Data Protection

(1) Data Protection at a Glance
(2) Hosting
(3) General Information and Mandatory Information
(4) Data Collection on This Website
(5) Analytics Tools and Advertising
(6) Plugins and Tools
(7) Audio and Video Conferences
(8) Conference Tools Used
(9) Tools Used
(10) Marketing to Existing Customers
(11) Information Obligation

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. Detailed information on data protection can be found in our privacy policy listed below this text.

Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the Controller” in this privacy policy.

Your data is collected, on the one hand, when you provide it to us. This may, for example, be data that you enter into a contact form.

Other data is collected automatically by our IT systems, or after you have given your consent, when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time the page was accessed). This data is collected automatically as soon as you enter this website.

Some data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the data transmitted is also processed for contractual offers, orders or other order-related enquiries.

You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given consent to data processing, you may withdraw this consent at any time with effect for the future. Furthermore, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You may contact us at any time regarding this or any other questions concerning data protection.

When visiting this website, your browsing behaviour may be statistically evaluated. This is mainly done using so-called analytics programs.

Detailed information on these analytics programs can be found in the following privacy policy.

The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (hereinafter “Hetzner”).

For details, please refer to Hetzner’s privacy policy: https://www.hetzner.com/de/legal/privacy-policy/.

Hetzner is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in presenting our website as reliably as possible. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law which ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

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

When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

The controller responsible for data processing on this website is:

ISR Information Products AG
Hintern Brüdern 23
38100 Braunschweig
Telephone: +49 (0) 531 1208-0
Email: info@isr.de

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data (e.g. names, email addresses or similar).

Unless a more specific storage period is stated in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for erasure or withdraw your consent to data processing, your data will be erased unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, erasure will take place once these reasons no longer apply.

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, where special categories of data are processed pursuant to Art. 9(1) GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of Section 25(1) TDDDG. Consent may be withdrawn at any time. If your data is necessary for the performance 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, we process your data if this is necessary to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

We have appointed a data protection officer.

ISR Information Products AG
– Data Protection Coordinator – 
Am Mittelhafen 14
48155 Münster
Telephone: +49 (0) 251 9 24 34-0
Email: datenschutz@isr.de

As part of our business activities, we work with various external entities. In some cases, the transfer of personal data to these external entities is also necessary. We only disclose personal data to external entities where this is necessary for the performance of a contract, where we are legally obliged to do so (e.g. disclosure of data to tax authorities), where we have a legitimate interest in disclosure pursuant to Art. 6(1)(f) GDPR, or where another legal basis permits the disclosure of data. When using processors, we only disclose our customers’ personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Many data processing operations are only possible with your express consent. You may withdraw consent that has already been given at any time. The lawfulness of data processing carried out before withdrawal remains unaffected by the withdrawal.

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. PLEASE REFER TO THIS PRIVACY POLICY FOR THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING,

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

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or the place of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

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

Within the scope of applicable statutory provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients, and the purpose of data processing, as well as, where applicable, a right to rectification or erasure of this data. You may contact us at any time regarding this or any other questions concerning personal data.

You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

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

• If the processing of your personal data was/is unlawful, you may request restriction of data processing instead of erasure.

• If we no longer need your personal data, but you require it for the exercise, defence or establishment of legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.

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

If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the website operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the browser’s address bar changing from

“http://” to “https://” and by the lock symbol in your browser bar.

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

We hereby object to the use of contact details published as part of the legal notice obligation for the sending of advertising and information material not expressly requested. The operators of these pages expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example through spam emails.

Our websites use so-called “cookies”. Cookies are small data packets and do not cause any damage to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services provided by third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions requested by you (e.g. for the shopping cart function) or to optimise the website (e.g. cookies for measuring web audiences) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent has been requested for the storage of cookies and comparable recognition technologies, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent may be withdrawn at any time.

You can configure your browser to notify you when cookies are set and to allow cookies only in individual cases, to exclude the acceptance of cookies in certain cases or in general, and to activate the automatic deletion of cookies when the browser is closed. If cookies are disabled, the functionality of this website may be limited.

If further cookies and services are used on this website, you can find this information in this privacy policy.

This website uses Usercentrics consent technology to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies and to document this in compliance with data protection law. The provider of this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, website: https://usercentrics.com/de/ (hereinafter “Usercentrics”).

When you visit our website, the following personal data are transmitted to Usercentrics:

• Your consent(s) or withdrawal of your consent(s)

• Your IP address

• Information about your browser

• Information about your device

• Time of your visit to the website

• Geolocation

Furthermore, Usercentrics stores a cookie in your browser in order to be able to assign the consents granted or their withdrawal to you. The data collected in this way are stored until you request that we delete them, delete the Usercentrics cookie yourself, or the purpose for data storage no longer applies. Mandatory statutory retention obligations remain unaffected.

Usercentrics is used to obtain the legally required consents for the use of certain technologies. The legal basis for this is Art. 6(1)(c) GDPR.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not disclose these data without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in effectively handling the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), where such consent has been requested; consent may be withdrawn at any time.

The data you enter in the contact form will remain with us until you request deletion, withdraw your consent to storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

If you contact us by email, telephone or fax, your enquiry, including all personal data arising from it (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not disclose these data without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in effectively handling the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), where such consent has been requested; consent may be withdrawn at any time.

The data you send to us through contact enquiries will remain with us until you request deletion, withdraw your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

We use Hubspot CRM on this website. The provider is Hubspot Inc. 25 Street, Cambridge, MA 02141 USA (hereinafter Hubspot CRM).

Hubspot CRM enables us, among other things, to manage existing and potential customers and customer contacts. With the help of Hubspot CRM, we are able to record, sort and analyse customer interactions via email, social media or telephone across different channels. The personal data collected in this way can be evaluated and used to communicate with potential customers or for marketing measures (e.g. newsletter mailings). Hubspot CRM also enables us to record and analyse the user behaviour of our contacts on our website.

Hubspot CRM is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in ensuring the most efficient customer management and customer communication possible. Where appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

For details, please refer to Hubspot's privacy policy: https://legal.hubspot.com/de/privacy-policy.

Data transfers to the USA are based on the EU Commission's standard contractual clauses. Details can be found here:

https://www.hubspot.de/data-privacy/privacy-shield .

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5812.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

This website uses the open-source web analytics service Matomo.

Matomo enables us to collect and analyse data on the use of our website by website visitors. This allows us, among other things, to find out when which page views were made and which region they come from. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

This analysis tool is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. Where appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

We use IP anonymisation when analysing data with Matomo. Your IP address is shortened before analysis so that it can no longer be clearly assigned to you.

We have configured Matomo so that Matomo does not store cookies in your browser.

We host Matomo exclusively on our own servers, so that all analytics data remains with us and is not disclosed.

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is intended to verify whether data entered on this website (e.g. in a contact form) is made by a human or by an automated program. To do so, reCAPTCHA analyses the behaviour of website visitors based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, length of time spent by the website visitor on the website, or mouse movements made by the user). The data collected during the analysis are forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitors are not notified that an analysis is taking place.

In this context, Google acts solely as a data processor within the meaning of Art. 28 GDPR and will not use the data collected in this way for its own purposes. The tool is used on the basis of a data processing agreement (DPA) with Google.

Data are stored and analysed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its web services against abusive automated spying and SPAM. Where appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

We use, among other things, online conference tools to communicate with our customers. The specific tools we use are listed below. If you communicate with us by video or audio conference via the internet, your personal data will be collected and processed by us and by the provider of the respective conference tool.

The conference tools collect all data that you provide/use to use the tools (email address and/or your telephone number). Furthermore, the conference tools process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other “context information” related to the communication process (metadata).

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

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

Please note that we do not have full control over the data processing operations of the tools used. Our options depend largely on the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the privacy policies of the respective tools we use, which are listed below this text.

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 within the meaning of Art. 6(1)(f) GDPR). Where consent has been requested, the relevant tools are used on the basis of this consent; consent may be withdrawn at any time with effect for the future.

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

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

We use the following conference tools:

We use Zoom. The provider of this service is Zoom Communications Inc., San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom's privacy policy: https://www.zoom.com/de/trust/privacy/privacy-statement/.

Data transfers to the USA are based on the EU Commission's standard contractual clauses. Details can be found here: https://www.zoom.com/de/trust/privacy/privacy-statement/.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5728.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

We use Microsoft Teams. The provider is 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/de-de/privacystatement.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/6474.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

We offer you the opportunity to apply to us (e.g. by email, post or via an online application form). Below, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

From a technical perspective, our online application portal is operated by our service provider

d.vinci HR-Systems GmbH
Nagelsweg 37-39
20097 Hamburg (hereinafter: d.vinci)

d.vinci provides only software and computing capacity and otherwise has no influence on the application process. This constitutes data processing pursuant to Art. 28 GDPR.

Our careers pages are operated through so-called widgets provided by d.vinci or through a portal created directly via d.vinci. These establish a direct technical connection to d.vinci as soon as you access these pages. For technical operation and maintenance purposes, data are automatically transmitted through your internet browser. The following data are stored by d.vinci:

• Date and time of access

• Browser type and version

• Operating system used

• URL of the previously visited website

• Amount of data sent

• IP address of access

These data are stored by d.vinci exclusively for technical reasons and are not assigned to a specific person at any time. The legal basis is Art. 6(1) sentence 1(f) GDPR.

d.vinci HR-Systems GmbH is contractually obligated to ensure the protection of your personal data through technical and organisational measures. Your data are stored in a secure operating environment that is not accessible to the public. Your data are encrypted during transmission using so-called Transport Layer Security (TLS). This means that communication between your computer and the data servers used takes place using a recognised encryption method.

If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is Section 26 BDSG under German law (initiation of an employment relationship), Art. 6(1)(b) GDPR (general contract initiation) and – if you have given your consent – Art. 6(1)(a) GDPR. Consent may be withdrawn at any time. Your personal data will only be disclosed within our company to persons involved in processing your application.

If the application is successful, the data you submitted will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6(1)(b) GDPR for the purpose of carrying out the employment relationship.

If we are unable to offer you a position, if you decline 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 after the end of the application process (rejection or withdrawal of the application).

The data will then be deleted and physical application documents destroyed. Retention serves, in particular, evidentiary purposes in the event of a legal dispute. If it is apparent that the data will be required after the 6-month period has expired (e.g. due to a threatened or pending legal dispute), deletion will only take place once the purpose for further retention no longer applies.

Longer retention may also take place if you have given corresponding consent (Art. 6(1)(a) GDPR) or if statutory retention obligations prevent deletion.

If we do not offer you a position, it may be possible to include you in our applicant pool. If you are included, all documents and information from your application will be transferred to the applicant pool in order to contact you in the event of suitable vacancies.

Inclusion in the applicant pool takes place solely on the basis of your express consent (Art. 6(1)(a) GDPR). Giving consent is voluntary and is not related to the ongoing application process. The data subject may withdraw their consent at any time. In this case, the data will be irrevocably deleted from the applicant pool, unless there are statutory grounds for retention.

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

Jobspreader Analytics enables us to analyse our job advertisements, including the application form, and optimise them in terms of delivery, content and the online application process. Jobspreader Analytics is software that can be used to carry out simple usage analyses tailored precisely to our Jobspreader job campaigns.

Jobspreader Analytics records how many users (not: which users) have reached our careers website from a job advertisement distributed via Jobspreader. It also records how many of these users (not: which users) have started an application process on the careers website and how many users (not: which users) have completed this process, i.e. submitted an application.

Using this information, we can determine how job campaigns distributed via Jobspreader affect potential applicants through their content in the environments in which they are placed, and to what extent the careers website and/or mobile careers application motivates applicants acquired via Jobspreader to begin the application process on the website. Finally, we can also determine the drop-off rate within the application process on the website or application. All insights gained with Jobspreader Analytics help us to assess and, where appropriate, optimise the Jobspreader campaign quantitatively and qualitatively with regard to environments, content and processes.

As part of Jobspreader Analytics, four cookies are set that process the following information:

Js_clid – This cookie sets a randomly assigned Jobspreader click ID. This ID can be used to identify that a user – not: which user – has reached the careers page via an advertisement placed through Jobspreader. This means that the Jobspreader click ID, the relevant job URL (from the job advertisement) and the current timestamp (to ensure uniqueness) are recorded. This cookie is stored for 30 days and deleted after this period.

js_startqueue - This cookie is used to track a user's – not: which user's - click on the “start application” button. The Jobspreader click ID, the current job URL and the current timestamp (to ensure uniqueness) are processed here. The cookie is then deleted.

js_endqueue - This cookie is used to track a user's – not: which user's – click indicating the end of the application process (“End Application”). The Jobspreader click ID, the current job URL and the current timestamp (to ensure uniqueness) are processed here. The cookie is then deleted.

js_end - This cookie is used to end this analysis upon the completion of the application process detected with the js_endqueue cookie. Before this, the click ID, the current job URL and the current timestamp (to ensure uniqueness) are processed again, and the information that the application and this analysis have been completed is recorded. All cookies are then deleted.

In addition, we record how often the page on which Jobspreader Analytics is integrated is accessed (we can determine this by whether and therefore how often the Jobspreader Analytics script is loaded) and how often a cookie is loaded in comparison. This allows us to determine in what percentage of cases cookies are inherently blocked by the user through ad or script blockers.

The user's IP address is also processed briefly, as this is technically essential. However, the IP address is then deleted immediately and not processed further.

a. No processing of personal data within the meaning of the GDPR

No personal data is processed with Jobspreader Analytics.

Although the IP address is mentioned as an example of personal data in Recital 30 GDPR, this does not mean that it must always be classified as personal data within the meaning of Art. 4 No. 1.

According to the legal definition in Art. 4 No. 1 GDPR, data is personal if it contains information relating to an identified or identifiable person. To answer this question, it is in turn necessary to consider the knowledge that the controller must have in order to be able to assign information to a natural person.

In principle, IP addresses can be traced and may therefore constitute data relating to persons. In its so-called Breyer ruling of 2016, the CJEU held that (dynamic) IP addresses only constitute personal data if the website operator has means at its disposal that can reasonably be used to identify a person on the basis of their IP address. Legally enforceable means could also be considered for such identification by the website operator.

We do not have such means at our disposal. Consequently, no data relating to persons in the form of the IP address is processed in these specific cases.

b. Processing of information pursuant to Section 25(2) No. 2 TDDDG

Cookies that “store information” which is “strictly necessary” may be stored without a user's consent.

Simple cookies that assign a non-personal session ID in order to carry out a simple digital usage analysis can be considered necessary within the meaning of Section 25(2) No. 2 TDDDG.

Such simple digital usage analyses provide us, as the company using them, with an overview of visitor flows on our own websites and applications. In this case, this makes it apparent which job advertisements attract interest in which environments, which job advertisements also actually result in applications and to what extent, and whether the application form guides users well through the process or whether there are drop-offs attributable to technical or ergonomic difficulties.

To this extent, the use of simple cookies for simple usage analyses, as in this case, is necessary within the meaning of Section 25(2) No. 2 TDDDG.

If we have received your email address in connection with the sale of goods or services and you have not objected to this, we process your email address in order to conduct email marketing for our own similar goods or services and, where applicable, additional personal data in order to address you personally. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is direct advertising.

We use external services for email marketing. Further information about the services used, the scope of data processing, and the technologies and procedures used when using the respective services, as well as whether profiling takes place when using the respective services and, where applicable, information about the logic involved and the significance and intended effects of such processing for you, can be found in the further information on the services we use at the end of this section and under the links provided there.

You have the right to object at any time to the processing of your personal data for email marketing purposes, without incurring any costs other than the transmission costs according to the basic rates. We will then no longer process your personal data for email marketing purposes. To object to the processing of your personal data for email marketing purposes, you can use the link provided in the emails or contact us using the contact details given above.

If you have objected to the processing of your personal data for email marketing purposes, we reserve the right to process your personal data in a so-called blacklist/blocking list in order to ensure in the future that no further email marketing takes place in connection with this personal data. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is avoiding unwanted email marketing.

We process your personal data as part of tracking and performance measurements in order to measure the reach of our email marketing, tailor it to needs and interests, and thus optimise our email marketing. This may also involve profiling (for advertising purposes, personalised information, etc.). Profiling may also take place across services and devices. If we have asked for your consent and you have given it, the legal basis for processing is Art. 6(1)(a) GDPR. If we have not asked for your consent, the legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is optimising our email marketing. Unfortunately, it is not possible to separately withdraw your consent or object in relation to tracking or performance measurements. You must use the above options for withdrawing your consent or objecting to the processing of your personal data for email marketing purposes as a whole.

If we have asked for your consent and you have given it, we process your email address in order to conduct email marketing and, where applicable, additional personal data in order to address you personally. The legal basis for processing is Art. 6(1)(a) GDPR. The content of the email marketing is described specifically when your consent is obtained. Otherwise, email marketing contains information about us and our goods and services.

We use the so-called double opt-in procedure to prevent potential misuse of your personal data. To this end, after collecting your email address, we send an email to the email address you provided, asking you to confirm that you actually wish to receive email marketing. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is the legally compliant implementation of email marketing.

We log the time at which you gave your consent and the time of your confirmation, as well as your IP address and the content of your declaration of consent, in order to be able to demonstrate that your consent was obtained in a legally compliant manner. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is the legally compliant implementation of email marketing.

We use external services for email marketing. Further information about the services used, the scope of data processing, and the technologies and procedures used when using the respective services, as well as whether profiling takes place when using the respective services and, where applicable, information about the logic involved and the significance and intended effects of such processing for you, can be found in the further information on the services we use at the end of this section and under the links provided there.

You may withdraw your consent at any time. Withdrawal of your consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. To withdraw your consent, you can use the link provided in the emails or contact us using the contact details given above.

If you have withdrawn your consent, we reserve the right to process your personal data in a so-called blacklist/blocking list in order to ensure in the future that no further email marketing takes place in connection with this personal data. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is avoiding unwanted email marketing.

We process your personal data as part of tracking and performance measurements in order to measure the reach of our email marketing, tailor it to needs and interests, and thus optimise our email marketing. This may also involve profiling (for advertising purposes, personalised information, etc.). Profiling may also take place across services and devices. If we have asked for your consent and you have given it, the legal basis for processing is Art. 6(1)(a) GDPR. If we have not asked for your consent, the legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is optimising our email marketing. Unfortunately, it is not possible to separately withdraw your consent or object in relation to tracking or performance measurements. You must use the above options for withdrawing your consent or objecting to the processing of your personal data for email marketing purposes as a whole.

We use HubSpot for email advertising to existing customers and newsletters.

If we have received your personal data in connection with the sale of goods or services and you have not objected to this, we process your personal data in order to conduct postal marketing. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is direct advertising.

We use external services (printers, mailing houses, etc.) for postal marketing.

You have the right to object at any time to the processing of your personal data for postal marketing purposes. We will then no longer process your personal data for postal marketing purposes. To object to the processing of your personal data for postal marketing purposes, you can contact us using the contact details given above.

If you have objected to the processing of your personal data for postal marketing purposes, we reserve the right to process your personal data in a so-called blacklist/blocking list in order to ensure in the future that no further postal marketing takes place in connection with this personal data. The legal basis for processing is Art. 6(1)(f) GDPR. Our legitimate interest is avoiding unwanted postal marketing.

The following privacy notices are provided in connection with the processing of your personal data for registration for and implementation of our events and webinars.

You can find further information here: https://isr.de/informationspflicht-gemaess-art-13-14-dsgvo/