Privacy Policy
Privacy Policy FalkenSteg
As of December 12, 2023.
- SUBJECT MATTER AND SCOPE OF APPLICATION
This Privacy Policy provides information about which personal data is collected during individual processing operations and how and for what purposes this personal data is processed.
This Privacy Policy provides information about data processing when visiting the website, but also in other contexts, e.g. about the processing of data from customers, applicants and when participating in video conferences.
Your personal data will always be processed in accordance with the statutory data protection regulations and this Privacy Policy.
- CONTROLLER AND DATA PROTECTION OFFICER
Controller is Falkensteg Holding GmbH & Co. KG, Peter-Müller-Straße 10, 40468 Düsseldorf, Germany, Phone: +49 (0)211 5476630, E-Mail: falkensteg@falkensteg.com (hereinafter „FalkenSteg“).
FalkenSteg is a group of companies with various group companies. In the case of individual processing operations, the respective group company is the controller if the respective processing operation is not carried out centrally for the entire group of companies by one controller, but if the data processing is carried out locally for the respective group company. This is the case, for example, with job applications.
The data protection officer of the respective controller can be contacted at schmoll@lucid-compliance.com.
- VISITING THE WEBSITE
3.1. Hosting and Log Files
The website is hosted by a service provider on the basis of a data processing agreement in the EU.
Each time the website is accessed, the system automatically collects data and information from the computer system of the accessing end device. The following data is recorded or logged:
- IP address of the calling computer
- Operating system of the calling computer
- Browser version of the calling computer
- Name of the retrieved file/website
- Date and time of retrieval
- Transferred amount of data
- Referring URL
This data is processed in order to be able to present the website, to ensure the security, availability and integrity of the website (e.g., detection and defense against DoS attacks or access by bots), to improve the quality and presentation of the website, to be able to identify and correct errors and for statistical purposes. This data is regularly deleted after a few days.
The legal basis for this data processing is the legitimate interest of the Controller in the above-mentioned purposes.
3.2. Web Analytics (Plausible)
The website uses the web analytics service Plausible provided by Plausible Insights OÜ in Estonia. The provider acts as a data processor on the basis of a data processing agreement.
The use of the website is statistically analyzed in order to better understand how visitors use the website and to be able to continuously improve the website and the content and services offered. The data collected is used to create aggregated usage reports.
- When using the web analysis service Plausible, the following data is collected
- IP address of the user's accessing system,
- the website accessed and the subpages accessed
- the website from which the user accessed the website (referrer)
- the time spent on the website,
- The frequency of visits to the website
Plausible does not set a cookie but uses a so-called device fingerprinting process. The following information is stored in the device fingerprinting process Browser language, operating system, browser used, browser plugins.
The data collected is stored hashed for 24 hours so that the website visitor can be recognized as a unique visitor on the next visit.
The legal basis for this data processing is the Controller's legitimate interest in a statistical evaluation of user behavior in order to continuously improve the website and the content and services offered. If consent has been obtained, the expressly granted consent, which can be revoked at any time, constitutes the legal basis.
- PROSPECTS, CUSTOMERS AND SERVICE PROVIDERS (CRM)
If you contact us, e.g. by email or via a contact form, the information you provide will be processed for the purpose of handling your inquiry.
We need the information requested in a contact form in order to process your inquiry, address you correctly and send you an answer.
We process the data of our customers, service providers and suppliers as part of the provision of our contractual services. This may involve processing inventory data (e.g. surname and first name of the contact person(s), address), contact data (e.g. email address, telephone number), contract data (e.g. subject matter of the contract, term), payment data and data that is collected as part of the provision of services and/or is necessary for the provision of services.
Inquiries and customer relationships are regularly processed in our CRM system. The data processed (surname, first name, title, postal address, date of birth if applicable, your specific interest in our products and services and your interactions with us) may also be used by us for direct marketing purposes, in particular for postal advertising, in compliance with legal requirements.
The legal basis for this data processing is the Controller's legitimate interest in communicating with customers, service providers, suppliers, interested parties, visitors to the website and other third parties, in maintaining relationships with interested parties, customers and service providers and in marketing the products and services. If the contact is aimed at the conclusion of a contract or takes place in the context of the performance of a contract, the legal basis for the processing is the fulfillment of the contract or the implementation of pre-contractual measures.
- SOCIAL MEDIA
5.1. Social Media Buttons
Social media buttons of various social media networks (e.g. Linkedin and Xing) are integrated on our website.
If you click on one of these social media buttons, you will be redirected to our pages on the respective social media network. In this case, the provider of the respective social media network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the respective social media network or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a server of the respective provider. If you click on a social media button and are either logged in to the respective social media network or then log in to the page of the respective social media network, the transmitted information can be assigned to your account with the social media network.
For information on the purpose and scope of data collection and processing by the providers of the respective social media network, the provider identification, a contact option and your rights and setting options for data protection, please refer to the respective privacy policy of the providers of the social media networks.The legal basis for the integration and use of social media buttons is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our offers and our website.
5.2. Social Media Pages
We maintain a publicly accessible profile on various social media networks (e.g. Linkedin and XING).
If you visit our social media pages and are logged in to the respective social media network, the provider of the respective social media network can analyze your usage behavior and assign the information collected to your account with the social media network and enrich it there. Even if you are not logged in or if you do not have an account with the respective social media network, personal data may be collected by the provider of the respective social media network, for example your IP address or data collected via a cookie.
The operators of the social media networks can use this data to create user profiles. Based on your user profile, you can then be shown interest-based advertisements both on the websites of the social media network and on other websites.
If you visit one of our social media pages, we are jointly responsible with the provider of the social media network for the collection and processing of your personal data that takes place there. For information on the collection and processing of your personal data that takes place there, we refer you to the privacy policy of the respective social media network.
You can assert your data subject rights in accordance with Chapter III. of the GDPR (right to information, correction, deletion, restriction of processing, data portability, etc.) both against us and against the provider of the respective social media network. In this context, we would like to point out that we can only influence the processing of personal data and the implementation of data subject rights within the framework of our social media pages within the scope of the possibilities made available to us by the respective provider.
The legal basis for our use of social media pages is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the presence and marketing of our products and services on the Internet.
- ONLINE MEETINGS AND WEBINARS
When participating in an online meeting or a webinar offered or conducted by the Controller, the personal data of the participants is processed.
When participating in an online meeting or webinar, various categories of data are processed. The scope of the data also depends on what data the participants provide about themselves and as part of their participation.
When participating in an online meeting or a webinar, at least a name must regularly be provided when registering. However, a pseudonym can also be used. The IP address of the participants is also processed to enable participation. Login information and device/hardware information is also processed. Furthermore, if specified, the participant's email address and profile picture will be processed. In the case of participation by telephone, the telephone number and, if applicable, the IP address are processed, if transmitted.
When participating in an online meeting or a webinar, if the participant has activated the microphone and/or a camera on the end device, the participant's image and sound data will be processed as part of the participation. If the screen is shared, the information from this screen share is also processed. Participants are free to activate the microphone, camera or screen share.
Audio and video recordings of online meetings or webinars can be created. In this case, the data of all audio, video and presentation recordings will be processed. There will always be a reference to the recording if one is made and, if necessary, the explicit consent of the participants will always be obtained for the recording.
It is also possible to use the chat, question or survey functions in online meetings or webinars. In this respect, the text entries made by the participants are processed in order to display them in the respective online meeting or webinar and, if necessary, to record them.
An external service provider is used as a data processor to conduct and, if necessary, record online meetings and webinars.
Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.
The legal basis for this processing is the fulfillment of the contract or the implementation of pre-contractual measures, provided that the implementation and participation in the online meeting or webinar within the framework of an existing contractual relationship is necessary for the fulfillment of the contract or is aimed at the conclusion of a contract. This is regularly the case for employees, customers, interested parties, service providers and suppliers. Otherwise, the legal basis for processing is the Controller's legitimate interest in efficient communication, both internally and with external stakeholders.
- JOB APPLICATIONS
7.1. Active Sourcing
We carry out so-called active sourcing measures to identify promising potential employees on the external labor market and actively contact potential applicants and employees. The purpose of data processing is recruitment, e.g. by individually drawing the attention of promising candidates to job vacancies in our company.
We collect the following categories of data for active sourcing: Surname, first name, gender, contact details, education, professional experience, qualifications, salary data, application data, non-professional experience and interests and other information resulting from public profiles on social networks, in particular LinkedIn and Xing, and/or from other publicly accessible sources on the internet.
All personal data processed in the context of active sourcing is collected from generally/publicly accessible sources on the Internet, in particular from social networks such as LinkedIn and Xing.
The legal basis for the collection and processing of publicly accessible data in the context of active sourcing is the Controller's legitimate interest in identifying, approaching and recruiting the best possible employees for the company.
7.2. Application Process
We collect and process personal data from applicants for the purpose of carrying out the application process.
If we conclude an employment contract with an applicant, the data transmitted will be processed for the purpose of implementing the employment relationship in compliance with the statutory provisions. If no employment contract is concluded, the application documents will be deleted immediately after the end of the application procedure, provided that there is no overriding legitimate interest in deletion, such as the defense against claims or the preservation of evidence in accordance with equal treatment and anti-discrimination laws.
The legal basis for this storage and processing is the implementation of pre-contractual measures.
7.3. Talent Pool
If the applicant has consented to a longer storage of his/her data, we will store the data submitted as part of the application in our talent pool for a further 2 years after the end of the application process in order to identify future positions of potential interest to the applicant and, if necessary, contact the applicant in this regard. After this period, the data will be deleted.
Such consent to the storage of application data in our talent pool can be withdrawn at any time for the future. To do so, please send us an email to the contact details provided above.
The legal basis for the storage of application documents in our Talent Pool is, where applicable, the explicit consent of the applicant, which can be revoked at any time.
7.4. Compliance/Sanctions Screening
Applicants who are shortlisted as part of the application process may be subject to an initial compliance check. The compliance check involves a comparison of the applicant's name and address with relevant sanctions lists, in particular on the basis of the EU anti-terrorism regulations.
To carry out the compliance/sanctions list screening, we use an external service provider as a data processor on the basis of a data processing agreement.
The legal basis for this storage and processing is, if there is a legal obligation to carry out a compliance/sanctions list screening, the fulfillment of the legal obligation. In individual cases, depending on a balancing of interests, compliance/sanctions list screening can also take place if there is no mandatory legal obligation. In this case, the legal basis is our legitimate interest in avoiding potential sanctions by foreign authorities.
- VIDEO SURVEILLANCE
Some of our production sites are monitored by video. This monitoring is clearly indicated by signs. The legal basis for this storage and processing is Art. 6 (1) lit. b) GDPR. The purpose of video surveillance and our legitimate interest is to safeguard the rights of the home, to protect our employees from dangerous situations, to protect our property, in particular our business premises including equipment, and to preserve evidence after criminal offences. Only the management has access to the records. In individual cases, the records may be passed on to criminal prosecution authorities in accordance with their purpose. The deletion of the data is carried out by the system after 7 working days, provided that there are no incidents in the sense of our legitimate interest, which make a longer storage necessary.
- MERGERS AND ACQUISITIONS (M&A)
If we are involved in a restructuring, acquisition, asset sale, merger, financing, transfer of services to another provider, due diligence, insolvency or receivership, your personal data may be transferred to third parties to the extent legally permitted in connection with and as part of the relevant legal process, subject to the basic principles of data protection law.
- AGE RESTRICTION
This website is not intended or designed for use by children under the age of 16. We do not knowingly collect personally identifiable information from or about anyone under the age of 16.
- RECIPIENTS OF DATA
Within the Controller's organization, access to data is granted to those internal departments or organizational units that need it to perform their tasks, if necessary to fulfill contracts, for data processing based on the consent of the data subject(s) or to protect overriding legitimate interests.
Data will only be passed on to third parties in accordance with legal requirements. Your data will only be passed on to third parties if this is necessary for contractual purposes or to safeguard our overriding legitimate interest in the effective performance of our business operations.
If we use service providers or third-party providers to provide the website or other services, we take suitable legal precautions and appropriate technical and organizational measures to ensure the protection of your personal data.
- DATA SUBJECT RIGHTS
Within the scope of the legal requirements, data subjects have the following rights with regard to the processing of personal data:
12.1. Right of Access
Data subjects have the right to request information about the personal data processed about them.
12.2. Right to Rectification
Data subjects have the right to request the rectification of inaccurate personal data concerning them. They also have the right to request the completion of incomplete personal data.
12.3. Right to Erasure
Data subjects have the right to request the erasure of personal data concerning them.
12.4. Right to Restriction of Processing
Data subjects have the right to request that the processing of personal data concerning them be restricted.
12.5. Right to Object to Processing
**Data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or which is based on a legitimate interest. In this case, the data will no longer be processed unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
In addition, data subjects have the right to object at any time to the processing of personal data concerning them for the purpose of direct marketing; this also applies to any profiling insofar as it is associated with such direct marketing. **
12.6. Right to Withdraw a Consent
Data subjects have the right to withdraw their consent if they have given their consent for processing.
12.7. Right to Data Portability
Data subjects have the right to receive the personal data concerning them, which they have provided to a Controller, in a structured, commonly used and machine-readable format ("data portability") and the right to transmit those data to another Controller.
12.8. Exercising the Rights
The rights of data subjects can be exercised by notifying the Controller or, where applicable, the Data Protection Officer using the contact details provided above.
12.9. Right to Lodge a Complaint with the Data Protection Supervisory Authorities
If data subjects believe that the processing of personal data concerning them breaches data protection law, they have the right to lodge a complaint with a data protection supervisory authority.
- MANDATORY INFORMATION AND PROFILING
The provision of personal data is neither legally nor contractually required. There is no obligation to provide personal data, however, the provision of personal information is necessary for the conclusion of a contract insofar as certain information is mandatory in order to conclude (and execute) a contract.
Automated decision-making, including profiling, is not carried out.
- RETENTION AND DELETION
We adhere to the principles of data avoidance and data economy and only store your personal data for as long as is necessary to achieve the respective purpose of the data processing purposes or as stipulated by the storage periods provided by law.
If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal data will be routinely anonymized or deleted in accordance with the statutory provisions.
- INFORMATION SECURITY
We take appropriate technical and organizational measures in accordance with the state of the art to ensure a level of protection for the personal data we process that is appropriate to the risk of the respective processing and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, inquiries or payment data that you send to us.
Our employees receive regular training on data protection and information security and are committed to confidentiality and data protection.
A restrictive rights and roles concept on a "need to know" basis ensures that employees only have access to the personal data they absolutely need to perform their duties.
- AMENDMENT OF THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy from time to time so that it always complies with current legal requirements and/or in order to implement changes to our services in the Privacy Policy, e.g. when introducing new services. When visiting the website or using our services, the current privacy policy always applies.