We Take Privacy Seriously
SECUDE International AG
Werftestraße 4 A
Managing Director: Dr. Heiner Kromer, Philipp Meier
Register Number: CH-170.3.029.848-0
Register Court: Lucerne
Link to the imprint: www.secude.de/impressum
Types of Processed Data
- Inventory data (e.g. names and addresses)
- Contact information (e.g. e-mail and phone numbers)
- Content data (e.g. text input, photographs, and videos)
- Usage data (e.g. websites visited, interest in content, and access time)
- Meta / communication data (e.g. device information and IP addresses)
Categories of Affected Persons
Visitors and users of the online service (hereafter the affected persons will referred to as “users”).
Purpose of Processing
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie is set that prevents the collection of your data on future visits to this website: disable Google Analytics.
- Provision of the online service, its functions and contents
- Answering contact requests and communicating with users
- Safety measures
- Reach Measurement / Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is regarded as identifiable and can be identified directly or indirectly, in particular by means of assignment to an identifier such as name, identification number, data, an online identifier (e.g. cookie) or through one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term has a wide reach and includes virtually handling of all data.
“Pseudonymisation” means the processing of personal data in such a way that personal data can be no longer attributed to a specific data subject without the need of additional information, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data that involves the use of personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Responsible person” means the natural or legal person, public authority, body or decision making body, alone or in conjunction with others, the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant Legal Basis
In accordance with Art. 13 of the GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following apply:
The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 of the GDPR
The legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b of GDPR.
The legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c of the GDPR
The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f of the GDPR.
In the event that vital interests of the data subject or another natural person requires the processing of personal data, Art. 6 para. 1 lit. d of the GDPR would be the legal basis.
We take appropriate technical measures in accordance with Art. 32 of the GDPR, taking into consideration the state of the technology, implementation costs and the scope, circumstances and purposes of processing as well as the different probabilities and severity of risks to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the utilization of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 of the GDPR).
Collaboration with Processors and Third Parties
If, in the context of processing, we disclose data to other persons and companies (contract processors or third parties), transmit the data to them or otherwise grant access to the data, this is done only on the basis of a legal permission (e.g, if data transmission to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (e.g. the use of agents, web hosters, etc.).
If we commission third parties to process data on the basis of “contract processing agreement”, this is done on the basis of Art. 28 of the GDPR.
Transfers to Countries Outside EU
If we process data in a country outside the European Union (EU) or the European Economic Area (EEA) or when using third-party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 under GDPR. That the processing is, for example, on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (“standard contractual clauses”).
Rights of Data Subjects
You have the right to ask the reason for the data in question being processed and any further information about this data as well as for a copy of the data in accordance with Art. 15 of the GDPR.
Also, you have the right to demand the complete data or the correction of incorrect data concerning you in accordance to Art. 16 of the GDPR.
In accordance with Art. 17 of the GDPR, you have the right to demand that data relevant to you be immediately deleted, or, alternatively, restrict the processing of data in accordance with Art. 18 of the GDPR.
You also have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 of the GDPR and request its transmission to other persons responsible.
You have the right, under Art. 77 of the GDPR, to file a complaint with the competent supervisory authority in case of discrepancies.
Withdrawal of Permission
At anytime in the future, you have the right to withdraw permission as in accordance with. Art. 7 Para. 3 of the GDPR.
Withdraw Permission to Process Data
In accordance with Art. 21 of the GDPR, at anytime in the future, you are entitled to withdraw permission granted to process your data. This is also applicable for direct marketing purposes.
Cookies and the Right to Object to Direct Mail
“Cookies” are small files that are stored on users’ computers. Different types of information can be stored within the cookies. A cookie serves primarily to store information about a user (or the device on which the cookie is stored) during or after his visit to a website. Temporary cookies (also known as “session cookies” or “transient cookies”), are cookies that are deleted after a user leaves an online service and closes their browser. In such a cookie (e.g. the contents of a shopping cart in an online shop) login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, for example, the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person responsible for providing the online offer (otherwise, if only their cookies are called “first-party cookies”).
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of Data
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, for taxation relevant Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place especially for 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-EU companies in EU Member States for which the Mini-One-Stop-Shop (MOSS) is used.
In addition we process:
- Contract data (e.g., subject, term, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, viz tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the financial administration, consultants such as tax accountants or auditors, and other fee agents and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store such company-related data permanently.
Business Analysis and Market Research
In order to operate our business economically, to recognize market trends, meet oblications of contractors and users, we analyze data available to us for business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business, marketing and market research. In doing so, we can provide the profiles of registered users with information, e.g. take into account their services. The analyses serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analyses are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyses.
If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyses and general trend provisions are created anonymously, if possible.
When contacting us (e.g through the contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing is in accordance with Art. 6 para. 1 lit. b of the GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or a comparable system.
We delete requests if they are no longer required. We check the requirement every two years. Please note that legal archiving obligations apply.
CRM System from Salesforce
We use the CRM system of the provider salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 München to process inquiries from users quickly and efficiently (legitimate interest in accordance with Article 6 (1) lit. of the GDPR).
Salesforce is certified under the Privacy Shield Agreement, which provides an additional guarantee to comply with European privacy legislation when processing data in the US (https://www.privacyshield.gov/participant?id=a2zt0000000KzLyAAK&status=Active).
Salesforce uses users’ data only for technical processing of inquiries and does not pass them on to third parties. To use salesforce, you must provide at least the correct e-mail address. A pseudonymous use is possible. During the processing of service requests it may be necessary to collect further data (such as name and address). The use of Zendesk is optional and serves to improve and speed up our customer and user service.
If users disagree with salesforce data collection and data storage in the external system of salesforce, we offer alternative contact options for submitting service requests by e-mail, telephone, fax or post.
Hosting and E-Mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services we use to operate this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f GDPR i.V.m. Art. 28 GDPR (conclusion of contract processing agreement).
Collection of Access Data and Log Files
We or our hosting provider collect, on the basis of our legitimate interests within Art. 6 para. 1 lit. f. of the GDPR, data on every access to the server on which this service is located (server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security purposes (for example to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online service by users, to compile reports on the activities within this online service and to provide us with further services related to the use of this online service and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of such data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of users will be deleted or anonymized after 14 months.
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set that prevents the collection of your data on future visits to this website: Disable Google Analytics.
Online Presence in Social Media
We maintain an online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
Integration of Services and Contents of Third Parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within Art. 6 (1) lit. DGDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceives the IP address of users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.
Functions of the Twitter service are integrated into our site. These features are available through Twitter Inc., registered at 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the ‘Re-Tweet’ function, the websites you visit are linked to your Twitter account and shared with other users. This data is also transmitted to Twitter.
Our website uses functions of XING, offered by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Every time you visit one of our sites that includes XING’s features, it will connect to XING servers.
Our website uses features of the LinkedIn network. The provider is registered at LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland.
Every time you visit one of our pages that contains LinkedIn a feature, it will connect with LinkedIn’s servers. LinkedIn will be informed that you have visited our website with your IP address. If you click LinkedIn’s ‘Recommend Button’when you are logged in to your LinkedIn account, LinkedIn will be able to associate your visit to our website with you and your user account.
LinkedIn privacy statement: https://www.linkedin.com/legal/privacy-policy.