I. Privacy Policy according to the Data Protection Regulation (DSGVO)
The following privacy policy, in accordance with the provisions of data protection law (in particular according to BDSG nF and the European General Data Protection Regulation DSGVO), informs you comprehensively about the handling, type, purpose and scope of the processing of personal data by our company, as well as their rights in connection with the use of our online offer and the associated website, functions and content, as well as external online presences, such as our social media profiles.
The use of our website is usually possible without providing personal data. If personal data (eg name, address or e-mail address) is collected on our website, this is done on a voluntary basis. If you do not want us to process your personal data, please do not submit it to us. In this Privacy Policy, we refer to our services to individuals and businesses as “Services”, the “natural persons” of our current or potential natural persons, and those who engage us in seeking suitable candidates, as “Customers”.
With regard to the definition of terms such as “personal data” or “processing”, we refer to Article 4 of the General Data Protection Regulation (GDPR). Unfortunately, it is in the nature of things that these explanations sound very technical, but we have tried to make the most important things as simple and clear as possible.
II. Responsible
The person responsible (hereinafter referred to as “responsible persons”) within the meaning of Art. 4 Zif. 7 DSGVO and other data protection laws of the member states as well as data protection regulations is:
Recenter & Refine
Inhaberin: Jamie Gutierrez
Hintere Metzgergasse 2
88131 Lindau
Germany
Phone.: +49 163 799 1638
E-Mail: [email protected]
Web: www.recenterrefine.com
If you have any questions about the collection, processing or use of your personal data, rights, such as information, correction, blocking or deletion of data or other topics with data protection rights, please contact our data protection team at the email address: [email protected].
III. Types of data, purposes of processing and categories of data subjects
Below we inform you about the nature, scope and purpose of the collection, processing and use of personal data:
1. Types of data we process
– Usage data (access times, websites visited, etc.)
– Inventory data (name, address etc.)
– contact details (telephone number, e-mail, fax, etc.)
– content data (e.g., text input, photographs, videos)
– meta / communication data (e.g., device information, IP addresses)
2. Purposes of processing according to Art. 13 para. 1 c) DS-GVO
Availability of the online offer, handling of contact requests and communication with users, marketing measures / range measurement
3. Categories of data subjects according to Art. 13, para. 1 e) DS-GVO
Visitors / users of the website, customers, prospects, applicants,
The persons concerned are collectively referred to as “users”.
IV. Definitions
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”); a natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by assigning him or her to an identifier such as a name, an identification number, location data, an online identifier or to one or more special features which express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person;
“Processing” means any process performed, with or without the aid of automated procedures, or any such process associated with personal data, such as gathering, collecting, sorting, organizing, storing, adapting or modifying, selecting, retrieving, using, disclosure by transmission, dissemination or other means of provision, matching or linking, restriction, erasure or destruction;
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data Data should not be assigned to an identified or identifiable natural person;
“Controller” means the natural or legal person, public authority, entity or other body which, alone or jointly with others, decides on the purposes and means of processing personal data; where the purposes and means of such processing are specified by Union law or the law of the Member States, the controller or the specific criteria of their appointment may be provided for under Union or national law;
“Processor” means a natural or legal person, public authority, entity or other body that processes personal data on behalf of the controller;”Third party” means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or processor;
“Consent” of the data subject shall mean any voluntary expression of intent, given in an informed and unambiguous manner, in the form of a statement or other unambiguous confirmatory act, by which the data subject indicates that they agree to the processing of personal data concerning them.
V. Automatic data storage
When you visit websites today, certain information is automatically created and stored, including on this website. If you visit our website as it is now, our web server (computer on which this website is stored) automatically saves data such as
– the address (URL) of the visited web page
– browser and browser version
– the operating system used
– the address (URL) of the previously visited page (Referrer URL) – the host name and the IP address of the device from which is accessed – date and time
in files (web server log files).
As a rule, web server log files are stored for two weeks and then deleted automatically. We do not disclose this information, but we can not rule out that it will be seen in the event of unlawful behavior. The legal basis, according to Article 6 paragraph 1 f DSGVO (lawfulness of processing), is that there is a legitimate interest in enabling the error-free operation of this website by capturing web server log files.
VI. Use of cookies
Our website uses technically necessary cookies. Cookies are text files that are stored in the Internet browser or on the Internet browser on your device used to access our website or our services. These cookies contain characteristic strings that allow the browser to be clearly identified when the website is reopened. This allows a more efficient and better use of our offer. You can object to the setting of cookies by changing the settings of your Internet browser and delete already set cookies at any time through your Internet browser or third-party software. Please note, however, that if you deactivate the setting of cookies, not all functions of our website may be fully usable. We use technically necessary cookies. The following data are stored and transmitted in the cookies:
– Information about the browser type and version used
– The operating system
– The IP address of the user
– Date and time of access
– Websites from which the system is accessed on our website
There are 4 types of cookies:
– Absolutely necessary cookies
These cookies are necessary to ensure basic functionality of the website. For example, these cookies are needed if a user puts a product in the shopping cart, then continues surfing on other sites and later goes to the checkout. These cookies do not delete the shopping cart, even if the user closes his browser window.
– Functional cookies
These cookies collect information about the user behavior and whether the user gets any error messages. In addition, these cookies also measure the load time and behavior of the website on different browsers.
– Targeted cookies
These cookies make for better usability. For example, stored locations, font sizes or form data are stored.
– Advertising cookies
These cookies are also called targeting cookies. They are used to provide the user with customized advertising. This can be very convenient, but also very annoying. Usually, the first time you visit a webpage, you are asked which of these cookie types you want to allow. And of course, this decision is also stored in a cookie.
How can I delete cookies?
You decide for yourself how and whether you want to use cookies. Regardless of which service or which website the cookies come from, you always have the option of deleting cookies, only partially approving or deactivating them. For example, you may block third-party cookies but allow all other cookies.
If you want to know which cookies have been saved in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:
Chrome: Delete, activate, and manage cookies in chrome
Safari: Manage cookies and site data with Safari
Firefox: Delete cookies to remove data that websites have stored on your computer
Internet Explorer: deleting and managing cookies
Microsoft Edge: deleting and managing cookies
If you basically do not want to have cookies, you can set up your browser so that it always informs you when a cookie is to be set. So you can decide with each single cookie whether you allow the cookie or not. The procedure varies depending on the browser. It is best that you search Google for “Chrome cookies” or “Disable cookies Chrome” in the case of a Chrome browser, or replace the word “Chrome” with the name of your browser, e.g. Edge, Firefox, Safari out.
VII. Legal basis for the processing of personal data
Below we inform you about the legal bases of the processing of personal data:
1. If we have obtained your consent for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a) DS-GMO Legal basis.
2. If the processing is necessary to fulfill a contract or to carry out pre-contractual measures, which are made at your request, then Art. 6 para. 1 sentence 1 lit. b) DS-GMO Legal basis.
3. If the processing is necessary to fulfill a legal obligation that we are subject to (eg statutory retention obligations), Art. 6 para. 1 sentence 1 lit. c) DS-GMO Legal basis.
4. If processing is necessary to protect the vital interests of the data subject or of another natural person, Art. 6 para. 1 sentence 1 lit. d) DS-GMO Legal basis.
5. If the processing is necessary to safeguard our or the legitimate interests of a third party and your interests or fundamental rights and freedoms do not predominate in this regard, then Art. 6 para. 1 sentence 1 lit. f) DS-GVO Legal basis.
VI. Disclosure of personal data to third parties and processors
Without your consent, we generally do not pass on data to third parties. If this is the case, then the transfer takes place on the basis of the aforementioned legal basis, e.g. when passing on data to online payment providers for performance of a contract or by court order or for a legal obligation to disclose the data for the purpose of prosecution, security or enforcement of intellectual property rights. We also use processors (external service providers, for example, to host our websites and databases) to process your data. If data are passed on to the processor by order processing, this is always done in accordance with Art. 28 of the GDPR. We select our processors carefully, monitor them regularly and have given us the right to give instructions regarding the data. In addition, the processors must have taken appropriate technical and organizational measures and the data protection rules in accordance with Art. BDSG n.F. and DS-GMOs
VIII. Data transmission to third countries
The adoption of the basic European data protection regulation (DS-GVO) has created a uniform basis for data protection in Europe. Your data will therefore be processed primarily by companies for which DS-GVO applies. If the processing takes place through services of third parties outside the European Union or the European Economic Area, they must fulfill the special requirements of Art. 44 et seq. DS-GVO. This means that the processing takes place on the basis of special guarantees, such as the official recognition by the EU Commission of a data protection level corresponding to the EU, or the observance of officially recognized special contractual obligations, the so-called “standard contractual clauses”. In US companies, submission to the so-called Privacy Shield, the EU-US data protection agreement, meets these requirements.
IX. Deletion of data and storage duration
Unless explicitly stated in this privacy policy, your personal data will be deleted or blocked as soon as the purpose of the storage is omitted, unless their further storage is required for evidence or contrary to legal storage requirements. These include, for example, commercial requirements for the storage of business letters pursuant to Section 257 (1) HGB (6 years) and tax-related retention obligations pursuant to Section 147 (1).If the prescribed retention period expires, your data will be blocked or deleted, unless storage is still required for a contract or fulfillment.
X. Existence of automated decision-making
We do not use automatic decision making or profiling.
XI. Provision of our website and creation of log files
1. If you only use our website for informational purposes (ie no registration and no other transmission of information), we only collect the personal data that your browser transmits to our server. If you want to view our website, we collect the following data:
• IP address;
• Internet service provider of the user;
• Date and time of the call;
• browser type;
• Language and browser version;
• Content of the call;
• time zone;
• access status / HTTP status code;
• amount of data;
• Websites from which the request comes;
• Operating system.
A storage of this data together with other personal data of you does not take place.
2. This data is for the purpose of the user-friendly, functional and secure delivery of our website to you with functions and content as well as their optimization and statistical evaluation.
3. The legal basis for this is our justifiable interest in the processing of data according to Art. 6 para. 1 p. 1 lit. f) DS-GMO.
4. For security reasons, we store this data in server log files for the retention period of days. After this period, they will be automatically deleted, unless we need their storage for evidence in attacks on the server infrastructure or other violations.
XII. Google Analytics
1. We have integrated the Google Analytics web site analytics tool (Google Ireland Limited, register no .: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website.
2. When visiting our website Google places a cookie on your computer in order to be able to analyze the use of our website by you. The data obtained is transferred to the USA and stored there. If personal information should be transferred to the US, Google’s certification under the Privacy Shield Agreement (https://www.privacyshield.gov/EU-US-Framework) is a guarantee of compliance with European data protection law.
3. We have activated the IP anonymization “anonymizeIP”, which means that the IP addresses are only processed in shortened form. Google’s IP address on this website is therefore shortened beforehand within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the controller. In addition, we have activated the cross-device analysis of website visitors, which is carried out via a so-called user ID. The IP address provided by Google Analytics within the framework of Google Analytics will not be merged with other data provided by Google. The use of Google Analytics is for the purpose of analyzing, optimizing and improving our website.
4. The legal basis for this is our justifiable interest in the processing of data according to Art. 6 para. 1 p. 1 lit. f) DS-GMO.
5. The data sent by us and linked to cookies, user IDs (eg user IDs) or advertising IDs will be automatically deleted after months. The deletion of data whose retention period has been reached is done automatically once a month.
6. For more information on Google Analytics data usage, please visit: https://www.google.com/analytics/terms/de.html (Analytics Terms of Service) https://support.google.com/analytics/answer/6004245?hl=de (Privacy Policy for Analytics) and Google’s Privacy Policy https://policies.google.com/privacy.
7. Opposition and opt-out: You can generally prevent the storage of cookies on your hard disk by selecting “Do not accept cookies” in your browser settings. However, this can result in a functional restriction of our offers. You may also prevent the collection of data generated by the cookie and related to your use of the website from Google, as well as the processing of such data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de
8. As an alternative to the above browser plug-in, you can prevent the collection by Google Analytics by clicking [insert the Analytics Opt-Out link of your website]. The click will set an “opt-out” cookie that will prevent the collection of your data when visiting this website in the future. This cookie is only valid for our website and your current browser and is only valid until you delete your cookies. In that case you would have to set the cookie again.
9. You can turn off cross-device user analytics in your Google Account under My Data> Personal Information.
XIII. Google ReCAPTCHA
1. We have incorporated on our website anti-spam feature “reCAPTCHA” from “Google” (Google Ireland Limited, register no .: 368047, Gordon House, Barrow Street, Dublin 4, Ireland). By using “reCAPTCHA” in our forms, we can determine if the input was made by a machine (robot) or a human. When using the service, your IP address and any other required data may be transmitted to Google servers in the United States.
2. The purpose of processing this data is to avoid spam and abuse as well as our economic interest in optimizing our website.
3. The legal basis for this is our justifiable interest in the processing of data according to Art. 6 para. 1 p. 1 lit. f) DS-GMO.
4. Google is certified under the Privacy Shield Agreement (https://www.privacyshield.gov/EU-US-Framework). This ensures that European data protection law is respected.
5. For more information, see Google ReCAPTCHA at https://www.google.com/recaptcha/ and Google’s Privacy Policy at https://policies.google.com/privacy.
XIV. Social media presence
1. We use social media profiles or fanpages to communicate with users who are affiliated and registered there and to provide information about our products, offers and services. The US providers are certified according to the so-called privacy shield and thus obliged to comply with European data protection. When you use and access our profile in the respective network through you, the respective privacy policy and terms of use of the respective network apply.
2. We integrate elements of social media services on our website to display pictures, videos and texts. By visiting pages representing these elements, data is transferred from your browser to the respective social media service and stored there. We do not have access to this data.
The following links lead you to the pages of the respective social media services where it is explained how they deal with your data:
• Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland) Data protection: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
• Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Data protection/ Opt-Out: http://instagram.com/about/legal/privacy/.
• Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Data protection: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
• XING (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Deutschland) – Data protection / Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
• LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland) – Data protection: https://www.linkedin.com/legal/privacy-policy, Cookie-Guideline and Opt-Out: https://www.linkedin.com/legal/cookie-policy, Privacy Shield.: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
3. We process your information that you send to us through these networks in order to communicate with you and to respond to your messages there.
4. The legal basis for the processing of personal data is our legitimate interest in communicating with users and our external presentation for the purpose of advertising pursuant to Art. 6 (1) sentence 1 lit. f) DS-GMO. Insofar as you have given consent to the person responsible for the social network in the processing of your personal data, the legal basis is Art. 6 (1) sentence 1 lit. a) and Art. 7 DS-BER.
XV. Social Media Buttons
5a. Facebook Button
We use features of Facebook, a social media network of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland. What features (social plug-ins) Facebook provides, you can read on https://developers.facebook.com/docs/plugins/ . By visiting our website information can be transmitted to Facebook. If you have a Facebook account, Facebook can associate that information with your personal account. If you do not want that, please log out of Facebook. The privacy policy, which information Facebook collects and how they use them can be found at https://www.facebook.com/policy.php.
5b. Instagram Button
We have implemented Instagram features on our website. Instagram is a social media platform owned by Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. Instagram has been a subsidiary of Facebook Inc. since 2012 and is one of the Facebook products. Embedding Instagram content on our website is called embedding. This allows us to show you content such as buttons, photos or videos from Instagram directly on our website. When you visit web pages on our website that have an Instagram feature, data is sent to Instagram, stored and processed. Instagram uses the same systems and technologies as Facebook. Your data will thus be processed across all Facebook companies.
5c. Twitter Button
On our website the social media button of the service Twitter is used. These buttons (e.g., “Tweet” or “Follow”) are offered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. If you click on the Twitter button as a user of our website, then your browser establishes a direct connection to the servers of Twitter. The content of the Twitter button is transmitted by Twitter directly to the user’s browser. We therefore have no influence on the amount of data that Twitter collects with the help of this plugin and hereby inform you according to our knowledge. After this only the IP address of the user, the URL of the respective website when the button is received, but not used for purposes other than the presentation of the button. If you want to know more about using your data through Twitter, you will find all the information in the Twitter Datenschutzrichtline auf https://twitter.com/de/privacy. If you have an account on Twitter, you can change your privacy settings in Account Settings at https://twitter.com/settings/account
5d. LinkedIn Button
Our website uses a feature of the LinkedIn network. Providers is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States. If you click the LinkedIn button (plug-in), you will be redirected to our LinkedIn offer in a separate browser window and, if you are logged in to your LinkedIn account, you can follow us on LinkedIn. The plug-in establishes a direct connection between your browser and the LinkedIn server. LinkedIn receives the information that you have visited our website with your IP address. In addition, LinkedIn will be able to associate your visit to our website – if you are logged in to your LinkedIn account – with you and your user account. We point out that we have no knowledge of the content of the transmitted (personal) data and their use by LinkedIn. You can find the privacy policy, what information LinkedIn collects and how they use it https://www.linkedin.com/legal/privacy-policy.
5e. XING Button
Our website uses a function of the network XING. Provider is the XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. If you click on the XING button (plug-in), you will be redirected to our offer on XING in a separate browser window and, provided that you are logged into your XING user account, you can follow us on XING. The plug-in establishes a direct connection between your browser and the XING server. XING receives the information that you have visited our website with your IP address. We point out that we have no knowledge of the content of the transmitted (personal) data and their use by XING. You can find the privacy policy, what information XING collects and how they use them https://www.xing.com/privacy.
XVI. Data protection in applications and in the application process
1. Applications sent electronically or by post to the person in charge will be processed electronically or manually for the purpose of processing the application process.
2. We expressly point out that application documents with “special categories of personal data” according to Art. 9 DS-GVO (eg a photo, which gives an indication of your ethnic origin, religion or your marital status), with the exception of any severe disability, which you wanting to disclose a free decision are undesirable. You should submit your application without this data. This does not affect your candidate chances.
3. Legal bases for processing are Art. 6 para. 1 p. 1 lit. b) DS-GVO and § 26 BDSG n.F.
4. If, after the completion of the application process, an employment relationship with the applicant is received, the applicant data will be stored in compliance with relevant data protection legislation. If no job is offered to you after completing the application process, your application letter and documents will be deleted 6 months after the cancellation has been sent in order to be able to satisfy any claims and proof obligations according to AGG.
XVII. Rights of the data subject
1. Opposition or revocation against the processing of your data
Insofar as the processing is based on your consent pursuant to Art. 6 para. 1 sentence 1 lit. a), Art. 7 DS-GVO, you have the right to revoke your consent at any time. The lawfulness of the processing on the basis of the consent until the revocation is not affected.
As far as we have the processing of your personal data on the balance of interests in accordance with Art. 6 para. 1 p. 1 lit. f) support DS-GMO, you can object to the processing. This is the case if, in particular, the processing is not required to fulfill a contract with you, which we present in the following description of the functions. In the event of any such disagreement, we ask you to explain the reasons why we should not process your personal data as we have done. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons on which we continue the processing.
You may object to the processing of your personal data for advertising and data analysis purposes at any time. The right to object can be exercised free of charge. About your advertising conflict you can inform us under the following contact details:
Recenter & Refine
Hintere Metzgergasse 2
88131 Lindau
Germany
E-Mail: [email protected]
2. Right to information
You have the right to ask us for confirmation of your processing of personal information. If this is the case, you have a right to information about your personal data stored by us according to Art. 15 DS-GVO. This includes, in particular, information about the processing purposes, the category of personal data, the categories of recipients to whom your data was or is being disclosed, the planned storage period, the source of their data, if these were not collected directly from you.
3. Right to rectification
You have the right to correct inaccurate or complete data according to Art. 16 DS-GVO.
4. Right to delete
You have a right to deletion of your stored data according to Art. 17 DS-GVO, unless statutory or contractual retention periods or other legal obligations or rights to further storage are contrary to this.
5. Right to restriction
You have the right to demand a restriction on the processing of your personal data if one of the conditions set out in Art. 18 (1) lit. a) to d) DS-GVO is fulfilled:
• If you deny the accuracy of your personal information for a period of time that enables the controller to verify the accuracy of your personal information;
• the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of personal data;
• the controller no longer needs personal information for the purposes of processing, but you need it to assert, exercise or defend legal claims; or
• if you have objected to the processing pursuant to Art. 21 para. 1 DS-GVO and it is not yet certain whether the legitimate reasons of the person responsible outweigh your reasons.
6. Right to data portability
You have the right of data transferability according to Art. 20 DS-GVO, which means that you can receive the personal data stored about us in a structured, common and machine-readable format or you can request the transfer to another person responsible.
7. Right to appeal
You have a right to complain to a supervisor. In general, you can turn this to the supervisory authority in particular in the Member State of their residence, their place of work or the location of the alleged violation.
XVIII. Data security
In order to protect all personally identifiable information transmitted to us and to ensure compliance with our privacy practices, as well as our external service providers, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server encrypted over a secure SSL connection.
Last updated: 22 May 2024