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This data protection declaration clarifies the type, scope and purpose of the processing of personal data (referred to as „data”) within our online offers and the websites, functions and content connected to it, as well as external online presences, e.g. our social media profile (collectively referred to as the „online offer”). With regard to the terminology used, e.g. “Processing” or “responsible person” we refer to the definitions in article 4 of the General Data Protection Regulation (GDPR).

 

Responsible:

SatMARS Navigations- u. Kommunikationssysteme GmbH

Bussardweg 14

41468 Neuss

Germany

Contact Details

Imprint

 

Types of data processed:

  • Inventory data (e.g., names, addresses)
  • Contact details (e.g., email, phone numbers)
  • Content data (e.g., text input, photographs, videos)
  • Usage data (e.g. websites visited, interest in content, access times)
  • Meta / communication data (e.g., device information, IP addresses)

 

Types of data processed:

Visitors and users of the online offer (collectively referred to as „users”).

 

Purpose of processing:

  • Providing the online offer, its functions and content.
  • Answering contact inquiries and communicating with users.
  • Safety measures.
  • Range measurement / marketing

 

Terms used:

Personal data is information that relates to an identified or identifiable natural person (referred to as „data subject”); A natural person is considered to be identifiable, if he or she can be identified directly or indirectly, in particular by assigning an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.

“Processing” is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data. The term practically covers every handling of data. The term is to be given a broad interpretation and, in practice, covers all handling of data.

„Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data cannot be assigned to an identified or identifiable natural person.

“Profiling” means any type of automized processing of personal data, which consists in the fact that this personal data is used to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal analyze or predict the preferences, interests, reliability, behavior, location or change of location of this natural person.

The “person responsible” is the natural or legal person, public authority, agency or other body that alone or with others decides on the purposes and means of processing personal data.

„Processor” is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.

 

Relevant legal bases:

In accordance with article 13 GDPR, we will inform you of the legal basis for our data processing. Unless the legal basis is mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is laid down in article 6 (1)(a) and article 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as answering inquiries is article 6 (1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is article 6 (1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is article 6 (1)(f) GDPR. In the case of vital interests of data subject or others require the processing of personal data, article 6 (1)(d) GDPR serves as the legal basis.

 

Safety measures:

In accordance with article 32 GDPR, we will take appropriate technical considerations, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing, as well as the different probability and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of the data by controlling the physical access to the data, as well as the access itself, input, transfer, securing availability and their separation. Furthermore, we have set up procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (article 25 GDPR).

 

Cooperation with processors and third parties:

If we disclose data to other people and companies (processors or third parties) as part of our processing, transmit them to them or give them access to the data, this will only be done on the basis of legal permission (e.g. if the data is transmitted to third parties, as to payment service providers, in accordance with article 6 (1)(b) GDPR for the fulfillment of the contract), your consent, a legal obligation or based on our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called „order processing contract”, this is done on the basis of article 28 GDPR.

 

Transfers to third countries:

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this takes place within the scope of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it is carried out to fulfill our (pre) contractual obligations, based on your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of article 44 ff. GDPR are met. I.e. the processing takes place e.g. on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the „Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called „standard contractual clauses”).

 

Rights of the data subjects:

You have the right to request confirmation as to whether the data in question are being processed, and for information about this data, for further information and a copy of the data in accordance with article 15 GDPR.

According to article 16 GDPR the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with article 17 GDPR, you have the right to request that the data in question be deleted immediately, or alternatively. In accordance with article 18 GDPR you have the right to request a restriction of the processing of the data.

You have the right to request that the data concerning you, which you have provided to us, be received in accordance with article 20 GDPR and to request their transmission to other responsible parties.

According to article 77 GDPR you also have the right to lodge a complaint with the competent supervisory authority.

 

Right of withdrawal:

You have the right to cancel a consent given at any time with effect for the future in accordance to 7 (3) GDPR.

 

Right to object:

You can object to the future processing of your data in accordance with article 21 GDPR at any time. The objection can in particular be made against processing for direct marketing purposes.

 

Cookies and right to object to direct mail:

Cookies are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie e.g. the content of a shopping cart in an online shop or a login status can be saved. Cookies are referred to as „permanent” or „persistent” and remain saved even after the browser is closed. For example, the login status is saved if the users visit it after several days. Such a cookie can also be used to store the interests of users, and used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, we speak of “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our data protection declaration.

If users do not want cookies to be stored on their computer, they have to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be found on a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ be explained. Furthermore, cookies can be deactivated in the browser settings. Please note that deactivating cookies may limit the extent to which you can use the website and the services offered there.

 

Deletion of data:

Processed data is deleted or its processing is restricted in accordance with article 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal storage obligations to prevent deletion. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data will be blocked and not processed for other purposes. This applies e.g. for data that must be kept for commercial or tax law reasons.

According to legal requirements in Germany, storage is carried out in particular for 10 years in accordance with §§ 147 (1) (AO), 257 (1) No. 1 and 4, paragraph 4 HGB (books, records, management reports, accounting documents, trading books, more relevant for taxation Documents, etc.) and 6 years according to § 257 (1) No. 2 and 3, Paragraph 4 HGB (commercial letters).

According to legal requirements in Austria, storage is carried out for 7 years in particular in accordance with Section 132 (1) BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.) for 22 years in connection with land and for 10 years for documents in connection with electronically provided services, telecommunication, radio and television services, which are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

 

Contractual services:

We process the data of our contractual partners and interested parties as well as other clients, customers, clients or contractual partners (referred to as „contractual partners”) in accordance with article 6 (1) lit. b. GDPR to provide you with our contractual or pre-contractual services. The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact details (e.g. email addresses and telephone numbers) as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., Bank details, payment history).

We generally do not process special categories of personal data, unless they are part of commissioned or contractual processing.

We process data that are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their specification, unless this is evident to the contractual partners. Disclosure to external persons or companies only takes place if it is required under a contract. When processing the data provided to us in the context of an order, we act in accordance with the instructions of the client and the legal requirements.

As part of the use of our online services, we can save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the interests of users in protecting against misuse and other unauthorized use. This data is not passed on to third parties, unless it is used to pursue our claims in accordance with article 6 para. 1 lit. f. GDPR or there is a legal obligation to do so in accordance with. article 6 para. 1 lit. c. GDPR.

The data will be deleted as soon as they are no longer required to fulfill contractual or statutory care obligations and to deal with any warranty and comparable obligations. The necessity of storing the data is being checked every three years; otherwise, the statutory retention requirements apply.

 

Administration, financial accounting, office organization, contact management:

We process data in the context of administrative tasks as well as the organization of our company, financial accounting and compliance with legal obligations, such as archiving. We process the same data that we process as part of the provision of our contractual services. The processing bases are article 6 (1) lit. c. GDPR, article 6 (1) lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

We disclose or transmit data to the financial administration, consultants such as tax advisors or auditors as well as other fee agencies and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, organizers and other business partners, e.g. for later contact. We generally store this mostly company-related data permanently.

 

Data protection information in the application process:

We process the applicant data only for the purpose and as part of the application process in accordance with the legal requirements. The processing of the applicant data takes place to fulfill our (pre) contractual obligations in the context of the application process within the meaning of article 6 (1) lit. b. GDPR article 6 (1) lit. f. GDPR if the data processing e.g. becomes necessary for us in the course of legal proceedings (in Germany, § 26 BDSG also applies).

The application process requires applicants to provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise results from the job descriptions and basically includes information about the person, postal and contact addresses and the documents associated with the application, such as cover letter, curriculum vitae and certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting the application to us, the applicants consent to the processing of their data for the purposes of the application process in accordance with the type and scope set out in this data protection declaration.

If special categories of personal data within the meaning of article 9 (1) GDPR are voluntarily communicated within the scope of the application process, their processing is also carried out in accordance with article 9 (2) lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of article 9 (1) GDPR are requested from applicants within the application process, their processing is also carried out in accordance with article 9 (2) lit. a GDPR (e.g. health data if necessary for the exercise of a profession).

If provided, applicants can send us their applications using an online form on our website. The data is encrypted and transmitted to us in accordance with the state of the article.

Applicants can also send us their applications via email. However, please note that emails are generally not sent in encrypted form and applicants must ensure that they encrypt them themselves. We can therefore not assume any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or sending by post. Because applicants still have the option to send us the application by post instead of applying via the online form and e-mail.

The data provided by the applicants can be processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicant data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

The deletion takes place, subject to a justified revocation of the application, after a period of six months, so that we can answer any follow-up questions to the application and meet our obligations to provide evidence from the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

 

Registration function:

Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and based on article 6 (1) lit. b GDPR processed for the purpose of providing the user account. The processed data include in particular the login information (name, password and an email address). The data entered during registration will be used for the purpose of using the account and its purpose.

Users can access information that is relevant to their user account, e.g. technical changes, to be informed by email. If users have terminated their user account, their data with regard to the user account will be deleted, subject to a legal retention requirement. It is the responsibility of the users to back up their data if the termination is successful before the end of the contract. We are entitled to irretrievably delete all user data stored during the contract period.

As part of the use of our registration and its functions and the use of the user account, the IP address and the time of the respective user action will be saved. The storage takes place on the basis of our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with article 6 (1) lit. c GDPR. The IP addresses will be anonymized or deleted after 7 days at the latest.

 

Contact:

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user is processed in accordance with article 6 (1) lit. b) GDPR. The information provided by users can be stored in a customer relationship management system (“CRM system”) or a comparable request organization.

We delete the requests if they are no longer necessary. We check the necessity every two years; The statutory archiving obligations also apply.

 

Newsletter:

With the following information we inform you about the content of our newsletter as well as the registration, shipping and statistical evaluation procedure as well as your right to object. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (referred to as „newsletter”) only with the consent of the recipient or a legal permission. Insofar as the content of a newsletter is specifically described, it is decisive for the consent of the user. Our newsletters also contain information about our services and us.

Double opt-in and logging: The registration for our newsletter takes place in a so-called double opt-in procedure. I.e. After registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s email address. The registrations for the newsletter are logged in order to be able to demonstrate the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name in order to address it personally in the newsletter.

The newsletter is sent and the success measurement associated with it is based on the consent of the recipient in accordance with article 6 (1) lit. a, article 7 GDPR in conjunction with § 7(2) No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with article 6 (1) according to f. GDPR in conjunction Section 7 (3) UWG.

The logging of the registration process is based on our legitimate interests in accordance with article 6 (1) lit. f GDPR. Our interest is focused on the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and also allows us to prove consent.

Cancellation / Revocation – You can cancel the receipt of our newsletter at any time, i.e. withdraw your consent. You will find a link to cancel the newsletter at the end of each newsletter. Based on our legitimate interests, we can save the e-mail addresses that have been removed for up to three years before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that the previous consent is confirmed.

 

Newsletter – shipping service provider:

The newsletter is sent by e3 Software, LLC / 465 Fairchild Drive, Suite 229 / Mountain View, CA 94043 / USA. You can view the data protection regulations of the shipping service provider here: https://directmailmac.com/privacy. The shipping service provider is based on our legitimate interests article 6 (1) lit. f GDPR and an order processing contract in accordance with article 28 (3) sentence 1 GDPR.

The shipping service provider can process the recipient’s data in pseudonymous form, i.e. use without assignment to a user, to optimize or improve their own services, e.g. use for technical optimization of the dispatch and presentation of the newsletter or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or to pass the data on to third parties.

 

Newsletter – measuring success:

The newsletters contain a so-called „web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, are initially collected.

This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or the access times. The statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

 

Hosting and emailing:

The hosting services used by us serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer.

We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer based on our legitimate interests in the efficient and secure provision of this online offer in accordance with article 6 (1) lit. f GDPR in conjunction article 28 GDPR (conclusion of an order processing contract).

 

Collection of access data and log files:

We, or our hosting provider, based on our legitimate interests within the meaning of article 6 (1) lit. f. GDPR process data about every access to the server on which this service is located (so-called server log files). The access data include the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider .

For security reasons (e.g. to investigate misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data which equiree to be stored for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

 

Google Analytics:

We use Google Analytics, a web analytics service provided by Google LLC („Google”), based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 (1) (f) GDPR). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the internet. Pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address is only transferred to a Google server in the USA and abbreviated there in exceptional cases.

The IP address transmitted by the user’s browser is not merged with other Google data. The users can prevent the storage of cookies by setting their browser software accordingly; Users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The personal data of the users will be deleted or anonymized after 14 months.

 

Google AdWords and Conversion Measurement:

We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 (1) (f) GDPR) , USA, („Google”).

Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing process Google „AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offer in a more targeted manner in order to only present users with ads that potentially correspond to their interests. If a user e.g. Displaying advertisements for products in which he was interested in other online offers is referred to as „remarketing”. For these purposes, when our and other websites on which the Google advertising network is active, Google directly executes a code from Google and so-called (re)marketing tags (invisible graphics or code, also as ” Web Beacons ”) in the website. With their help, an individual cookie, i.e. a small file is saved (comparable technologies can be used instead of cookies). This file notes which websites the user has visited, what content he is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer.

We also receive an individual „conversion cookie”. The information obtained with the help of cookies is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information that can be used to personally identify users.

The data of the users are processed pseudonymously within the Google advertising network. I.e. Google does not store and process the user’s name or email address, but processes the relevant cookie-related data within pseudonymous user profiles. I.e. From Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about the user is transmitted to Google and stored on Google’s servers in the USA.

Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

 

Integration of services and content from third parties:

We use content or service offers from third-party providers within our online offer based on our legitimate interests, (ie interest in analysis, optimization and economic operation of our online offer within the meaning of Article 6 (1) lit. ) such as videos or fonts (hereinafter referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required to display this content. We strive to only use content, provided by respective providers who only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as „web beacons”) for statistical or marketing purposes. The „pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.

 

Google Maps:

We integrate the maps of the “Google Maps” service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data can include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually carried out as part of the settings of their mobile devices). The data can be processed in the USA. Data protection declaration: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

 

OpenStreetMap:

We integrate the maps of the “OpenStreetMap” service (https://www.openstreetmap.de), which are offered by the OpenStreetMap Foundation (OSMF) on the basis of the Open Data Commons Open Database license (ODbL). Privacy Policy: https://wiki.openstreetmap.org/wiki/Privacy_Policy.

The data of the users are used by OpenStreetMap exclusively for the purpose of displaying the map functions and temporarily storing the selected settings. This data can include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually carried out as part of the settings of their mobile devices).

The data can be processed in the USA. Further information can be found in the data protection declaration of OpenStreetMap: https://wiki.openstreetmap.org/wiki/Privacy_Policy.