erasure of personal data stored by Trivadis AG, they can contact an employee of the controller at any time. The Trivadis AG employee will ensure that the erasure request is fulfilled without undue delay.

Where Trivadis AG has made personal data public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, Trivadis AG, 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. The employee of Trivadis AG will arrange the necessary measures in individual cases.

e) Right to restriction of processing
Every data subject has the right granted by European legislation to obtain restriction of processing from the controller when one of the following conditions applies:

The data subject contests the accuracy of the personal data, 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 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 defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate interests of the controller override those of the data subject.

If one of the aforementioned grounds applies and a data subject wishes to request the restriction of processing of personal data stored by Trivadis AG, they can contact an employee of the controller at any time. The employee of Trivadis AG will arrange the restriction of processing.

f) Right to data portability
Every data subject has the right granted by European legislation to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also 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) GDPR or point (a) of Article 9(2) GDPR, or on a contract pursuant to point (b) of Article 6(1) 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) 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 an employee of Trivadis AG.

g) Right to object
Every data subject has the right granted by European legislation to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) or (f) of Art. 6(1) GDPR, including profiling based on those provisions.

If the data subject objects, Trivadis AG will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or the processing is for the establishment, exercise or defence of legal claims.
Where Trivadis AG processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling, insofar as it takes place in connection with such direct advertising. If the data subject objects to Trivadis AG to the processing for direct marketing purposes, Trivadis AG 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 the processing of personal data concerning him or her by Trivadis AG for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise their right to object, the data subject may contact any employee of Trivadis AG or an employee of another Trivadis company. 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 European legislation 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 authorised 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, Trivadis AG 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 a data subject wishes to exercise their rights concerning automated decision-making, they can contact an employee of the controller at any time.

i) Right to withdraw consent to data processing
Every data subject has the right granted by European legislation to withdraw their consent to the processing of personal data at any time.

If a data subject wishes to exercise their right to withdraw consent, they can contact an employee of the controller at any time.

12. Data protection for job applications and application procedures

The controller collects and processes the personal data of job applicants for the purpose of conducting the application procedure. Processing may also take place electronically. This is particularly the case when a candidate sends application documents to the controller electronically, by email for example, or by using an online form on the website. If the controller enters into an employment contract with a candidate, the data sent are stored for the purpose of processing the employment relationship in accordance with statutory provisions. If the controller does not enter into an employment contract with the candidate, the application documents are erased six months after the decision to reject the candidate has been announced, unless this conflicts with any other legitimate interests or contractual obligations towards recruitment agencies acting for the controller. Another legitimate interest in this context could be for example an obligation to provide evidence in legal proceedings under the General Act on Equal Treatment (AGG). Other contractual obligations in this context could be for example a recourse claim by a recruitment agency, which is why an application is erased twelve months after the decision to reject a candidate has been made known.

To ensure an optimal and fast application procedure we collect all the information in the recruitment management system Umantis – Talent Manager from Haufe-Lexware GmbH.
Haufe-Lexware GmbH is a software company based in Germany.

Contact:
Haufe-Lexware GmbH & Co. KG
Munzinger Straße 9
79111 Freiburg
Telephone: 0800 50 50 445

a) Location-based services
Trivadis AG uses location-based services to alert visitors to the website to vacant positions in their local area and so to facilitate their search. Data subjects are asked to activate location-based services by a pop-up window in their web browser. Data subjects therefore have to actively approve the use of location-based services. To determine the data subject’s location, a tracking method is used which derives their region from their IP address.

13. Data protection provisions concerning the use of Instagram

The controller has integrated components of the Instagram service on this website. Instagram is a service that can be described as an audiovisual platform, which enables users to share photos and videos with one another and post them to other social networks.

Instagram is operated by Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA.

Every time the visitor accesses one of the pages of this website, which is operated by the controller and in which an Instagram component (Insta button) has been integrated, the Instagram component automatically causes the internet browser on the visitor’s IT system to download an image of the corresponding component from Instagram. In the course of this technical procedure, Instagram receives information about which specific pages of our website are visited by the data subject.

If the data subject is logged in to Instagram at the same time, Instagram recognises which specific pages are visited by the data subject every time they access our website, for the entire duration of their visit. This information is collected by the Instagram component and assigned to the data subject’s Instagram account by Instagram. If the data subject clicks on one of the Instagram buttons integrated in our website, the data and information are assigned to the data subject’s personal Instagram account and stored and processed by Instagram.

If the data subject is logged in to Instagram, their visit to our website is always notified to Instagram via the Instagram component, regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want such information to be transferred to Instagram, they can prevent it by logging out of their Instagram account before accessing our website.

Further information and Instagram’s applicable data protection policy can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

14. Data protection provisions concerning the use of Facebook

The controller has integrated components from Facebook on this website. Facebook is a social network.

A social network is a social meeting place on the internet, an online community that generally enables users to communicate with one another and to interact in a virtual space. A social network can act as a platform for the exchange of opinions and experience or to enable the internet community to provide personal or corporate information. Among other things, Facebook enables the users of its social network to create private profiles, upload photos and build a network by means of friend requests.

Facebook is operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. When the data subject lives outside the USA or Canada, the controller for the processing of personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Every time the visitor accesses one of the pages of this website, which is operated by the controller and in which an Facebook component (Facebook plug-in) has been integrated, the Facebook component automatically causes the internet browser on the visitor’s IT system to download an image of the corresponding component from Facebook. An overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE. In the course of this technical procedure, Facebook receives information about which specific pages of our website are visited by the data subject.
If the data subject is logged in to Facebook at the same time, Facebook recognises which specific pages of our website are visited by the data subject every time they access our website, for the entire duration of their visit. This information is collected by the Facebook component and assigned to the data subject’s Facebook account by Facebook. If the data subject clicks on one of the Facebook buttons embedded on our website, e.g. the “Like” button or posts a comment, Facebook assigns this information to the data subject’s personal Facebook account and stores this personal data.

If the data subject is logged in to Facebook, their visit to our website is always notified to Facebook via the Facebook component, regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want such information to be transferred to Facebook , they can prevent it by logging out of their Facebook account before accessing our website.

Facebook’s data policy, which can be retrieved from https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains the settings Facebook offers to protect the privacy of data subjects. In addition, a number of applications are available that make it possible to prevent the transfer of data to Facebook. Data subjects can use such applications to prevent their data being transferred to Facebook.

15. Data protection provisions concerning the use of Google Analytics (with anonymisation function)

The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics is the gathering, collection and interpretation of data about the behaviour of website visitors. Among other things, a web analytics service tracks data about the website from which a data subject has reached our website (known as a referrer), which pages of the website are accessed and how often and for how long a page is viewed. Web analytics is mainly used to optimise a website and to carry out a cost-benefit analysis of online advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

The controller uses the code “_gat._anonymizeIp” for web analytics via Google Analytics. When this code is used, Google abbreviates and anonymises the IP address of the data subject’s internet connection if our websites are accessed from a member state of the European Union or the European Economic Area.

The purpose of the Google Analytics component is to analyse visitor traffic to our website. Among other things, Google uses the data and information collected to analyse the use of our website, to compile online reports showing activities on our websites and to provide additional services in connection with the use of our website.

Google Analytics sets a cookie on the data subject’s IT system. What cookies are, has already been described above. By setting the cookie, Google is able to analyse the use of our website. Every time the visitor accesses one of the pages of this website, which is operated by the controller and in which an Google Analytics component has been integrated, the Google Analytics component automatically causes the internet browser on the visitor’s IT system to send data to Google for the purpose of analysis. In the course of this technical procedure, Google gains access to personal data, such as the IP address of the data subject, which Google uses among other things to track the origin of visitors and clicks and so to enable commissions to be billed.

The cookie enables the storage of personal information, such as the time of access, the place from which the site was accessed and the frequency of visits to our website by the data subject. Every time our websites are visited, these personal data, including the IP address of the internet connection used by the data subject, are transferred to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may transfer the personal data collected via this technical procedure to third parties.

As described above, the data subject can prevent our website from storing cookies at any time by setting their internet browser accordingly and so permanently withhold their consent to the use of cookies. Setting the internet browser accordingly would also prevent Google from storing a cookie on the data subject’s IT system. Furthermore, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Data subjects also have the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of these data by Google. To do so, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on uses JavaScript to tell Google Analytics that it may not transfer data and information on website visits to Google Analytics. Google treats the installation of the browser add-on as an objection. If the data subject’s IT system is erased, reformatted or reinstalled at a later date, the data subject must install the browser add-on again in order to deactivate Google Analytics. If the browser add-on is deinstalled or deactivated by the data subject or another person whose actions are attributable to them, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable data protection policy can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Further information about Google Analytics can be found under the link https://www.google.com/intl/de_de/analytics/.

16. Data protection provisions concerning the use of Google AdWords

The controller has integrated Google AdWords on this website. Google AdWords is an online advertising service that enables advertisers to place adverts in Google search results and in the Google advertising network. Google AdWords enables advertisers to define certain keywords that enable an advert only to be shown in the Google search results when the user enters a keyword in the search engine. In the Google advertising network the adverts are distributed to relevant websites by means of an automatic algorithm and the previously defined keywords.

The operator of Google AdWords is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to advertise our website by showing relevant adverts on third-party websites and in the search results of the Google search engine.

If a data subject reaches our website via a Google advert, what is known as a conversion cookie is stored on the data subject’s IT system by Google. What cookies are, has already been described above. A conversion cookie expires after 30 days and does not enable the data subject to be identified. Until it expires, the conversion cookie makes it possible to track whether visitors go to certain pages of our website, e.g. the shopping basket of our online shop system. The conversion cookie enables both us and Google to see whether a data subject who reaches our website via an AdWords advert generates a sale, i.e. completes a purchase or not.

The data and information gathered by the use of the conversion cookie are used by Google to compile visitor statistics for our website. These visitor statistics are used by us in turn to calculate the total number of visitors brought to us via AdWords adverts, i.e. to determine the success or failure of the individual AdWords advert and so to optimise our AdWords adverts for the future. Neither our company nor other advertising clients of Google AdWords receive any information from Google that would enable the data subject to be identified.

The conversion cookie enables personal information to be stored, such as the websites visited by the data subject. Every time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, are therefore transferred to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may transfer the personal data collected via this technical procedure to third parties.

As described above, the data subject can prevent our website from storing cookies at any time by setting their internet browser accordingly and so permanently withhold their consent to the use of cookies. Setting the internet browser accordingly would also prevent Google from storing a conversion cookie on the data subject’s IT system. Furthermore, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.

In addition, the data has the option of objecting to interest-based advertising from Google. To do so, the data subject must follow the link www.google.de/settings/ads from every web browser used and adjust the settings accordingly.

Further information and Google’s applicable data protection policy can be found at https://www.google.de/intl/de/policies/privacy/.

17. Data protection provisions concerning the use of Bing Ads

The controller has integrated Bing Ads on this website. Bing Ads is an online advertising service that enables advertisers to place adverts in Bing search results and in the Bing advertising network. Bing Ads enables advertisers to define certain keywords that enable an advert only to be shown in the Bing search results when the user enters a keyword in the search engine. In the Bing advertising network the adverts are distributed to relevant websites by means of an automatic algorithm and the previously defined keywords.

Bing Ads is operated by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA.

The purpose of Bing Ads is to advertise our website by showing relevant adverts on third-party websites and in the search results of the Bing search engine.

If a data subject reaches our website via a Bing advert, what is known as a conversion cookie is stored on the data subject’s IT system by Bing. What cookies are, has already been described above. A conversion cookie expires after 30 days and does not enable the data subject to be identified. Until it expires, the conversion cookie makes it possible to track whether visitors go to certain pages of our website, e.g. the shopping basket of our online shop system. The conversion cookie enables both us and Bing to see whether a data subject who reaches our website via an Ads advert generates a sale, i.e. completes a purchase or not.

The data and information gathered by the use of the conversion cookie are used by Bing to compile visitor statistics for our website. These visitor statistics are used by us in turn to calculate the total number of visitors brought to us via AdWords adverts, i.e. to determine the success or failure of the individual AdWords advert and so to optimise our AdWords adverts for the future. Neither our company nor other advertising clients of Bing Ads receive any information from Bing that would enable the data subject to be identified.

The conversion cookie enables personal information to be stored, such as the websites visited by the data subject. Every time our websites are visited, personal data, including the IP address of the internet connection used by the data subject, are therefore transferred to Bing in the United States of America. These personal data are stored by Bing in the United States of America. Bing may transfer the personal data collected via this technical procedure to third parties.

As described above, the data subject can prevent our website from storing cookies at any time by setting their internet browser accordingly and so permanently withhold their consent to the use of cookies. Setting the internet browser accordingly would also prevent Bing from storing a conversion cookie on the data subject’s IT system. Furthermore, a cookie already set by Bing Ads can be deleted at any time via the internet browser or other software programs.

In addition, the data has the option of objecting to interest-based advertising from Bing.

Further information and Bing’s applicable data protection policy can be found at https://privacy.microsoft.com/de-de/privacystatement.

18. Data protection provisions concerning the use of LinkedIn

The controller has integrated components from LinkedIn Corporation on this website. LinkedIn is an online social network that enables its users to connect with existing business contacts and to make new business contacts. LinkedIn has over 400 million registered users in more than 200 countries. This currently makes LinkedIn the biggest platform for business contacts and one of the most-visited websites in the world.

LinkedIn is operated by LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible for data protection matters outside the USA.

Every time our website with a LinkedIn component (LinkedIn plug-in) is accessed, this component causes the browser used by the data subject to download a corresponding image of the component from LinkedIn. Further information on the LinkedIn plug-ins can be found at https://developer.linkedin.com/plugins. In the course of this technical procedure, LinkedIn receives information about which specific pages of our website are visited by the data subject.

If the data subject is logged in to LinkedIn at the same time, LinkedIn recognises which specific pages of our website are visited by the data subject every time they access our website, for the entire duration of their visit. This information is collected by the LinkedIn component and assigned to the data subject’s LinkedIn account by LinkedIn. If the data subject clicks on a LinkedIn button embedded in our website, LinkedIn assigns this information to the data subject’s personal LinkedIn account and stores these personal data.

If the data subject is logged in to LinkedIn, their visit to our website is always notified to LinkedIn via the LinkedIn component, regardless of whether the data subject clicks on the LinkedIn component or not. If the data subject does not want such information to be transferred to LinkedIn, they can prevent it by logging out of their LinkedIn account before accessing our website.

LinkedIn provides options for cancelling emails, text messages and targeted adverts and for managing advertising settings at https://www.linkedin.com/psettings/guest-controls. LinkedIn also works with partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame, which can all set cookies. Such cookies can be rejected under https://www.linkedin.com/legal/cookie-policy. The applicable data protection policy of LinkedIn is available from https://www.linkedin.com/legal/privacy-policy. LinkedIn’s cookie policy is available from https://www.linkedin.com/legal/cookie-policy.

19. Data protection provisions concerning the use of SlideShare

The controller has integrated SlideShare components on this website. LinkedIn SlideShare is a filehosting service that enables presentations and other documents such as PDF files, videos and webinars to be exchanged and archived. The filehosting service allows users to upload media contents in all common formats, whereby the documents can either be made publicly available or marked as private.

SlideShare is operated by LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible for data protection matters outside the USA.

LinkedIn SlideShare provides embed codes for the media contents stored there (presentations, PDF files, videos, photos, etc.). Embed codes are program codes that are embedded in websites to enable external contents to be displayed there. Embed codes make it possible to show contents on a company’s own website without storing them on its own server and so possibly infringing the reproduction rights of the copyright holder. Another advantage of using embed codes is that the operator of a website does not use any of its own storage capacity and so relieves pressure on its own servers. An embed code can be embedded anywhere on another website, so external contents can also be inserted within a piece of proprietary text. The purpose of using LinkedIn SlideShare is to relieve pressure on our server and to avoid copyright infringements when using third-party content.

Every time our website with a SlideShare component (embed code) is accessed, this component causes the browser used by the data subject to download the embedded contents from SlideShare. In the course of this technical procedure, LinkedIn receives information about which specific pages of our website are visited by the data subject.

If the data subject is logged in to SlideShare at the same time, SlideShare recognises which specific pages are visited by the data subject every time they access our website, for the entire duration of their visit. This information is collected by SlideShare and assigned to the data subject’s SlideShare account by LinkedIn.

If the data subject is logged in to SlideShare, their visit to our website is always notified to LinkedIn via the SlideShare component, regardless of whether the data subject clicks on the embedded media files or not. If the data subject does not want such information to be transferred to LinkedIn, they can prevent it by logging out of their SlideShare account before accessing our website.

LinkedIn also works with partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame, which can all set cookies. Such cookies can be rejected under https://www.linkedin.com/legal/cookie-policy. The applicable data protection policy of LinkedIn is available from https://www.linkedin.com/legal/privacy-policy.

20. Data protection provisions concerning the use of Twitter

The controller has integrated components from Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service that enables users to publish and distribute short messages of up to 280 characters, which are known as ‘tweets’. These messages can be accessed by anyone, i.e. also people not logged in to Twitter. The tweets are also sent to the user’s ‘followers’. Followers are other Twitter users who have subscribed to receive a user’s tweets. Twitter also enables a broad public to be addressed by means of hashtags, links and retweets.

Twitter is operated by Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Every time the visitor accesses one of the pages of this website, which is operated by the controller and in which an Twitter component (Twitter button) has been integrated, the Twitter component automatically causes the internet browser on the visitor’s IT system to download an image of the corresponding Twitter component from Twitter. Further information about the Twitter button can be found at https://about.twitter.com/de/resources/buttons. In the course of this technical procedure, Twitter receives information about which specific pages of our website are visited by the data subject. The purpose of integrating the Twitter component is to enable our users to distribute the contents of this website, to make this website known in the digital world and to increase the number of our visitors.

If the data subject is logged in to Twitter at the same time, Twitter recognises which specific pages of our website are visited by the data subject every time they access our website, for the entire duration of their visit. This information is collected by the Twitter component and assigned to the data subject’s Twitter account by Twitter. If the data subject clicks on one of the Twitter buttons integrated in our website, the data and information are assigned to the data subject’s personal Twitter account and stored and processed by Twitter.

If the data subject is logged in to Twitter, their visit to our website is always notified to Twitter via the Twitter component, regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not want such information to be transferred to Twitter, they can prevent it by logging out of their Twitter account before accessing our website.
The applicable data protection policy of Twitter is available from https://twitter.com/privacy?lang=de.

21. Data protection provisions concerning the use of Xing

The controller has integrated components from Xing on this website. Xing is an online social network that enables its users to connect with existing business contacts and to make new business contacts. Individual users can create their own profile on Xing. Companies can create company profiles or publish job offers on Xing.

Xing is operated by XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.

Every time the visitor accesses one of the pages of this website, which is operated by the controller and in which an Xing component (Xing plug-in) has been integrated, the Xing component automatically causes the internet browser on the visitor’s IT system to download an image of the corresponding Xing component from Xing. Further information on the Xing plug-ins can be found at https://dev.xing.com/plugins. In the course of this technical procedure, Xing receives information about which specific pages of our website are visited by the data subject.

If the data subject is logged in to Xing at the same time, Xing recognises which specific pages of our website are visited by the data subject every time they access our website, for the entire duration of their visit. This information is collected by the Xing component and assigned to the data subject’s Xing account by Xing. If the data subject clicks on a Xing button embedded in our website, like the ‘Share’ button, Xing assigns this information to the data subject’s personal Xing account and stores these personal data.

If the data subject is logged in to Xing, their visit to our website is always notified to Xing via the Xing component, regardless of whether the data subject clicks on the Xing component or not. If the data subject does not want such information to be transferred to Xing, they can prevent it by logging out of their Xing account before accessing our website.

Xing’s privacy policy, which can be retrieved from https://www.xing.com/privacy/, provides information about the collection, processing and use of personal data by Xing. Xing has also published its data protection policy for the XING share button at https://www.xing.com/app/share?op=data_protection.

22. Data protection provisions concerning the use of YouTube

The controller has integrated components from YouTube on this website. YouTube is an online video portal that enables publishers to upload video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows all kinds of videos to be published, so complete films and television programmes, as well as music videos, trailers and user-generated videos can be accessed via the online portal.

The operator of the YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

Every time the visitor accesses one of the pages of this website, which is operated by the controller and in which a YouTube component (YouTube video) has been integrated, the YouTube component automatically causes the internet browser on the visitor’s IT system to download an image of the corresponding YouTube component from YouTube. Further information about YouTube is available from https://www.youtube.com/yt/about/de/. In the course of this technical procedure, YouTube and Google receive information about which specific pages of our website are visited by the data subject.

If the data subject is logged in to YouTube at the same time, YouTube recognises which specific pages of our website are visited by the data subject every time they access a page including a YouTube video. This information is collected by YouTube and Google and assigned to the data subject’s YouTube account.

If the data subject is logged in to YouTube, their visit to our website is always notified to YouTube and Google via the YouTube component, regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not want such information to be transferred to YouTube, they can prevent it by logging out of their YouTube account before accessing our website.

YouTube’s data protection policy, which can be retrieved from https://www.xing.com/privacy/, provides information about the collection, processing and use of personal data by YouTube and Google.

23. Legal basis for processing

When our company obtains consent to data processing for a particular purpose, our processing is based on Art. 6(1)a GDPR. When 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 supplies of goods or services or the payment of consideration, the processing takes place on the basis of Art. 6(1)b GDPR. The same applies to processing necessary for the performance of pre-contractual activities, such as requests for our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as a tax obligation, the processing is based on Art. 6(1)c GDPR. In rare cases it may become necessary to process personal data to protect the vital interests of the data subject or another natural person. This would be the case, for instance, if a visitor to our premises were to be injured and their name, age, health insurance details or other vital information had to be disclosed to a doctor, a hospital or other third parties. Processing would then be based on Art. 6(1)d GDPR. Finally, processing could be based on Art. 6(1)f GDPR. This is the legal basis for processing that is not covered by any of the preceding legal grounds, if the processing is necessary to pursue the legitimate interests of our company or a third party and these override the interests, rights and freedoms of the data subject. We are entitled to carry out such processing because European legislation specifically authorises us to do so. The legislative bodies were of the opinion that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).

24. Legitimate interests in processing pursued by the controller or a third party

25. To the extent that processing of personal data is based on Art. 6(1)f GDPR, the controller considers that the processing is in its legitimate interest. In this case we are acting for the benefit of our business, the welfare of all our employees and shareholders.Duration for which personal data are stored

26. The criterion for determining the duration of storage of personal data is the statutory retention period; if no retention period applies, the deletion intervals defined by the controller are used. After the deadline expires, the data concerned are routinely erased, unless they are required for the performance of the contract or pre-contractual activities or for another purpose. Statutory or contractual provisions on providing personal data; requirement for entering into a contract; obligation of the data subject to provide personal data; potential consequences of non-compliance

We hereby notify you that in some cases you are obliged by law to provide personal data (e.g. tax regulations) or that you may have a contractual duty to do so (e.g. information about a contracting party). In some cases it may be necessary for a data subject to provide us with personal data – which then have to processed by us –before a contract can come about. The data subject is obliged to provide us with personal data, for example, if our company enters into a contract with him or her. Not providing the personal data would mean that the contract with the data subject would not come about. Before providing personal data, the data subject can get in touch with one of our employees. Our employee will explain to the data subject whether the provision of personal data is required by statute or contract or for the contract to come about; whether an obligation exists to provide the personal data and what the consequences of non-compliance would be.

27. Existence of automated decision-making

As a responsible company we do not make use of automated decision-making.

Trivadis

We lessen complexity.