networker variant

Privacy Policy

Privacy Policy

A. General Information

As networker, solutions GmbH (hereinafter referred to as “networker” or “we”), we process personal data in accordance with Article 26 of the General Data Protection Regulation (GDPR). In the following privacy information, we outline the data processing activities that we undertake.

B. Principles

The data processing of our GmbH based in the European Union (“EU”) and the European Economic Area (“EEA”) also includes the disclosure through transmission to third parties and, where applicable, to so-called third countries outside the EU and the EEA. Where we transfer data to countries outside the EU or the EEA, we have marked this accordingly below.

C. Responsible Entity

1. Contact Information

1.1 Contact Person

We have appointed a data protection officer in accordance with Article 37 of the GDPR. You can contact the data protection officer at the following contact details:

External Data Protection Officer:
Andreas Pohl on behalf of Pohl Consulting Team GmbH
Mengeringhäuser Straße 15
34454 Bad Arolsen
Germany

Phone: +49 5691 8900 501
Email: [email protected]

1.2 Responsible Entity

The responsible entity in the context of the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) for the processing of your personal data is:

networker, solutions GmbH
Tibarg 31
22459 Hamburg
Germany

Phone: +49 (0) 40 228 666 40
Email: [email protected]

The responsible entity is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2. Data Processing

The data involved in joint data processing, the purposes of processing, legal bases, recipients, and where applicable, transfers to third countries are outlined in the following sections:

2.1 Contacting Us

When you contact us, we process the following data for the purpose of processing and handling your inquiry: Name, contact details (if provided), and your message.

The legal basis for data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations in accordance with Art. 6 (1) b) GDPR and/or our overriding legitimate interest in processing your inquiry in accordance with Art. 6 (1) f) GDPR.

2.2 Log Files During Website Visit

We log your visit to the websites operated by us. In doing so, we process the following data:

  • Name(s) of the website(s) retrieved
  • Date and time of the retrieval
  • Amount of data transmitted
  • Browser type and version
  • The operating system you use
  • The referrer URL (the previously visited website)
  • Your IP address
  • The requesting provider

The legal basis for data processing is our overriding legitimate interest in the continuous availability and security of our website, according to Art. 6 (1) f) GDPR.

The log file is deleted after seven days, unless it is required to demonstrate or investigate specific legal violations that have become known during the retention period.

2.3 Hosting via IONOS

To provide our online presence, we use services from web hosting providers who process the above-mentioned and any other data in connection with the operation of this website (log file during website visit) on our behalf.

The legal basis for data processing is our overriding legitimate interest in providing our website, according to Art. 6 (1) f) GDPR.

Details/Information on data protection: Privacy Policy – IONOS Terms and Conditions

2.4 Newsletter Offering

To provide you with regular information about our company and offerings, we offer the sending of an email newsletter. By subscribing to the newsletter, we process the data you entered during the subscription (email address and any other voluntary information). To prevent misuse, we send you a confirmation email after your registration asking you to confirm your subscription (Double-Opt-In procedure). To comply with legal requirements, your subscription is logged. This includes the subscription and confirmation time and your IP address.

The legal basis for sending the newsletter is your consent in accordance with Art. 6 (1) a) GDPR. Data processing related to the confirmation email and the associated logging of data is carried out in accordance with Art. 6 (1) f) GDPR based on our legitimate interest in proving your proper registration.

If you provide your consent, we will also analyze whether you have opened the newsletter and your scroll and click behavior within the newsletter. This is done to tailor the content of the newsletter to your interests and improve the quality of the newsletter. The legal basis for the analysis of the newsletter is your consent in accordance with Art. 6 (1) a) GDPR.

For the sending of newsletters, we use service providers to whom we transmit the relevant data.

The collected data is transmitted to the servers of the following service provider as part of processing on our behalf to Ireland: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. HubSpot’s European branch is based in Ireland: 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500. HubSpot is certified under the EU-US Data Privacy Framework and, as such, is covered by the EU adequacy decision for the USA.

Email Direct Marketing for Existing Customers

If you have not objected, we will send you direct marketing regarding goods and services you have purchased, offering similar goods and services. We use the email address you provided at the time of contract conclusion.

You can object to this use at any time, without any costs other than the transmission costs according to basic tariffs.

The legal basis for sending this direct marketing is Art. 6 (1) f) GDPR.

For customers in Germany, we also observe the provisions of § 7 (3) of the Act Against Unfair Competition (UWG) in conjunction with Art. 95 GDPR.

For customers located in Switzerland, the direct marketing is in accordance with Swiss Data Protection Law (DSG) as well as Art. 3 lit. o final sentence of the Act Against Unfair Competition (UWG) Switzerland.

For sending the promotional emails, we use service providers to whom we transmit the relevant data.

The collected data is transmitted to the servers of the following service provider as part of processing on our behalf to Ireland: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. HubSpot’s European branch is based in Ireland: 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500. HubSpot is certified under the EU-US Data Privacy Framework and, as such, is covered by the EU adequacy decision for the USA.

2.5 Live-Chat

We use a chat tool on our website to enable you to contact us via live chat. The data processing occurs based on your consent according to Art. 6 (1) a) GDPR.

In this context, we use various service providers:

2.5.1 HubSpot

We use the HubSpot chat tool, provided by HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA (HubSpot). HubSpot is integrated into our website via the appropriate JavaScript. HubSpot uses cookies. Information about the specific cookies we use, their providers, and their purposes can be found in our consent banner, which can be accessed at any time in the privacy settings at the bottom right of the website.

When using the HubSpot chat tool, the following data is processed: chat content, date and time of access, browser type/version, operating system used, URL of the previously visited website, individual user ID, number of visits, and the amount of data sent.

The data is transmitted to the servers of the following service provider within the framework of processing on behalf of networker to Ireland: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA.

The European branch of HubSpot, Inc. is based in Ireland: 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500.

HubSpot is certified under the EU-US Data Privacy Framework and thus falls under the EU’s adequacy decision for the USA.

More information about the cookies used by HubSpot can be found in our consent management platform, which can be accessed by clicking on the left bottom of the website.

2.6 Use of Cookies

We use so-called cookies on our website. Cookies are small text files that are placed on your device (PC, smartphone, tablet, etc.) and stored by your browser.

Information about the specific cookies we use, their providers, and their purposes can be found in our consent banner, which can be accessed at any time in the privacy settings at the bottom right of the website. There, you can give your consent according to § 25 (1) TDDG (Telecommunications-Telemedia Data Protection Act), withdraw it, or adjust your settings.

2.6.1 Our Consent Banner

To document your choices regarding specific data processing activities and to fulfill our data protection obligations, we use a consent banner. When you visit our website, your cookie preferences are requested via the banner. We then set a cookie in which data regarding granted or withdrawn consents is stored. Data processing occurs to fulfill our legal obligations according to Art. 6 (1) c) GDPR.

2.7 Analysis / Marketing

2.7.1 Google Services

We use various services from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereafter “Google”) on our website. This may also involve data transfers to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA.

Google is certified under the EU-US Data Privacy Framework and thus falls under the EU’s adequacy decision for the USA.

(a) Google Analytics

We use Google Analytics, a tracking tool from Google, to evaluate your use of our website, compile reports on activities within this web service, and provide additional services related to website usage to improve user-friendliness.

Google Analytics uses cookies to track and systematically analyze website visitors’ interactions.

We use Google Analytics with the “anonymizeIp()” extension, which anonymizes IP addresses within EU or EEA member states. If data is transmitted to Google’s servers in the USA, only in exceptional cases will the full IP address be transmitted and shortened there. A direct personal reference is generally excluded. In particular, it is no longer possible to assign the data to the specific computer or device used by the website visitor.

The following data is processed by Google Analytics:

  • The first 3 bytes of the IP address of the user’s system (anonymized IP address),
  • The visited website,
  • The website from which the user reached the visited page (referrer),
  • The subpages accessed from the website,
  • The duration of the stay on the website,
  • The frequency of visits to the website.

Google states that it will not link your IP address with other Google data.

(b) Google Tags / Remarketing / Retargeting

We use Google tracking cookies on our website. When visiting our page, permanent cookies store information about which products you have viewed on our site and which advertisements and third-party pages have led users to our website. Upon a subsequent visit to a partner website, we can display personalized advertisements based on the products you previously viewed.

(c) Google Ads

We use Google Ads, an online advertising program by Google, on our website. This includes conversion tracking. When you click on an ad by Google, a cookie is set. This cookie expires after 30 days and does not identify the user personally. If the user visits certain pages of this website and the cookie has not yet expired, both Google and we can recognize that the user clicked on the ad and was directed to this page.

The data collected through the conversion cookie is used to create statistics for Ads customers who have opted for conversion tracking.

(d) Legal Basis and Revocation

The legal basis for data processing within the framework of the above Google services is your prior consent according to Art. 6 (1) a) GDPR.

You can withdraw your consent at any time with effect for the future by adjusting your preferences in our consent banner.

2.7.2 HubSpot

We also use tracking tools from HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA (HubSpot) on our website. We use HubSpot to analyze your use of the website, compile reports on activities within this web service, and provide additional services related to website usage to improve user-friendliness. HubSpot primarily captures and analyzes interactions of website visitors using cookies.

The legal basis for data processing is your prior consent according to Art. 6 (1) a) GDPR.

You can withdraw your consent at any time for the future by adjusting the settings in our consent management platform, which can be accessed at the bottom right of the website.

The data is transmitted to the servers of the following service provider as part of processing on behalf of networker to Ireland:

HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA.

The European branch of HubSpot, Inc. is located in Ireland: 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500.

HubSpot is certified under the EU-US Data Privacy Framework and thus falls under the EU’s adequacy decision for the USA. More information about the cookies used by HubSpot can be found in our consent management platform.

2.8 Webinars

As part of your participation in webinars, we process your data. For registration and conducting a webinar, we process the following personal data:

  • Communication data (e.g., your email address, if provided)
  • Personal information (if provided)
  • Company data
  • Log files, protocol data
  • Metadata (e.g., IP address, participation time, etc.).

Unless otherwise stated, such as in the invitation, we will not allow audio or video recordings of participants to ensure anonymity.

Additionally, other data may be required depending on the webinar tool used for the event (e.g., MS Teams, Zoom, etc.). In such cases, we will provide additional information during registration, including details about possible recipients and potential data transfers to third parties.

The data will be used exclusively for managing your registration and participation in the webinar and for sending information, notifications, and materials related to the webinar.

The legal basis for data processing is Art. 6 (1) b) GDPR (performance of a contract) and, if applicable, Art. 6 (1) f) GDPR (legitimate interest). Our legitimate interest lies in the smooth execution of the webinar.

3 Rights of the Data Subject

Your rights as a data subject can be found in section E.

4 Exercise of Your Rights and Right to Lodge a Complaint

If you have any questions about the processing of your personal data, or if you wish to request information, correction, blocking, objection, or deletion of data, or if you wish to transfer data to another company, please contact us at:
[email protected]

D. Data Processing

1 Data Processing Activities

The following table outlines the specific data processing activities, processing purposes, legal bases, recipients, and potential transfers to third countries:

1.1 Contract Fulfillment and Data Management in the Provision of Services

In the context of providing our services, as well as initiating and executing the existing contractual relationship between you and us, we process various data. If you have commissioned us to provide a service, we process your data (if provided: name, contact details, address) and any information necessary for fulfilling the service exclusively for the purpose of processing and completing the contractual relationship. This includes particularly appropriate advice and support, correspondence with you, invoicing, and fulfilling our accounting and tax obligations.

The data processing occurs based on Art. 6 (1) b) GDPR for the performance of the contract, as well as, if applicable, Art. 6 (1) c) GDPR for the fulfillment of our legal obligations.

If necessary for contract fulfillment, your data may be transferred to third parties. This includes, in particular, the transfer to supervisory authorities for correspondence and for asserting and defending your rights.

Additionally, the group companies cooperate in providing various services. In this case, data will be shared with subsidiaries within processing on behalf of networker.

1.2 External Content on Our Website

We use dynamic content (“Content”) from third parties to optimize the presentation and offerings of our website. When visiting the website, an automatic request is made to the server of the respective content provider via an interface, and certain log data (e.g., the user’s IP address) is transmitted. The dynamic content is then delivered and displayed on our website.

We use external content in connection with the following functionalities:

1.2.1 Embedding YouTube Videos

We have embedded videos from the YouTube platform operated by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (“YouTube”) on our website. The data processing at YouTube is carried out by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereafter “Google”). When the videos are played, log data is transmitted to YouTube servers in the USA.

The legal basis for data processing is our legitimate interest in optimally marketing our online offerings in accordance with Art. 6 (1) f) GDPR.

Google is certified under the EU-US Data Privacy Framework and thus falls under the EU’s adequacy decision for the USA.

1.2.2 Google Maps

We use the “Google Maps” service from Google on our website to provide you with an interactive map. When displaying the map, data, including your IP address and location, is transmitted to Google’s servers and stored there.

The legal basis for processing is your prior consent according to Art. 6 (1) a) GDPR.

The data processing responsibility for Maps lies with Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereafter “Google”). It cannot be ruled out that data is transferred to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google is certified under the EU-US Data Privacy Framework and thus falls under the EU’s adequacy decision for the USA.

2 Social Media

In this section, we inform you about the data processing carried out through the social media channels we operate.

2.1 LinkedIn

2.1.1 Joint Responsibility for Data Processing

LinkedIn is a product provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Together with LinkedIn, we are jointly responsible for the data processing related to our company profile, particularly concerning the “Page Insights” feature, in accordance with the General Data Protection Regulation (GDPR), Art. 4 No. 7 GDPR. When you visit our company profile, personal data is processed by LinkedIn and us as the data controllers.

LinkedIn holds primary responsibility under the GDPR for processing Page Insights data. LinkedIn is therefore responsible for all obligations under the GDPR regarding the processing of Page Insights data (including Articles 12 and 13, Articles 15 to 22, and Articles 32 to 34 GDPR). LinkedIn remains solely responsible for processing such personal data related to Page Insights that do not fall under the existing Page Insights Joint Controller Addendum.

The “Page Insights Joint Controller Addendum” can be accessed at: https://legal.linkedin.com/pages-joint-controller-addendum.

You can find LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy.

2.1.2 What Data Do We Process and for What Purpose?

Exchange and Communication

The purpose of operating our company profile on LinkedIn is to establish contact with users and visitors of the LinkedIn social network and engage in communication. Through this, we directly inform about our company and associated offerings.

As a LinkedIn profile user, we may process the data you provide as a LinkedIn member. This includes all the information you have posted on your profile, messages you send to us, and interactions with our content. This particularly happens when you share or recommend our content, comment on it, interact with us, or reference our profile within LinkedIn.

The processing of personal data by us is based on our legitimate interests in effective communication with LinkedIn users and visitors to our profile, as well as in communication with users on our social media profiles and our company presentation, in accordance with Art. 6 (1) f) GDPR.

Applications

If you submit your application via LinkedIn, or express interest in a job offer that we present to you, the data you provide (e.g., name, email address, desired location, LinkedIn profile data, etc.), your message, and any submitted application documents will be processed exclusively for the purpose of handling and processing your application.

The processing of applicant data by us is based on § 26 (1) BDSG. According to this, processing is permitted if it is necessary for the decision about establishing an employment relationship.

Should the data be required for legal claims after the application process, data processing may occur to protect our legitimate interests under Art. 6 (1) f) GDPR, particularly for asserting and/or defending claims.

User Analysis

LinkedIn provides us with various insights into the visits and visitors to our company page through the “Page Insights” service. These insights are created by LinkedIn and help us improve the marketing of our activities. These are aggregated data, meaning they cannot be traced back to any individual. Data processing within the “Page Insights” service is solely the responsibility of LinkedIn. We do not have access to personal data, except in an aggregated form.

The processing of personal data by us is based on our legitimate interests in effective communication with LinkedIn users and visitors to our profile, as well as in connection with communication with users on our social media profiles and our company presentation, in accordance with Art. 6 (1) f) GDPR.

2.1.3 Data Transfer and Data Transmission to the USA

It is possible that data collected when visiting our company profile will be forwarded to LinkedIn Corporation in the USA for processing. LinkedIn is certified under the EU/US Data Privacy Framework and thus falls under the EU’s adequacy decision for the USA.

We do not transfer data to third parties within the context of operating our company profile.

2.2 XING

2.2.1 What Data Do We Process and for What Purpose?

Exchange and Communication

We operate a company profile on the online platform of the social network “XING,” owned by New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany. The purpose of running our company profile on XING is to engage with users and visitors of the social network, foster communication, and receive applications directly through XING. We provide direct information about our company and related offerings.

As a user of a XING company profile, we may process the data you provide as a XING member. This includes all information you have provided on your profile, messages you send to us, and interactions with our content. This particularly happens when you share or recommend our content, comment on it, or reference our profile within XING.

For information on which data XING processes and for what purposes, please refer to XING’s privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

The processing of personal data by us is based on our legitimate interests in effective communication with XING users, visitors to our profile, receiving applications directly via XING, and communication with users on our social media profiles and our company presentation, in accordance with Art. 6 (1) f) GDPR.

Applications

If you submit your application via XING, or express interest in a job offer that we present to you, the data you provide (e.g., name, email address, desired location, XING profile data, etc.), your message, and any submitted application documents will be processed exclusively for the purpose of handling and processing your application.

The processing of applicant data by us is based on § 26 (1) BDSG. According to this, processing is permitted if it is necessary for the decision about establishing an employment relationship.

Should the data be required for legal claims after the application process, data processing may occur to protect our legitimate interests under Art. 6 (1) f) GDPR, particularly for asserting and/or defending claims.

2.2.2 Data Transfer and Data Transmission to the USA

No data transfer to third parties takes place in the context of operating our company profile.

E. Your Rights as a Data Subject

Unless otherwise specified in the respective privacy notices, the following rights apply to you as a data subject.

Your Rights as a Data Subject

  1. Right to Information Upon request, you will receive, free of charge, information about all personal data we have stored about you at any time.
  2. Correction, Deletion, Restriction of Processing (Blocking), Objection If you no longer agree with the storage of your personal data or if this data has become inaccurate, we will initiate the deletion or blocking of your data or make the necessary corrections upon your request (as far as this is possible under applicable law). The same applies if we should only process the data restrictively in the future. You also have the right to object, particularly in cases where your data is required for the performance of a task in the public interest or the processing is based on our legitimate interests, including profiling based on these interests. Additionally, you have the right to object if the data is being processed for direct marketing purposes.
  3. Right to Withdraw Consent for Future Processing Any consents you have given can be revoked at any time, with effect for the future. Your withdrawal does not affect the lawfulness of processing carried out until the withdrawal.
  4. Data Portability If data processing is based on a contract, pre-contractual negotiations, consent, or automated procedures, you have the right to data portability. Upon request, we will provide your data in a common, structured, and machine-readable format so that you can transfer it to another controller, if desired.
  5. Restriction of Processing Data that cannot be used to identify the data subject, such as data anonymized for analysis purposes, is not covered by the above rights. However, access, deletion, blocking, correction, or transfer to another company may be possible if you provide us with additional information that allows identification.
  6. No Automated Decision Making Data subjects are not subjected to automated decision-making processes as per Article 22 of the GDPR. If this is to occur in an individual case, the affected individuals will be informed separately.
  7. Exercising Your Rights and the Right to Lodge a Complaint If you have questions regarding the processing of your personal data, if you wish to obtain information, request correction, blocking, objection, or deletion of data, or wish to transfer the data to another company, please contact the respective department mentioned above.

    You also have the option to lodge a complaint with a supervisory authority regarding your data subject rights.

Status of this Privacy Policy: January 2024.