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United States General Privacy Policy

Last Updated: December 14, 2023

1. General information

This General Privacy Policy explains the types of regulated Personal Information or data (“Personal Information”) that Freudenberg Medical, LLC (“Freudenberg Medical” or “we”) collects, uses, and discloses through its business operations and http://www.freudenbergmedical.com/ (its “Website”).

  • This is our Privacy Policy for the United States Market. If you are reaching our Website from elsewhere, please see the Freudenberg Privacy Policy - EEA.
  • We do not do business with the general public or intentionally collect Personal Information from individuals outside of the business-to-business context.
  • If you are a job applicant in California, please see our California Applicant Privacy Notice for additional information on how we handle the Personal Information of applicants.
  • If you are an employee in California, you have or will be provided with our Employee Privacy Notice, which contains information on how we handle the Personal Information of employees.

By providing Personal Information to us, you accept and consent to the practices described in this Privacy Policy. If you have any questions about this Notice, including if you wish to send us a request to exercise any of your legal rights, please contact us at Dataprotection-support@freudenbergmedical.com or call +1 (978) 281-2023 or +1 (877) 308-0558.

2. General categories of Personal Information we collect

Server log information. Our web server captures certain information automatically. This information may include your Internet protocol (IP) address, approximate geographic location, browser type, computer operating system, time and date you visit, the pages you access, and the address of the page that directed you to our Website. We use this data to understand patterns of Website activity and to improve the Website so it is more useful for you. This information is not linked in any way to you personally, and we do not have the means to link it to you.

Cookies. Our Website uses cookies and similar technologies. Cookies record small amounts of data in your web browser. When you enter the Website, our web server uses these for various purposes, including making our site work properly and optimizing your experience. The cookies we use – and how to control them – are shown in our Cookie Selector.

Personal Information that you intentionally submit. Aside from the above, we do not collect identifiable Personal Information from you unless you supply it voluntarily. This would happen when you communicate with us by email, fill out an online form, or conduct business with us.

Personal Information that we obtain from others. We may obtain marketing leads from outside our corporate group. This is normally basic contact information. If we have an advertising service provider perform a blind mailing (a campaign using a mail or email list known to the service provider but not disclosed to us), we do not obtain your Personal Information unless and until you respond.

Aggregated or anonymized information. In some instances, we receive information that either combines the information of numerous consumers or is transformed in such a way that the information can no longer be linked to a particular consumer or their household. Under the law, this is not Personal Information.

3. What do we do with the Personal Information we collect?

We will not sell, trade, or otherwise transfer to third parties your Personal Information that is identifiable with you personally unless we provide you with advance notice; however, we may share your Personal Information as permitted by law with the Freudenberg corporate group (our “Business”), and vendors we retain to provide services necessary to our operations (our “Service Providers”). Service Providers might include website hosting companies, public relations companies, advertising and marketing agencies, and mail delivery service companies. These parties are under obligation to use the information only in support of our business, not their own.

Some Internet Usage Information (see below) is shared with third parties for the purpose of providing you with advertising and offers relevant to your interests. You can opt out of the sharing of this information by clicking on our Cookie Selector. In general, you can opt out of specific campaigns by clicking the triangular “your ad choices” icon in a particular campaign. To opt out of targeted ads from Digital Advertising Alliance members, visit https://youradchoices.com/token.

We also reserve the right to release Personal Information (i) when the law requires it (e.g., we have received a subpoena) or we otherwise believe that the law requires us to do so; (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or safety of Freudenberg Medical, our users or others; or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud, and otherwise enforce our Privacy Policy.

Additionally, if Freudenberg Medical merges with or becomes part of another organization, or if Freudenberg Medical is sold, it sells all or substantially all of its assets, or it is otherwise reorganized, the information you provide may be one of the transferred assets to the acquiring or reorganized entity.

4. Personal Information we collect, how we collect It, and who sees It

The table below shows the Personal Information that we collect, where/how we collect it, and disclosures to third parties for our business (where we or our service providers or contractors use it to support our business). This table does not include situations involving our employees or job applicants (see the linked notices at the top).

Data elements How do we collect or obtain them? Which of our Service Providers receives them?
Internet usage information
  • Pages visited
  • ISP
  • IP address
  • Operating system
  • Browser version
  • General geolocation
  • Website preferences
  • Pages visited
  • Web server logs from your interaction with our website
  • Without personal identification
  • Marketing vendors
Contact information
  • Individual name
  • Company (if applicable)
  • Mailing address
  • Telephone number
  • Email address
  • Marketing vendors
  • Delivery/freight vendors
Personal identifiers
  • Individual name
  • Social security number
  • Driver’s license number
  • State ID number
  • Passport number
  • Date of birth
  • Gender identity
  • Geolocation
  • Web and other forms
  • Credit applications that include a personal guarantee
  • N/A
Financial information
  • Account numbers
  • Commercial transactions
  • Banks
  • Payment processors
Purchasing histories, tendencies, or profiles
  • Marketing vendors

 

5. How we use your Personal Information and how long we keep it

We request Personal Information when necessary to provide a service, complete a transaction, or otherwise run our business. Please note that the same information may be retained for different reasons, and the expiration of its retention for one reason may not trigger its deletion (for example, you may unsubscribe from a promotional mailing list and be deleted from that list, but you might also be a current customer whose information we need to retain to support your needs).

Uses of data elements by activity How long we keep the data for that use
Interaction with our website

Internet usage information.
Contact Information
This information is collected in a way that is not associated with you personally. The retention of this data is described in our Cookie Selector.
General correspondence

Contact Information
Requests for callbacks, contacts, or quotes
We maintain this information long enough to fulfill your request/inquiry plus as needed to support any resulting business communications or transactions. Where there is no activity, we delete personal information after two (2) years.
Commercial transactions (B2B)

Contact information
Financial information
Purchasing histories, tendencies, or profiles
We maintain basic contact and transaction information for the period required to fulfill the transaction plus the amount of time required to document the transaction, honor any warranties, and fulfill any recall obligations.

We use contact information obtained in transactions as a basis to provide you with information on related offerings and special offers. To be deleted from our promotional mailing lists, please use the “unsubscribe” link at the bottom of a marketing email.
Promotional/marketing information

Contact information
Purchasing histories, tendencies, or profiles
We maintain information sufficient to send out mailing lists and other business information/promotions until you unsubscribe from the relevant campaign using the supplied link (for email) or other methods as provided in postal mailings.

 

6. How do we protect your Personal Information?

Although no system is impenetrable, we have established physical, electronic, and procedural safeguards for the information we collect that is reasonable given the nature of the information and its sensitivity.

7. For residents of California

Under the laws of your state, and as those laws become effective, you have certain rights regarding information that could reasonably be used to identify you or your family. This Privacy Policy is provided so that you can understand at or before the point of collection what we are collecting and why. These rights do not extend to anonymized or aggregated information that can no longer be connected to you personally. Please note also that certain banking and health information is outside the scope of these states’ data privacy laws.

Right to know and data portability. You have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about the consumer. These are described generally in this Notice and specifically in the table in Section 4.

Under California law, we are not required to research Personal Information where it is not in a reasonably searchable format, we maintain the information solely for legal or compliance reasons, we do not use the information for commercial purposes or sell it, and we explain what we are not searching on these grounds. Likewise, we are not required to disclose a particular Social Security number, driver’s license number or another government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions, and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. We will, however, identify which of these items we retain.

Right to deletion. You have the right to delete Personal Information that we have collected from you, subject to certain exceptions; except where there is a statutory exception. In California, these exceptions when the Personal Information is needed to:

  1. Complete a transaction for which the Personal Information was collected, provide a good or service requested by you, reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act under Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the California Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research if you have provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Other exceptions may be present under state law. Depending on your state, we may ask you to confirm your election to delete your Personal Information.

Right to correct Personal Information. You have the right to correct inaccurate Personal Information that we maintain about you. We may request documentation establishing the inaccuracy of the information we have. Per applicable law, these requests may be denied if the totality of the circumstances suggests that the information we have on file is accurate.

Right to limit the use of Sensitive or Special Personal Information. You have the right to limit the use of sensitive Personal Information (as defined by law) to that necessary to conduct business with you. Freudenberg Medical does not collect intentionally collect these types of information from the public and does not use them in its external business dealings.

Right to opt out of the sale or sharing of your Personal Information. Freudenberg Medical does not sell Personal Information and has not done so in the past twelve (12) months. See above for information on how to opt out of the sharing of information.

Right to non-discrimination. You have the right to not be discriminated against due to the exercise of your privacy rights under state privacy law. However, the exercise of certain privacy rights by California residents may make it so that we are no longer able to provide those residents with certain services or communications. For example, if, at the request of a California resident, Freudenberg Medical deletes all of the California resident’s Personal Information that it maintains, Freudenberg Medical will no longer be able to send communications to that resident.

Right to opt out of automated decision-making or profiling. You have the right to know about and opt out of automated decision-making.

Other rights: to the extent you have data subject rights that are not shown here, we will respect them.

Exercising your rights. To exercise your rights under your state’s law, please contact Dataprotection-support@freudenbergmedical.com or call (626) 814-9684 and state the nature of your request. We will require you to verify your identity. There are some circumstances in which we are not required to grant requests concerning your Personal Information, including where repeated requests are made for purposes of harassment or fraud.

Authorized agents. We entertain requests from authorized agents according to your state’s law. California residents can designate an authorized agent to make requests under the CCPA on their behalf relating to the residents’ Personal Information. Only you as a California resident, or a person you have designated in writing as your authorized agent, may make a consumer request related to your Personal Information.

If you wish to have an authorized agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent, such as a power of attorney under California Probate Code sections 4000 to 4465. We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we have collected Personal Information.

We can deny any request made by a purported authorized agent who does not submit proof that they have been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information provided in Section 14.

Response time. Consistent with CCPA, we will respond within 45 days of a verifiable request to provide or erase your Personal Information, unless we notify you that up to another 45 days will be needed.

Notice of Financial Incentives: California residents are entitled to certain information about Freudenberg Medical’s financial incentive programs. However, we do not offer any programs with a financial incentive, as defined by the CCPA, to consumers.

8. Do Not Track

DNT is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. We do not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available third-party tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.

9. Minors

Our website is not intended to be used by persons under the age of eighteen (18), and we do not knowingly store Personal Information of any kind relating to such persons. If you are the parent or guardian of a minor and believe that a minor’s Personal Information has been collected, please contact us so that we may delete it.

10. How can you opt out of emails and block or restrict cookies?

Emails. You can opt out of receiving future promotional electronic mailings from us by following the unsubscribe procedures indicated in each electronic mailing, such as “unsubscribe” or “manage your preferences.

Cookies. We use cookies to keep track of and enhance certain user activities on our Website such as saving your preferences and user-specific features. You may block or restrict cookies on your computer or purge them from your browser by adjusting your web browser preferences.

You should consult the operating instructions that apply to your browser for instructions on how to configure your browser setting to meet your preferences.

However, because cookies may allow you to take advantage of some features or functions of our Website, we recommend that you leave them turned on.

More information is contained in our Cookie Selector.

11. How can you update your Personal Information?

Direct contact. If you have another type of account or relationship with us, please contact the contact at the bottom of this policy.

12. What about links to other websites?

This statement applies only to this Website. This Website may contain links to third-party websites. We are not responsible for the content or policies of such websites and recommend that you check the privacy statements posted on their websites.

13. What if this Privacy Policy changes?

Our business changes from time to time, and our Privacy Policy will change too. Your continued use of our Website following the posting of any amendment to this Privacy Statement indicates your acceptance of the revised Privacy Policy. We may send you notices of changes to our Privacy Policy if we possess your contact information at the time of such updates.

14. How do I ask questions or provide feedback?

We welcome your questions, comments, and concerns about privacy. Freudenberg Medical is committed to the resolution of concerns about your privacy and our collection or use of your Personal Information. If you have any questions regarding this privacy statement or how we protect your Personal Information, please contact us at:

Freudenberg Medical
Attn: Consumer Affairs/Privacy
40 Sam Fonzo Drive
Beverly, MA 01915
+1 (978) 281-2023

+1 (877) 308-0558

Dataprotection-support@freudenbergmedical.com 

 

Privacy Policy according to GDPR

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

We are hosting the content of our website at the following provider:

Hetzner

The provider is the Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter referred to as Hetzner).

For details, please view the data privacy policy of Hetzner: https://www.hetzner.com/de/rechtliches/datenschutz.

We use Hetzner on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable depiction of our website possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Google Cloud CDN

We use the Google Cloud CDN content delivery network. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google offers a globally distributed content delivery network. Technically, the transfer of information between your browser and our website is routed through the Google network. This enables us to increase the global accessibility and performance of our website.

The use of Google Cloud CDN is based on our legitimate interest in the most error-free and secure provision of our website (Art. 6(1)(f) GDPR).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://cloud.google.com/terms/eu-model-contract-clause.

You can find more information about Google Cloud CDN here: https://cloud.google.com/cdn/docs/overview?hl=en.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Freudenberg Medical Europe GmbH
Liebigstr. 2-8
67661 Kaiserlautern
Germany

Phone: +49 631 5341 7500
E-mail: Dataprotection-support@freudenbergmedical.com 

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

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

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

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer

We have appointed a data protection officer.

Ingenieurbüro Dr. Plesnik GmbH
Kaiserstraße 100
52134 Herzogenrath
Germany

Phone: +49 241 149460
E-mail: datenschutz@plesnik.de

Information on data transfer to the USA and other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

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 should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

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

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

Consent with Cookiebot

Our website uses consent technology from Cookiebot to obtain your consent to the storage of certain cookies on your end device or for the use of certain technologies and to document this in a data protection-compliant manner. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter “Cookiebot”).

When you enter our website, a connection is established with the Cookiebot servers to obtain your consent and provide you with other explanations regarding the use of cookies. Cookiebot will then store a cookie in your browser to identify the consent you have given or its revocation. The data collected in this way is stored until you request us to delete it, delete the Cookiebot cookie itself or the purpose for which the data is stored no longer applies. Mandatory legal storage obligations remain unaffected.

Cookiebot is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

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

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

5. Social media

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendumhttps://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381.

LinkedIn

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.

If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=en.

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

6. Analysis tools and advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

LinkedIn Insight Tag

This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data processing by LinkedIn Insight tag

We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.

LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.

The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.

Legal basis

If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in effective advertising promotions that include the utilization of social media.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

Objection to the use of LinkedIn Insight Tag

You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

7. Plug-ins and Tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Fonts

With your consent to play videos from YouTube on this website, YouTube uses so-called Google Fonts, which are provided by Google, for the uniform display of fonts. When you call up the page, your browser loads the required fonts into its browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google's servers. Through this, Google obtains knowledge that this website was accessed via your IP address. The use of Google Fonts in the context of YouTube videos is based on Art. 6 (1) lit. a GDPR. and § 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

If your browser does not support Google Fonts, a standard font will be used by your computer.

You can find more information about Google Fonts at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=de.

Vimeo

This website uses plug-ins of the video portal Vimeo. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.

If you visit one of the pages on our website into which a Vimeo video has been integrated, a connection to Vimeo’s servers will be established. As a consequence, the Vimeo server will receive information as to which of our pages you have visited. Moreover, Vimeo will receive your IP address. This will also happen if you are not logged into Vimeo or do not have an account with Vimeo. The information recorded by Vimeo will be transmitted to Vimeo’s server in the United States.

If you are logged into your Vimeo account, you enable Vimeo to directly allocate your browsing patterns to your personal profile. You can prevent this by logging out of your Vimeo account.

Vimeo uses cookies or comparable recognition technologies (e.g. device fingerprinting) to recognize website visitors.

The use of Vimeo is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here: https://vimeo.com/privacy.

For more information on how Vimeo handles user data, please consult the Vimeo Data Privacy Policy under: https://vimeo.com/privacy.

Friendly Captcha

We use Friendly Captcha (hereinafter referred to as “Friendly Captcha”) on this website. The provider is
Friendly Captcha GmbH, Am Anger 3-5, 82237 Woerthsee, Germany.

Friendly Captcha is used to verify whether the entry of data into this website (e.g., into a contact form) is
being processed by a person or an automated program. For this purpose, Friendly Captcha analyzes the
behavior patterns of website visitors based on numerous characteristics. For the analysis, Friendly Captcha
examines a wide range of information (e.g., anonymized IP address, referrer, time of the visit, etc.).
For more related information please visit: https://friendlycaptcha.com/legal/privacy-end-users/.

The storage and analysis of the data occurs on the basis of Art. 6 (1)(f) GDPR. The website operator has a
legitimate interest in protecting the operator’s web presentations against abusive automatic spying and
SPAM. In the event that respective consent has been obtained, the data will be processed exclusively on the
basis of Art. 6 (1)(a) GDPR and § 25 (1) TTDSG, if the consent comprises the storage of cookies or access to
information on the user’s device (e.g., device fingerprinting) as defined in the TTDSG (German
Telecommunications Act). Such consent may be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.

8. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access 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).

Furthermore, the provider of the tool processes all the technical data required for the processing of the 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 loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

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

Conference tools used

We employ the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

9. Custom Services

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.