Data protection
Data protection declaration according to the GDPR
This data protection declaration explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our website.
I. Name and address of the responsible party
The responsible party within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:
CBE DIGIDEN AG
Franklinstrasse 27
10587 Berlin
Board of directors: Sabine Clausecker, Eberhard Bingel, Mike Petersen
Commercial register: Charlottenburg District Court, HRB 111483 B
Tel.: +49 30 81884 0
E-mail: berlin@cbe-digiden.de
II. Name and address of the data protection officer
The data protection officer of the responsible party is:
Tom Noack
CBE DIGIDEN AG, Franklinstraße 27, 10587 Berlin
Tel.: 030 – 81 884 0
E-mail: datenschutzbeauftragter@cbe-digiden.de
III. General information on data processing
1. Scope of processing of personal data
We generally only process the personal data of our users to the extent that this is necessary to provide a functional website and our content and services. The processing of our users’ personal data usually only takes place after the user has given their consent. An exception applies in cases where prior consent cannot be obtained for actual reasons and the processing of the data is permitted by law.
2. Legal basis for the processing of personal data
If we obtain the consent of the data subject for processing personal data, Art. 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.
For the processing of personal data that is necessary to fulfill a contract to which the data subject is a party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
If the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
If processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) (f) GDPR serves as the legal basis for processing.
3. Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to further store the data for the conclusion or fulfillment of a contract.
4. Cooperation with processors and third parties
If, as part of our processing, we transmit data to other people and companies (processors or third parties) or otherwise grant them access to the data, this will only be done on the basis of a legal permission, you have consented, a legal obligation requires this, for the processing of contractual relationships with you or we have a legitimate interest in the data transmission (e.g. when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
5. Company profiles in social media
We operate company profiles within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write posts on our online presence or send us messages.
IV. Provision of the website and creation of log files
When you visit our website ww.cbe.de, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is recorded without your intervention and stored until it is automatically deleted:
- Information about the browser type and version used
- The user’s operating system
- The user’s Internet service provider
- The user’s IP address
- Date and time of access
- Websites from which the user’s system accesses our website
- Websites that are accessed by the user’s system via our website
The data mentioned is processed by us for the following purposes:
- Ensuring a smooth connection to the website,
- Ensuring comfortable use of our website,
- Evaluating system security and stability and
- for other administrative purposes.
The legal basis for data processing is Art. 6 Paragraph 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above. Under no circumstances do we use the data collected to draw conclusions about you personally. In addition, we use cookies and analysis services when you visit our website. You can find more detailed explanations in sections V and VIII of this data protection declaration.
V. Use of cookies
We use cookies on our website. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause any damage to your device and do not contain viruses, Trojans or other malware. Information is stored in the cookie that is related to the specific device used. However, this does not mean that we thereby receive direct knowledge of your identity.
On the one hand, the use of cookies serves to make the use of our offer more pleasant for you. We use so-called session cookies to recognise that you have already visited individual pages of our website. These are automatically deleted after you leave our site. In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your device for a specific period of time. If you visit our site again to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you (see Section VIII). These cookies enable us to automatically recognise that you have already been with us when you visit our site again. These cookies are automatically deleted after a defined period of time.
As far as cookies are technically necessary, our legitimate interest in data processing lies in the above purposes. The legal basis in these cases is Art. 6 Para. 1 lit. f) GDPR. In all other cases, the legal basis is Art. 6 Para. 1 lit. a) GDPR (your consent), which you can give us via the cookie banner displayed when you first visit our website. You can change or revoke your consent at any time in the cookie settings.
Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, completely deactivating cookies may mean that you cannot use all the functions of our website.
VI. Newsletter
On our website you can subscribe to a free newsletter. When you register for the newsletter, the following data from the input mask is sent to us:
- Email address
For the processing of the data, your consent is obtained during the registration process and reference is made to this data protection declaration. Registration for our newsletter takes place using a so-called double opt-in process. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with someone else’s email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
The newsletter is sent using “Cleverreach”, a newsletter distribution platform of CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede (“CleverReach”), to which we pass on your data for the purpose of creating and sending the newsletter. You can view CleverReach’s data protection regulations here https://www.cleverreach.com/de/datenschutz/.
Furthermore, according to its own information, CleverReach can use this data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. for the technical optimization of the dispatch and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, CleverReach does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.
The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from the CleverReach server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor that of CleverReach to observe individual users. The evaluations are much more useful for us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The legal basis for the processing of data after the user has registered for the newsletter is Art. 6 Para. 1 lit. a GDPR if the user has given their consent. The user’s email address is collected to deliver the newsletter. The collection of other personal data as part of the registration process serves to prevent misuse of the services or the email address used. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user’s email address is therefore stored as long as the newsletter subscription is active. The other personal data collected during the registration process is usually deleted after a period of seven days.
The subscription to the newsletter can be canceled by the affected user at any time. For this purpose, there is a corresponding link in every newsletter. This also makes it possible to revoke the consent to the storage of the personal data collected during the registration process. Alternatively, you can send your unsubscribe request at any time to
kontakte@cbe-digiden.de
by email with the subject “Unsubscribe”.
VII. Email contact
You can contact us via the email address provided kontakt@cbe-digiden.de. In this case, the user’s personal data transmitted with the email will be stored. In this context, the data will not be passed on to third parties. The data will only be used to process the conversation.
The legal basis for processing the data transmitted when sending an email is Art. 6 (1) (f) GDPR. If the email contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR.
We process the personal data from the email solely to process the contact. This is also where the necessary legitimate interest in processing the data lies.
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.
The user has the option of revoking his or her consent to the processing of personal data at any time. If the user contacts us by email (kontakt@cbe-digiden.de), he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. All personal data that was stored in the course of contacting us will be deleted in this case.
VIII. Tracking tools
The tracking measures listed below and used by us are carried out in accordance with Art. 6 Paragraph 1 Clause 1 Letter a of GDPR on the basis of your consent, which you gave us in the cookie banner. With the tracking measures used, we want to ensure that our website is designed to meet your needs and is continuously optimized. On the other hand, we use the tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision. The respective data processing purposes and data categories can be found in the corresponding tracking tools.
1. Google Adwords Conversion Tracking
We also use Google Conversion Tracking to statistically record the use of our website and to evaluate it for the purpose of optimizing our website for you. Google Adwords places a cookie (see Section V.) on your computer if you have accessed our website via a Google ad. These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords customer’s website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. Each Adwords customer receives a different cookie. Cookies cannot therefore be tracked across the websites of Adwords customers. The information obtained using the conversion cookie is used to create conversion statistics for Adwords customers who have opted for conversion tracking. Adwords customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that can be used to personally identify users. If you do not wish to participate in the tracking process, you can also refuse the setting of a cookie required for this purpose – for example, by using a browser setting that generally deactivates the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser so that cookies from the domain “www.googleadservices.com” are blocked. Google’s privacy policy on conversion tracking can be found here
(https://services.google.com/sitestats/de.html).
1. Matomo (formerly Piwik)
This website uses the open source web analysis service Matomo. Matomo uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of the use of the website. For this purpose, the information generated by the cookie about the use of this website is stored on our server. The IP address is anonymized before storage. The information generated by the cookie about the use of this website will not be passed on to third parties. You can prevent cookies from being saved by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. If you do not agree to the storage and use of your data, you can deactivate the storage and use. In this case, an opt-out cookie will be stored in your browser that prevents Matomo from saving usage data. If you delete your cookies, this will also result in the Matomo opt-out cookie being deleted. The opt-out must be reactivated when you visit our site again.
IX. Third-party services
1. Youtube
We embed videos from the “YouTube” platform on our website, which is provided by Google Ireland Limited (“Google”), a company registered and operated under Irish law (registration number: 368047) with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland (). If you visit one of our pages equipped with a YouTube plug-in, a connection to the YouTube servers will be established unless you have objected to the setting of cookies via our cookie banner. If a connection is established, the YouTube server will be informed which of our pages you have visited. This information (including your IP address) is sent directly from your browser to the YouTube server and stored there. If you are logged into your YouTube account, you allow YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account. Further information on how user data is handled can be found in YouTube’s privacy policy at: https://www.google.de/intl/de/policies/privacy
We only integrate the YouTube plug-in after you have given your consent in accordance with Art. 6 Paragraph 1 Clause 1 Letter a of GDPR via the cookie banner displayed when you first visit our website in order to protect visitors to our website as best as possible. You can object to the use of the plug-in at any time in our cookie settings.
2. Google Maps
Google Maps API is a map service provided by Google Ireland Limited (“Google”), a company registered and operated under Irish law (registration number: 368047) with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). We use Google Maps API to display an interactive map and to create route plans. When you use Google Maps, information about your use of this website (including your IP address) may be transferred to a Google server and stored there. Further information on data protection and the terms of use for Google Analytics can be found at: https://www.google.com/intl/de_de/help/terms_maps.html and https://policies.google.com/privacy?hl=de
Google Maps will only be integrated after you have given your consent in accordance with Art. 6 Paragraph 1 Clause 1 Letter a of GDPR via the cookie banner displayed when you first visit our website in order to protect visitors to our website as best as possible. You can object to the use of the plug-in at any time in our cookie settings.
X. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
1. Right to information
You can request confirmation from the controller as to whether personal data concerning you is being processed by us.
If such processing takes place, you can request information from the controller about the following:
- the purposes for which the personal data are processed;
- the categories of personal data that are processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- the planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period;
- the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right to lodge a complaint with a supervisory authority;
- all available information about the origin of the data if the personal data are not collected from the data subject;
- the existence of automated decision-making, including profiling, in accordance with Art. 22 Paragraphs 1 and 4 of the GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
- You have the right to request information about whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate guarantees in accordance with Art. 46 of the GDPR in connection with the transfer.
2. Right to rectification
You have the right to have the personal data concerning you rectified and/or completed by the controller if the personal data concerning you that are processed are incorrect or incomplete. The controller must carry out the rectification immediately.
3. Right to restriction of processing
You can request the restriction of the processing of the personal data concerning you under the following conditions:
- if you contest the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data;
- the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;
- the controller no longer needs the personal data for the purposes of the processing, but you need them to assert, exercise or defend legal claims, or
- if you have objected to the processing pursuant to Art. 21 Para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, these data – apart from their storage – may only be processed with your consent or for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State If the restriction of processing has been restricted in accordance with the above-mentioned requirements, you will be informed by the controller before the restriction is lifted.
4. Right to erasure
a) Obligation to erase
You can request that the responsible party delete the personal data concerning you immediately, and the responsible party is obliged to delete this data immediately if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You withdraw your consent on which the processing was based in accordance with Art. 6 Para. 1 lit. a or Art. 9 Para. 2 lit. a GDPR, and there is no other legal basis for the processing.
- You object to the processing in accordance with Art. 21 Para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you object to the processing in accordance with Art. 21 Para. 2 GDPR.
- The personal data concerning you were processed unlawfully.
- The Deletion of the personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
- The personal data concerning you were collected in relation to information society services offered in accordance with Art. 8 (1) GDPR.
b) Exceptions
The right to erasure does not apply if processing is necessary
- to exercise the right to freedom of expression and information;
- to fulfil a legal obligation which requires processing under Union or Member State law to which the controller is subject, or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health pursuant to Art. 9 (2)(h) and (i) and Art. 9 (3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to make the realisation of the objectives of this processing impossible or seriously compromises it, or
- to assert, exercise or defend Legal claims.
5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing vis-à-vis the responsible party, this party is obliged to inform all recipients to whom the personal data concerning you was disclosed of said rectification, erasure or restriction of processing, unless doing so should prove impossible or involve disproportionate expenditure.
You have the right to be informed by the responsible party of these recipients.
6. Right of objection
You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR for reasons arising from your particular situation; this also applies to profiling based on these provisions.
The controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
In connection with the use of information society services, you have the option of exercising your right of objection by means of automated procedures that use technical specifications, regardless of Directive 2002/58/EC.
7. Right to withdraw the consent to data protection
You have the right to withdraw your consent to data protection at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.
8. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the GDPR.
The supervisory authority to which the complaint was submitted will inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.
As of: September 2021