Privacy Policy

Learn more about how PeoplePath protects your personal data.

two business women with ipad

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for PeoplePath GmbH and our affiliates, PeoplePath, Inc., IntraWorlds Inc. (our U.S. subsidiaries), PeoplePath s.r.o. (our Czech Republic subsidiary), and PeoplePath Ltd. (our U.K. subsidiary), hereinafter collectively referred to as PeoplePath.

The use of the Internet pages of PeoplePath is possible without providing any personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we will obtain consent from the data subject.

1. Definitions

The data protection declaration of PeoplePath is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

A) Personal Data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

B) Data Subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

C) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

D) Restriction of Processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

E) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

F) Pseudonymisation

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

G) Controller or Controller Responsible For The Processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

H) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

I) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

J) Third Party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

K) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name And Address of The Controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

PeoplePath GmbH
Friedenheimer Brücke 20
80639 München
Germany

Phone: +49 89 2000 412-00
Email: info@peoplepath.com
Website: www.peoplepath.com

3. Name And Address of The Data Protection Officer

The Data Protection Officer of the controller is:

René Rautenberg

ER Secure GmbH
In der Knackenau 4
82031 Grünwald
Germany

Phone: +49 89 2000 412-00
Email: datasec@peoplepath.com
Website: www.er-secure.de

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

4. Cookies

The Internet pages of PeoplePath use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, PeoplePath can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

5. Collection of General Data And Information

The website of PeoplePath collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, PeoplePath does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, PeoplePath analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

6. Registration on Our Website

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

7. Subscription to Our Newsletters

On the website of PeoplePath, users are given the opportunity to subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

PeoplePath informs its customers and business partners regularly by means of a newsletter about enterprise offers. The newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to communicate this to the controller in a different way.

8. Newsletter Tracking

The newsletter of PeoplePath contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, PeoplePath may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. PeoplePath automatically regards a withdrawal from the receipt of the newsletter as a revocation.

9. Contact Possibility via The Website

The website of PeoplePath contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

10. General Contact With The Company or Its Employees by Affected Data Subjects

PeoplePath stores personal data voluntary transmitted to PeoplePath by data subjects (e.g. via e-mail, postal mail, fax or phone) pro-actively or by replying to communication from PeoplePath’ employees. Such personal data is stored for the purpose of processing and contacting the data subject.

11. Routine Erasure And Blocking of Personal Data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

12. Rights of The Data Subject

A) Right of Confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

B) Right of Access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

C) Right of Rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

D) Right to Erasure (Right to be Forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by PeoplePath, he or she may, at any time, contact any employee of the controller. An employee of PeoplePath shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of PeoplePath will arrange the necessary measures in individual cases.

E) Right of Restriction of Processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by PeoplePath, he or she may at any time contact any employee of the controller. The employee of PeoplePath will arrange the restriction of the processing.

F) Right to Data Portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of PeoplePath.

G) Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

PeoplePath shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If PeoplePath processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to PeoplePath to the processing for direct marketing purposes, PeoplePath will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by PeoplePath for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of PeoplePath. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

H) Automated Individual Decision-Making, Including Profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, PeoplePath shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of PeoplePath.

I) Right to Withdraw Data Protection Consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of PeoplePath.

13. Requirements Under The CCPA

Data subjects shall have the right to opt-out of the sale of their personal information, and the CCPA prohibits PeoplePath from discriminating against consumers that exercise their opt-out rights. PeoplePath cannot ask consumers to sign contracts that limit their data privacy rights under the CCPA. PeoplePath stores personal data voluntarily transmitted to PeoplePath by data subjects and does not sell such personal data to third parties.

14. Data Protection For Applications And The Application Procedures

The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased six months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

15. Data Protection Provisions About The Application And Use of Facebook

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

16. Data Protection Provisions About The Application And Use of Google Analytics (With Anonymization Function)

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Cloud EMEA Ltd., 70 Sir John Rogerson's Quay, Dublin 2, Ireland, a subsidiary of: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Google acts as a processor for PeoplePath and processes data as directed by PeoplePath. Appropriate contractual agreements have been concluded to meet the legal requirements.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

17. Data Protection Provisions About The Application And Use of HubSpot (With Anonymization Function)

The controller has integrated components from HubSpot, Inc. (hereinafter “HubSpot”) on this website. HubSpot matches relevant website content to data from prospects and customers to enable Internet site operators to more effectively target prospects and customers. The purpose of HubSpot is to increase the conversion rate of prospective customers into customers and thus to increase the turnover of a website operator.

The operating company of HubSpot for EMEA is HubSpot Ltd., Two Dockland Central Guild Street, Dublin 1, Ireland.

HubSpot places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, HubSpot is enabled to analyze the use of controller website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a HubSpot component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the HubSpot component for the purpose of performing online analytics to HubSpot. During the course of this technical procedure, the enterprise HubSpot gains knowledge of personal information, such as the IP address of the data subject, which serves HubSpot, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

HubSpot uses the specific types of first and third party cookies served through controller ́s website. For a list of the cookies used by HubSpot, see following link: https://knowledge.hubspot.com/account/hubspot-cookie-security-and-privacy.

The cookies are used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to HubSpot in (a) the United States of America for visitors located outside of the European Economic Area or (b) to Ireland for visitors located within the European Economic Area. HubSpot may share data with trusted partners to help perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, where they are required to maintain the confidentiality of your information.

HubSpot partners with trusted third parties to provide co-marketing content that may be relevant to you. When data subject engages with these co-marketing partners, HubSpot will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to HubSpot’s privacy and data protection policies. For more information on HubSpot's co-marketing program, see following link: https://www.hubspot.com/co-marketing-request-form.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent HubSpot from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by HubSpot may be deleted at any time via a web browser or other software programs.

In addition, the data subject may object to the collection of data that are generated by HubSpot, which is related to the use of this website, as well as the processing of this data by HubSpot and the chance to preclude any such. For this purpose, the data subject can find more information about how to opt out from collecting data in the following link: https://legal.hubspot.com/cookie-policy in the section “How can I control cookies?”

HubSpot acts as a processor for PeoplePath and processes data as directed by PeoplePath. Appropriate contractual agreements have been concluded to meet the legal requirements.

Further information and the applicable data protection provisions of HubSpot may be retrieved under: https://legal.hubspot.com/privacy-policy.

18. Data Protection Provisions About The Application And Use of Google Ads

On this website, the controller has integrated Google Ads. Google Ads is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google Ads allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google Ads is Google Cloud EMEA Ltd., 70 Sir John Rogerson's Quay, Dublin 2, Ireland, a subsidiary of: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.The purpose of Google Ads is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a data subject reaches our website via a Google Ads, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g. the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an Ads on our website generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through Ads to ascertain, the success or failure of each Ads is to optimize our Ads in the future. Neither our company nor other Google Ads advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google Ads may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the URL https://www.google.de/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

19. Data Protection Provisions About The Application And Use of Instagram

On this website, the controller has integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as disseminate such data in other social networks.

The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. During the course of this technical procedure, Instagram becomes aware of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.

Instagram receives information via the Instagram component that the data subject has visited our website provided that the data subject is logged in at Instagram at the time of the call to our website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our website is made.

Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

20. Data Protection Provisions About The Application And Use of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy.

21. Data Protection Provisions About The Application And Use of Twitter

On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages, which are limited to 280 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

22. Data Protection Provisions About The Application And Use of XING

On this website, the controller has integrated components of XING. XING is an Internet-based social network that enables users to connect with existing business contacts and to create new business contacts. The individual users can create a personal profile of themselves at XING. Companies may, e.g. create company profiles or publish jobs on XING.

The operating company of XING is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a XING component (XING plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding XING component of XING. Further information about the XING plug-in the may be accessed under https://dev.xing.com/plugins. During the course of this technical procedure, XING gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on XING, XING detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the XING component and associated with the respective XING account of the data subject. If the data subject clicks on the XING button integrated on our Internet site, e.g. the “Share”-button, then XING assigns this information to the personal XING user account of the data subject and stores the personal data.

XING receives information via the XING component that the data subject has visited our website, provided that the data subject is logged in at XING at the time of the call to our website. This occurs regardless of whether the person clicks on the XING component or not. If such a transmission of information to XING is not desirable for the data subject, then he or she can prevent this by logging off from their XING account before a call-up to our website is made.

The data protection provisions published by XING, which is available under https://www.xing.com/privacy, provide information on the collection, processing and use of personal data by XING. In addition, XING has published privacy notices for the XING share button under https://www.xing.com/app/share?op=data_protection.

23. Data Protection Provisions About The Application And Use of YouTube

On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

24. Data Protection Provisions About The Application And Use of Google Maps

The controller has integrated components from Google Maps on this website. Google Maps is an online mapping service that allows users to view the Earth’s surface as a road map, aerial or satellite image. Google Maps also shows e.g. the locations of institutions, companies and attractions and allows a route planning.

The operating company of Google Maps is Google Cloud EMEA Ltd., 70 Sir John Rogerson's Quay, Dublin 2, Ireland, a subsidiary of: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.Each visit to one of the pages of this website, which is operated by the controller, and which embeds a Google Maps component (Google Maps map section), will automatically download a visualization of the respective map from Google Maps servers. More information about Google Maps can be found at https://www.google.com/maps/about/. As part of this technical process, Google will be aware of the specific page of our website you visited.

If the data subject is logged in at the same time to Google, Google recognizes with each call-up to our website by the data subject and for the entire duration of his or her stay on our Internet site, which specific sub-pages of our Internet page were visited by the data subject. This information is collected through Google and matched with the respective Google account associated with the data subject.

Through Google Maps, Google receives information that the data subject visited our website, if the data subject at the time of the call-up to our website is logged in to Google. This occurs regardless of whether the data subject loads or doesn’t load a Google Map. If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of his Google account before calling up our website.

Further information and the applicable data protection provisions of Google may be retrieved under https://policies.google.com/privacy.

25. Data Protection Provisions About The Application And Use of Salesforce

The controller uses a CRM system from Salesforce.com for customer care, sales & marketing and online offerings. With a CRM system, relationships with current, former and potential customers as well as generally all interested parties of a company are maintained and deepened.

The operating company of Salesforce.com is Salesforce.com Germany GmbH, Erika-Mann-Str. 63, 80636 Munich, Germany. US Salesforce.com Inc.’s headquarter address is: The Landmark @ One Market Street, Suite 300, San Francisco, CA 94105, USA.

We use Salesforce.com to connect with our customers and to inform prospects and potential customers about our products and services. We also use Salesforce for customer support, contract management, and billing. Our data in Salesforce.com is stored in the United States of America.

Salesforce acts as a processor for PeoplePath and processes data as directed by PeoplePath. Appropriate contractual agreements have been concluded to meet the legal requirements.

Further information and the applicable data protection provisions of DoubleClick may be retrieved under https://www.salesforce.com/company/privacy/.

26. Data Protection Provisions About The Application And Use of Adobe Fonts

The controller uses so-called web fonts provided by Adobe for displaying fonts. When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

To do this, the browser you use must connect to Adobe servers. As a result, Adobe learns that our website has been accessed via your IP address and it does not store it. The use of Adobe Fonts is in the interest of a consistent and attractive presentation of our online services. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

If your browser does not support web fonts, a default font will be used by your computer.

More information about Adobe Fonts can be found at https://www.adobe.com/privacy/policies/adobe-fonts.html and in Adobe General Terms of Use: https://www.adobe.com/legal/terms.html.

27. Data Protection Provisions About The Application And Use of Zoom

The person responsible for processing uses Zoom for online meetings after prior consultation with you. Zoom is a provider of web conferences and webinars. During online meetings, participants can speak to each other using their computers or by dialing in separately by phone. The moderator's screen can be shared for participants on the computer, or the screen of other participants after prior approval. Online meeting participants can also chat and share files. Activating a plug-in or installing a client may be required to participate in online meetings via the computer.

Zoom is operated by Zoom Video Communications Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA.

The moderator can activate a recording function when holding online meetings. By registering for Zoom's services, you expressly confirm that Zoom, if instructed by the moderator of the meeting, can make recordings for Zoom Meetings and webinars and can make these recordings available to moderators and participants at the moderator's instructions. A visual notification is sent to participants who join a meeting or webinar via the Zoom web-based platform, and an audio notification is sent to participants who only dial in by phone. A moderator can also send an audio notification to participants who have logged into the web platform. If you do not want to be recorded, you can choose to leave the meeting or webinar.

Zoom works for PeoplePath as a processor and processes data according to PeoplePath ' instructions. Corresponding contractual agreements have been concluded in order to meet the legal requirements.

Further information on the terms of use and the data protection guidelines can be found at https://zoom.us/de-de/legal.html.

28. Data Protection Provisions About The Application And Use of Microsoft 365 Services

The controller uses Microsoft 365 from Microsoft Corporation for communication and collaboration internally and with external stakeholders such as customers, prospects, partners, applicants, government authorities, service providers and other interested parties.

The operating company of Microsoft 365 is Microsoft Corporation Inc., One Microsoft Way Redmond, 98052, Washington. Microsoft Central and Eastern Europe Headquarters address is: Konrad-Zuse-Str.1, 85716 Unterschleißheim, Germany.

We use Microsoft 365 to connect with our customers and to inform prospects and potential customers about our products and services. We also use Microsoft 365 services for customer support, contract management, and billing. Furthermore PeoplePath uses Microsoft  365 to communicate via e-mail with any third party (Exchange), to work on and share documents (OneDrive/SharePoint), to ask stakeholders to particiate in polls (Forms) and to meet online (Teams). Our data in Microsoft 365 is stored in European Union. For further information please see: https://docs.microsoft.com/en-us/microsoft-365/enterprise/o365-data-locations?view=o365-worldwide

The person responsible for processing uses Microsoft Teams for online meetings after prior consultation with you. Microsoft Teams is a provider of web conferences and webinars. During online meetings, participants can speak to each other using their computers or by dialing in separately by phone. The moderator's screen can be shared for participants on the computer, or the screen of other participants after prior approval. Online meeting participants can also chat and share files. Activating a plug-in or installing a client may be required to participate in online meetings via the computer.

The moderator can activate a recording function when holding online meetings. By registering for Microsoft Teams’ services, you expressly confirm that Microsoft Teams, if instructed by the moderator of the meeting, can make recordings for Microsoft Teams Meetings and webinars and can make these recordings available to moderators and participants at the moderator's instructions. A visual notification is sent to participants who join a meeting or webinar via the Microsoft Teams web-based platform, and an audio notification is sent to participants who only dial in by phone. A moderator can also send an audio notification to participants who have logged into the web platform. If you do not want to be recorded, you can choose to leave the meeting or webinar.

Microsoft acts as a processor for PeoplePath and processes data as directed by PeoplePath. Appropriate contractual agreements have been concluded to meet the legal requirements.

Further information and the applicable data protection provisions may be retrieved under https://privacy.microsoft.com/en-us/privacystatement.

29. Information About Data Processing in Regards to The Facebook Page

For its Facebook page, PeoplePath uses the technical platform and services of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbor, Dublin 2, Ireland.

We would like to point out that you use this Facebook page and its functions at your own risk. This applies in particular to the use of the interactive functions (e.g. commenting, sharing, rating). Alternatively, you can access information about our company on our website at https://peoplepath.com.

When you visit our Facebook page, Facebook records your IP address and other information that is available on your PC in the form of cookies. This information is used to provide us, as the operator of the Facebook page, with statistical information about the use of the Facebook page. Facebook provides more information on this under the following link: http://de-de.facebook.com/help/pages/insights

The data collected about you in this context is used by Facebook Ltd. processed and possibly transferred to countries outside the European Union. What information Facebook receives and how it is used is described in general terms by Facebook in its data usage guidelines. There you will also find information about contact options for Facebook and the setting options for advertisements. The data usage guidelines are available at the following link: http://de-de.facebook.com/about/privacy. You can find the complete data guidelines of Facebook here: https://de-de.facebook.com/full_data_use_policy.

How Facebook uses the data from visiting Facebook pages for its own purposes, to what extent activities on the Facebook page are assigned to individual users, how long Facebook stores this data and whether data from a visit to the Facebook page is passed on to third parties, is not clarified conclusively by Facebook and is not known to us.

When you access a Facebook page, the IP address assigned to your device is transmitted to Facebook. According to information from Facebook, this IP address is anonymized (for "German" IP addresses). Facebook also stores information about its users' end devices (e.g. as part of the "registration notification" function); If necessary, Facebook is able to assign IP addresses to individual users.

If you are currently logged into Facebook as a user, there is a cookie on your device with your Facebook ID. This enables Facebook to understand that you have visited this page and how you have used it. This also applies to all other Facebook pages. Facebook buttons integrated into websites enable Facebook to record your visits to these website pages and to assign them to your Facebook profile. This data can be used to offer content or advertising tailored to you.

If you want to avoid this, you should log out of Facebook or deactivate the "stay logged in" function, delete the cookies on your device and close and restart your browser. In this way, Facebook information that can be used to directly identify you is deleted. This allows you to use our Facebook page without revealing your Facebook ID. When you access the interactive functions of the site (like, comment, share, news, etc.), a Facebook login screen appears. After you have logged in, you will again be recognized by Facebook as a specific user.

Information on how you can manage or delete existing information about you can be found on the following Facebook support pages: https://de-de.facebook.com/about/privacy. As the provider of the information service, we do not collect or process any data from your use of our Facebook page.

30. Legal Basis For The Processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

31. The Legitimate Interests Pursued by The Controller or by a Third Party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

32. Period For Which The Personal Data Will be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

33. Provision of Personal Data as Statutory or Contractual Requirement; Requirement Necessary to Enter Into a Contract; Obligation of The Data Subject to Provide The Personal Data; Possible Consequences of Failure to Provide Such Data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

34. Data transfers Outside of The EU/EEA, UK And Switzerland

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to PeoplePath.

The details of how we process your data, the data we collect and your rights under the GDPR are given in prior chapters of this privacy policy. In some situations, we enlist the services of third-party contractors or agents as detailed above. In the event we transfer your data to a third-party contractor, we remain liable to you if this contractor processes your information in a manner inconsistent with the GDPR Principles. PeoplePath, in its role as data controller and processor for its customers, has concluded data processing agreements with every third-party contractor processing personal data on our behalf. In case a third-party contractor transfers data outside of the EU/EEA, UK or Switzerland (for example to the United States) we have adopted the applicable Standard Contractual Clauses framework of the European Commission or the Information Commissioner’s Office (UK) as an appropriate safeguard for the transfer of personal data to non-EEA countries under Art. 46 GDPR.

As the controller, PeoplePath has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g., by telephone. In the U.S., please call +1 (206) 792-4245 and in Europe, please call +49 (89) 20 00 412-00.

35. Disclaimer For Website Content

PeoplePath takes no responsibility for the timeliness, accuracy, completeness, or quality of the information provided. Liability claims regarding any kinds of damage caused by the use or misuse of any information provided, including incomplete or incorrect information, will be rejected unless a willful default on behalf of PeoplePath can be established. All offers are without engagement or obligation. PeoplePath reserves the explicit right to amend, change, or delete specific information, pages, or the complete publication.

36. Disclaimer For External References

With regard to references and links to external websites, liabilities only arise when PeoplePath had knowledge of the contents contained therein and feasible for PeoplePath to prevent access to unlawful content. PeoplePath declares that all linked web pages contained no obviously illegal content at the time the external links were inserted. PeoplePath has no influence on the current or future design, content, or authorship of external web pages; the sole responsibility for illegal, incorrect, or incomplete content and damages caused by the use or misuse of provided information lies with the author of the linked web page(s). This declaration applies to all links or references on the PeoplePath website.

37. Copyright

PeoplePath intends to observe the copyrights of all graphics, sound files, video files, and texts used on its website. All registered trademarks mentioned on the PeoplePath website are the property of their respective owners. The mention of those registered trademarks without marking them as such does not justify the conclusion that they are not registered or protected by copyrights of other parties. The copyrights of objects created and published by PeoplePath remain property of their author. Duplication or the use of such graphics, sound files, video files, or texts in other digital or printed media without the explicit permission of the author will result in prosecution. All rights are reserved by PeoplePath.

38. Legal Ramifications

This disclaimer is to be regarded as part of the internet publication which referred to this page. If sections or individual terms of this disclaimer are not fully legal, the content and validity of the other parts or terms remain unaffected.

39. Usage of Icons

Icons and vector images have been sourced from Freepik (http://www.freepik.com) and Flaticon (http://www.flaticon.com) and are licensed under Creative Commons (http://creativecommons.org/licenses/by/3.0/).

This Privacy Policy has partly been generated by the Privacy Policy Generator of the German Association for Data Protection that was developed in cooperation with Privacy Lawyers from WILDE BEUGER SOLMECKE, Cologne.

Last modified: May 23, 2023

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