Privacy policy

Data protection is important to us and accordingly, we explain in this privacy policy how we collect and process which personal data (in short: "personal data,” i.e. data relating to an identified or identifiable person, such as name, address, nationality, email address, interests and hobbies, user behavior on websites). This privacy policy is based on the EU’s General Data Protection Regulation (GDPR).

1. responsible person, data protection officer and representative

(1) CloudLab Sales & Management GmbH is responsible for data protection.
(2) The contact details of the external data protection officer are as follows:
Attorney Ulf Haumann, LL.M.
Kaiserstr. 21-23
44135 Dortmund
datenschutz@ruhr-dsc.eu

Tel. +49 231 2281 9010

2. collection of personal data and purposes of processing

(1) We restrict the processing of personal data primarily to personal data which we receive in connection with our services and products from our customers, our cooperation partners or other persons involved or which we collect from users on our websites, apps or other applications.

(2) In particular, we collect the following personal data from you on a case-specific basis and depending on the purpose (see below):

• Salutation / Title
• First name, last name
• Gender
• Address
• Email address
• Phone number(s)
• Date of birth
• Nationality
• Hobbies / personal interests
• Tax identification number
• Bank details
• IP address
• Company affiliation

(3) In addition, where permitted and indicated, we obtain and process further data on a case-by-case basis from publicly accessible sources (e.g. land register, commercial register, media, internet, Worldcheck) or receive such data from other group companies, from authorities and institutions, from your personal environment (such as family, legal advisors) or from other third parties.

(4) We require this data in particular to fulfill the following purposes:

• to identify you as a customer, cooperation partner or service provider or as a user of our websites, online services and apps
• for correspondence with you
• to carry out our due diligence obligations
• to comply with other legal requirements
• for the conclusion and execution of service contracts
• for the conclusion and execution of purchase and sales contracts, e.g. for the purchase of products from suppliers or sales to interested parties
• for invoicing
• for the provision of further services from our company or, if necessary, in cooperation with third parties
• to provide you with the best possible and customized services and to further develop our range of services and products
• for communication with third parties (e.g. media)
• to assess and respond to applications
• to advertise and market our services and products (unless you have objected to the use of your data for this purpose)
• to assert legal claims or defend our position in general
• to ensure our operations in general (e.g. IT, websites, apps)
• for video surveillance as a security element for access management (incl. visitor lists or other access controls)
• to maintain further safety aspects

(5) We process your personal data only if we have a legal or contractual basis or the data processing is necessary for the performance of a task which is in the public interest or in the exercise of official authority. We only process data beyond this if we have consent from you and there is no revocation. Or if a legitimate interest on our part prevails (e.g. continuation of the delivery of newsletters to existing customers, provided there is no revocation here either). Consent can be revoked at any time.

3. Recipients of personal data and data transfer abroad

(1) We will only disclose your personal data to recipients or third parties within the scope of the purposes described above, to the extent permitted and indicated. This may include in particular:

• Group companies
• Service companies such as banks, asset management companies, insurance companies, IT providers, printing companies, etc.
• Our customers
• Suppliers, dealers, transport companies, subcontractors or other cooperation partners
• Authorities, state institutions, courts
• Associations, public interest entities
• Media, press offices

(2) Such data transfer is based either on a legal obligation (e.g. data transfer in the course of the automatic exchange of information), a contractual fulfillment (e.g. asset manager abroad), consent on your part, public interest or on the basis of a legitimate interest on our part, unless your interests or fundamental rights and freedoms with regard to the protection of personal data do not predominate.

(3) The recipients may be in Germany or abroad. In particular, we would like to point out that we may exchange personal data within our group companies or transfer personal data to countries in which service companies from which we obtain services are located (e.g. Microsoft, SAP, Google, etc.).
In the case of recipients outside our company in the EU/EEA area or in countries with recognized data protection adequacy (e.g. Switzerland), we ensure data protection by concluding so-called commissioned data processing agreements where necessary and appropriate.
If we transfer personal data to third countries without adequate legal data protection, we ensure an adequate level of protection in accordance with legal requirements, for example on the basis of EU standard contractual clauses or other instruments (e.g. Binding Corporate Rules, U.S. Privacy Shield).

4. Use of our website

In addition to the above, we inform you about the use of cookies, analytics/tracking or other technologies on our websites as follows:

(1) In the case of merely informational use of the website (i.e. if you do not log in to use the website, register or otherwise provide us with information), we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website, which may include the following personal data in particular:

• IP address
• Date and time of the request
• Time zone difference from Greenwich Mean Time (GMT)
• Content of the request (concrete page)
• Access status/HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• Browser used
• Operating system and its interface
• Language and version of the browser software

(2) Our website uses so-called cookies. These are small text files that are stored on your terminal device with the help of the browser. The cookies do not cause any harm.We only use them to make our offer more user-friendly. Some cookies remain stored on your end device until you delete them. They enable us to recognize your browser on your next visit.

If you do not wish this, you can set up your browser so that it informs you about the setting of cookies and you only allow this in individual cases. However, we would like to point out that in this case you may not be able to use all functions of our websites to their full extent.

5. Use of other web services

5.1 Google Analytics

We use Google Analytics on our websites. Google Analytics is a web analysis service provided by Google Inc. in the USA and uses cookies. Web analysis means the collection, compilation and evaluation of data about the behavior of data subjects to websites. A web analysis service collects, among other things, data about which website a data subject came from, which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is predominantly used to optimize a website and for cost-benefit analysis of internet advertising.

The purpose of Google Analytics is to analyze the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our websites and to provide other services related to the use of our website. Google may combine your behavior with other websites you visit. If you are a registered customer of Google, Google will recognize you accordingly. In that case, Google's privacy policy will apply to the further processing of your personal data. Personal information, for example the access time, the place from which an access originated and the frequency of visits to our website by the data subject, is stored by means of cookies. Each time a person visits our website, their personal data, including the IP address of the internet connection they are using, is transferred to Google in the USA. Google may pass on to third parties the personal data collected via this technical procedure.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by changing the corresponding settings of the internet browser they are using and thus permanently prevent cookies from being set. Such browser setting can also prevent Google from setting a cookie on your device (e.g. computer, notebook, tablet). In addition, a cookie already set by Google Analytics can be deleted at any time via Internet browser or other software programs.For more information, please contact Google directly at the following links:

• www.google.de/intl/de/policies/privacy/
• www.google.com/analytics/terms/de.html
• www.google.com/intl/de_de/analytics/

5.2 Google Adwords

The controller has integrated Google AdWords into this website. Google AdWords is an Internet advertising service that allows advertisers to place ads in Google's search engine results as well as in the Google advertising network. Google AdWords allows an advertiser to specify certain keywords in advance, by means of which an ad is displayed in Google's search engine results exclusively when the user retrieves a keyword-relevant search result using the search engine. In the Google advertising network, the ads are distributed on topic-relevant websites by means of an automatic algorithm and in conformity with the previously defined keywords. Google AdWords is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to advertise our website by displaying interest-relevant advertisements on the websites of third-party companies and in the search engine results of the Google search engine and to display third-party advertisements on our website.

If a data subject accesses our website via a Google ad, a so-called conversion cookie is stored by Google on the data subject's information technology system. Cookies have already been explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. The conversion cookie is used to track whether certain subpages, for example the shopping cart of an online store system, have been called up on our website, provided that the cookie has not yet expired. Through the conversion cookie, both we and Google can track whether a data subject who has accessed our website via an AdWords ad has generated a sale, i.e. has completed or cancelled a purchase of goods.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other advertising customers of Google AdWords receive information from Google by means of which the data subject could be identified.

Personal information, for example the internet pages visited by the data subject, is stored by means of the conversion cookie. Each time the data subject visits our website, personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the U.S. and stored there by Google. Google may pass the personal data collected via this technical procedure on to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by changing the corresponding settings of the internet browser they are using and thus permanently prevent cookies from being set. This would also prevent Google from setting a conversion cookie on the data subject’s information technology system. In addition, a cookie already set by Google AdWords can be deleted at any time via internet browser or other software programs.

Furthermore, the data subject has the option to object to interest-based advertising by Google. To do this, the data subject must call up the link www.google.de/settings/ads from any of the internet browsers they use and make the desired settings there.

Further information and the applicable Google privacy policy can be found here.

5.3 Newsletter

On the website of the CloudLab Sales & Management GmbH, users are given the opportunity to subscribe to our company newsletter. The personal data transmitted to the controller when the newsletter is ordered is specified in the input mask used for this purpose.
The CloudLab Sales & Management GmbH informs its customers and business partners at regular intervals by means of a newsletter about company offers. Our newsletter can only be received by the data subject, if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation email will be sent to the email address given by the data subject for newsletter dispatch using the double opt-in procedure. This confirmation email serves to verify whether the owner of the email address has authorized receipt of the newsletter.

When registering for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration, as assigned by the Internet service provider (ISP), as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the email address of a data subject at a later point in time and therefore serves as a legal safeguard.

The personal data collected in the context of registration for the newsletter will be used exclusively for sending our newsletter. It may also be used to inform subscribers by email, if necessary, of any changes relating to the newsletter, to the operation of the newsletter service or a related registration, or to technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. Subscriptions to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data that the data subject has given us for the newsletter mailing can be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on the website of the controller at any time or to notify the controller of this in another way.

5.4 Tracking services

The newsletters of CloudLab Sales & Management GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails that are sent in HTML format to enable log file recording and log file analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the CloudLab Sales & Management GmbH may see if and when an email was opened by a data subject, and which links contained in the email were called up by the data subject.

Personal data that is collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller in order to optimize the newsletter dispatch and to better adapt the content of future newsletters to the interests of the data subject. This personal data will not be disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After a revocation, this personal data will be deleted by the controller. The CloudLab Sales & Management GmbHautomatically regards unsubscribing from the newsletter as a revocation.

5.5 Other web services

For the use of other web services, such as social media (XING, LinkedIn, Facebook, Slack, etc.), YouTube, Vimeo, etc., in addition to the General Data Protection Regulation, which is to be treated as having priority, their privacy policies also apply. These can be accessed on each of the provider’s websites.We make videos available on YouTube, which means that YouTube’s Community Guidelines also apply. These can be found in the same place as their privacy agreement.

6. Data protection in connection with applications and during the application process

We collect and process personal data from applicants for the purpose of handling the application process. The processing can take place on paper, electronically by email or by filling out an online form. If an employment contract is concluded with an applicant, the personal data received is processed for the purpose of handling the employment relationship in compliance with statutory provisions. Otherwise, the application documents will be deleted three months after rejection, provided that no legitimate interests on our part, for example in connection with a duty of proof in the sense of equal treatment, conflict with deletion.

7. Storage period

We generally retain your personal data only for as long as is necessary for the purposes for which it was collected in accordance with this privacy policy. However, we may be required by law to retain certain data for a longer period of time. In this case, we will ensure that your personal data is treated in accordance with this privacy policy for the entire period.

8. Your rights

(1) You have the right to request information from us at any time and free of charge about the personal data we have stored about you, as well as about its origin, recipients or categories of recipients to whom this personal data is disclosed and the purpose for which it is stored.

(2) You also have the right to demand that we correct, delete or restrict the processing of your personal data at any time. In addition, you have the right to data portability.

(3) You also have the right to object to the processing of your personal data by us at any time.

(4) If you have given us permission to use personal data, you can revoke this permission at any time without giving reasons.

(5) Furthermore, you have the right to complain directly to the German Office of the Federal Commissioner for Data Protection and Information Security in Bonn or Berlin.

(6) If you wish to exercise the above rights, please contact us at the address stated in paragraph 1.

9. Data security

We maintain current technical measures to ensure data security, in particular to protect your personal data from risks during data transmission and from third parties gaining access to it. In each case, these measures are adapted according to the current state of the art.

10. Changes

In the context of the technical further development of our range of services as well as the legal framework, we will also adapt our privacy policy on an ongoing basis. For this purpose, changes to the privacy policy will be published on our website. Therefore, please read the current version of this privacy policy regularly. Subject to applicable law, any changes to the privacy policy will take effect as soon as the updated privacy policy is published. If we have already collected data about you and/or are subject to a legal obligation to inform you, we will additionally inform you about material changes to our privacy policy and ask for your consent, should this be required by law.

As of: June 13, 2018

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