Privacy Policy

Privacy Policy

1. Data protection at a glance

General notes

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for the data collection on this website?

Data on this website is processed by the website operator. You can find the operator’s contact details in the section "Information on the data controller" in this Privacy Policy document.

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This may be, for example, data that you enter in a contact form.

Other data is collected by our IT systems automatically or after your consent when you visit our website. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time with regard to this and other questions on the subject of data protection.

Analytics tools and third-party tools

When visiting this website, your surfing behavior may be statistically analyzed. This is done mainly with so-called analytics tools.

Detailed information about these analytics tools can be found in the following privacy policy.

2. Hosting and Content Delivery Networks (CDN)

External hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the hoster's servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contractual data, contact data, names, website accesses and other data generated via a website.

The hoster is used for the purpose of fulfilling contracts with our potential and existing customers (Art. 6 para. 1 point b GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Art. 6 para. 1 point f GDPR). Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 point a GDPR and § 25 para. 1 German Federal Act on the Regulation of Data Protection and Privacy in Telecommunications and Telemedia (TTDSG), insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Our hoster will only process your data to the extent necessary to fulfill its service obligations and will follow our instructions regarding this data.

We use the following hoster:

checkdomain GmbH
a dogado group company
Große Burgstraße 27/29
23552 Lübeck
Germany

Job processing

We have concluded a job processing agreement (AVV) with the above-mentioned hoster. This is a contract required by data protection law which ensures that the hoster processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General notes and mandatory information

Data protection

The operators of these web pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how this is done and for what purpose.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security holes. Complete protection of the data against access by third parties is not possible.

Information on the data controller

Controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:

Kummer Consulting GmbH
Königsberger Str. 17
71696 Möglingen
Germany

Phone: +49 (0) 7141 66 14 55
E-mail: datenschutz(at)kummer-consulting.de

Managing directors: Friedrich Kummer, Adrian Kummer

Commercial register: Local court Stuttgart HRB 746713
VAT ID: DE296682543
Tax number: 71 335 / 046 09

Storage period

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted after these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 point a GDPR or Art. 9 para. 2 point a GDPR, if special categories of data are processed pursuant to Art. 9 para. 1 GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is also based on Section 25 para. 1 TTDSG. The consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 point b GDPR. Furthermore, we process your data if this is necessary for the fulfillment of a legal obligation on the basis of Art. 6 para. 1 point c GDPR. In addition, the data processing may be based on our legitimate interest according to Art. 6 para. 1 point f GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Data protection officer

We have appointed a data protection officer for our company.

Stephan Frank
SFC | Stephan Frank Consulting
Datenschutz und Informationssicherheit
Kopernikusplatz 11
D-90459 Nürnberg
Germany

Phone: +49 (911) 14885292
E-mail: dsb(at)stephan-frank.com

Note on data transfer to the USA and other third countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in these countries. For example, U.S. companies are obligated to release personal data to security authorities without you, the data subject, being able to take legal action against this. It can therefore not be ruled out that U.S. authorities (e.g. intelligence agencies) process, evaluate and permanently store your data located on U.S. servers for surveillance purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 PARA. 1 POINT E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21 PARA: 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right of appeal to the competent supervisory authority

In the event of breaches of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right of appeal is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the browser address bar changes from "http://" to "https://" and by the lock symbol in your browser bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, deletion and correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about stored personal data about you, the origin of the data, its recipients and the purpose of the data processing and, if applicable, the right to correction or deletion of this data. You can contact us at any time with regard to this and other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restrict processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.

  • If the processing of your personal data happened/is happening unlawfully, you may request the restriction of data processing instead of the deletion.

  • If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.

  • If you have lodged an objection pursuant to Art. 21 para. 1 GDPR, a balancing of your and our interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

Objection to advertising e-mails

The use of contact data published within the scope of the imprint obligation for the transmission of not expressly requested advertising and information materials is hereby contradicted. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

4. Data collection on this website

Server log files

The provider of the pages automatically collects and stores information in so-called server log files which your browser automatically transmits to us. These are:

  • Browser type and version

  • Operating system used

  • Referrer URL

  • Host name of the accessing computer

  • Time of the server request

  • IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6 para. 1 point f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - for this purpose, the server log files must be recorded.

Contact form

If you send us inquiries via the contact form, the information you provide in the inquiry form, including the contact data you enter there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 point b GDPR, provided that your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 point f GDPR) or on your consent (Art. 6 para. 1 point a GDPR) if this has been requested.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your inquiry). Mandatory legal provisions - in particular retention periods - remain unaffected.

Inquiry by e-mail, phone or fax

If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your inquiry. We do not share this data without your consent.

The processing of this data is based on Art. 6 para. 1 point b GDPR, provided that your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 point f GDPR) or on your consent (Art. 6 para. 1 point a GDPR) if this has been requested.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Communication via WhatsApp

For communication with our customers and other third parties, we use, among other things, the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Communication takes place via end-to-end encryption (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the communication content. WhatsApp does, however, gain access to metadata that is created in the course of the communication process (e.g., sender, recipient, and time). We would also like to point out that WhatsApp, according to its own statement, shares personal data of its users with its parent company Facebook, which is based in the USA. For more details on data processing, please see WhatsApp's privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.

WhatsApp is used on the basis of our legitimate interest in communicating as quickly and effectively as possible with customers, interested parties and other business and contractual partners (Art. 6 para. 1 point f GDPR). If a corresponding consent has been requested, the data processing is carried out exclusively on the basis of the consent; this can be revoked at any time with effect for the future.

The communication content exchanged between and on WhatsApp remains with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g., after we have completed processing your inquiry). Mandatory legal provisions - in particular retention periods - remain unaffected.

We use WhatsApp in the "WhatsApp Business" variant.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.whatsapp.com/legal/business-data-transfer-addendum.

We have set our WhatsApp account so that it does not automatically match data with the address book on the smartphones in use.

We have concluded a job processing agreement (AVV) with the above-mentioned hoster.

Microsoft Bookings

As a result of communication with our employees, you have the opportunity to make appointments with us. For appointment bookings we use the tool "Microsoft Bookings". Provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, see the Microsoft Teams privacy policy: https://privacy.microsoft.com/de-de/privacystatement.

For the purpose of booking an appointment, enter the requested data and the desired date in the mask provided. The data entered will be used for the planning, execution and, if necessary, follow-up of the appointment.

The data you enter will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies. Mandatory legal provisions - in particular retention periods - remain unaffected.

The legal basis for the data processing is Art. 6 para. 1 point f GDPR. The website operator has a legitimate interest in making it as uncomplicated as possible to arrange appointments with interested parties and customers. Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 point a GDPR and § 25 para. 1 German Federal Act on the Regulation of Data Protection and Privacy in Telecommunications and Telemedia (TTDSG), insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Job processing

We have concluded a job processing agreement (AVV) with the above-mentioned hoster. This is a contract required by data protection law which ensures that the hoster processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

5. Postal advertising

Postal advertising

We use your address in compliance with all legal requirements for sending advertising material by mail (postal advertising).

The legal basis for this is our legitimate interest in direct marketing according to Art. 6 para. 1 point f in conjunction with recital 47 GDPR. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 point a GDPR; the consent can be revoked at any time. More specific regulations may be communicated to you as part of the data collection process, if applicable, and will take precedence over these regulations.

Your address will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to postal advertising, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted after these reasons no longer apply.

6. Audio and video conferencing

Data processing

Among other things, we use online conference tools to communicate with our customers. The tools we use in particular are listed below. When you communicate with us via video or audio conferencing over the Internet, your personal data is collected and processed by us and the provider of the respective conferencing tool.

In doing so, the conference tools collect any data that you provide/enter to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other "context information" related to the communication process (metadata).

In addition, the provider of the tool processes all technical data required for the handling of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and connection type.

If content is exchanged, uploaded or otherwise made available within the tool, this content is also stored on the servers of the tool providers. Such content specifically includes cloud recordings, chat/instant messages, voicemails uploaded photos and videos, files, whiteboards, and other information shared while using the Service.

Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider. For further information on data processing by the conference tools, please refer to the privacy statements of the respective tools used, which we have listed below this text.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 point b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 point f GDPR). Insofar as consent has been requested, the tools in question are used on the basis of this consent; consent can be revoked at any time with effect for the future.

Storage period

The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies. Stored cookies remain on your terminal device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conference tools:

Microsoft Teams

We use Microsoft Teams. Provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, see the Microsoft Teams privacy policy: https://privacy.microsoft.com/de-de/privacystatement.

Job processing

We have concluded a job processing agreement (AVV) with the above-mentioned hoster. This is a contract required by data protection law which ensures that the hoster processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

7. Own services

Handling of applicant data

You have the possibility to send your application documents to our employees via our website, via our online application form and via e-mail. This application will of course be treated by us with the utmost confidentiality.

We store your documents in our database so that our consultants can consider your profile for vacancies with our clients. Our goal is to provide you with the best possible offer of current vacancies and at the same time to be able to provide our service to our clients. We store your personal data only as long as it is necessary for these purposes, but we delete your data no later than two years after the last personal, telephone or written contact with you in which you consented to the further storage of your data.

Scope and purpose of data collection

If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 German Data Protection Act (BDSG) (initiation of an employment relationship), Art. 6 para. 1 point b GDPR (general contract initiation) and - if you have given your consent - Art. 6 para. 1 point a GDPR. The consent can be revoked at any time. Only our employees have access to your personal data. We will only forward your application to our clients if you have expressly consented to the forwarding to the client.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of Section 26 German Data Protection Act (BDSG) and Art. 6 para. 1 point b GDPR for the purpose of implementing the employment relationship.

Data retention period

If you no longer wish to be considered by us for vacancies with our clients, we reserve the right to retain the data you have provided on the basis of our legitimate interests (Art. 6 para. 1 point f GDPR) for up to 6 months from the termination of the application process (rejection or withdrawal of the application). Subsequently, the data is deleted and the physical application documents are destroyed. The storage serves in particular evidence purposes in the event of a legal dispute. If it is apparent that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), the data will not be deleted until the purpose for continued storage no longer applies.

A longer storage can also take place if you have given a corresponding consent (Art. 6 para. 1 point a GDPR) or if legal storage obligations oppose the deletion.

HR4YOU

We use HR4YOU as an applicant management system and have also integrated HR4YOU on this website. The provider is HR4YOU AG, Ulbarger Straße 52, 26629 Großefehn / Timmel, Germany (hereinafter "HR4YOU").

HR4YOU allows us to let you upload your application documents directly through our website. When you upload content, it is stored on HR4YOU's servers.

The use of HR4YOU is based on Art. 6 para. 1 point f GDPR. The website operator has a legitimate interest in a reliable upload area for the submission of application documents on its website. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 point a GDPR; the consent can be revoked at any time.

Job processing

We have concluded a job processing agreement (AVV) with the above-mentioned hoster. This is a contract required by data protection law which ensures that the hoster processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.