Privacy policy

This Privacy Policy will inform you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offer and the websites, functions and related content, as well as external online presences, such as our social media profiles (hereinafter referred to as “online offer”). With regard to the terms like “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

 

Responsible party

CST GmbH
Alfred-Nobel-Straße 17
79761 Waldshut Tiengen
Germany

Email: info@cst-gmbh.eu
CEO: Dr. Michael Bach

 

Types of data processed

  • Inventory data (e.g. personal data, names or addresses)
  • Contact data (e.g. email, phone numbers)
  • Content data (e.g. text input, photographs, videos)
  • Usage data (e.g. web pages visited, interest in content, access times)
  • Meta/communication data (e.g. device information, IP addresses)

 

Categories of affected persons

Visitors and users of the online offer (hereinafter referred to as “users”).

 

Purpose of processing

  • Provision of the online offer, its functions and contents
  • Respond to contact requests and communicate with users
  • Safety measures
  • Reach measurement/marketing

 

Used terms

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

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is global and includes virtually any handling of data.

“Pseudonymization” means the processing of personal data in such a way 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 stored separately and is subject to technical and organizational measures to ensure that personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data which includes using such personal data to evaluate personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

“Responsible party” means a natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the personal data processing.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the responsible party.

 

Applicable legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users from the jurisdiction of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if a legal basis is not stated in the privacy policy:

The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for the processing to fulfill our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR;

The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another person make it necessary to process personal data, Art. 6 (1) lit. d GDPR serves as the legal basis.
The legal basis for necessary processing for the performance of a task carried out in public interest or in exercise of official authority transferred to the responsible party is Art. 6(1)(e) GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f GDPR.
The processing of data for purposes other than those for which they were collected shall be determined in accordance with Art. 6 (4) GDPR.
The processing of special categories of data (in accordance with Art. 9 (1) of the GDPR) is determined in accordance with the requirements of Art. 9 (2) of the GDPR.

 

Security measures

We take appropriate technical and organizational measures to ensure a level of protection related to the risk in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedom of persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure of, assurance of availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. Additionally, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly presets.

 

Cooperation with processors, joint persons responsible and third parties

If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible parties or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permissions (e.g. if a transmission of the data to third parties is necessary for the fulfillment of the contract, for example to payment service providers), if users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.)..

If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and in addition, on a basis that complies with legal requirements.

 

Transfer to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of using third-party services or disclosing, or transferring data to other persons or companies, this will only be done in order to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as contractual obligation with so-called standard protection clauses of the EU Commission, the existence of certifications or mandatory internal data protection rules (Art. 44 to 49 GDPR, EU Commission information page).

 

Rights of the data subjects

You have the right to request confirmation as to whether data in question is being processed and to disclosure about this data, as well as further information and a copy of the data in accordance with the legal requirements.

In accordance with the legal requirements, you have the right to request that your data may be completed or corrected.

In accordance with the legal requirements, you have the right to demand that your data may be deleted without delay or alternatively, to demand restriction of the processing of the data.

In accordance with the legal requirements, you have the right to request that the data you have provided to us be received and to request that it be transferred to other data controllers.

In accordance with the legal requirements, you also have the right to file a complaint with the competent supervisory authority.

 

Right of withdrawal

You have the right to revoke given consents with effect for the future.

 

Right of object

You may object to the future processing of data relating to you at any time in accordance to legal requirements. The objection can be made in particular for the processing for purposes of direct advertising.

 

Cookies and right to object to direct advertising

Cookies are small files that are stored on users’ computers. Different information can be stored in these cookies. The main purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after the visit of an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes the browser. In such a cookie, for example, the contents of a shopping cart of an online store or a login status can be stored. “Permanent” or “persistent” cookies are those that are stored even after the browser is closed. For example, the login status can be saved when a user visits the website after several days. Such a cookie may also store the interests of users, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only their cookies, they are referred to as “first party cookies”).

We may use temporary and permanent cookies and further explain this in our privacy policy.

If users do not want cookies to be stored on their computer, they can disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the settings of the browser. The exclusion of cookies may lead to functional restrictions of the online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the website http://www.aboutads.info/choices/ for the US or http://www.youronlinechoices.com/ for the EU. Furthermore, the storage of cookies can be achieved by means of their deactivation in the browser settings. Please note that in this case not all functions of the online offer can be used.

 

Deletion of data

The data processed by us will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any legal requirements.

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. I.e. the data is restricted and not processed for other purposes. This applies, for example, to data that must be stored for reasons of commercial or tax law.

 

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will update the privacy policy when changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require a cooperation from you (e.g. consent) or other individual notification.

 

Business-related processing

In addition we process

  • Contract data (e.g. subject matter of the contract, term, customer category)
  • Payment data (e.g. bank details, payment history)

of our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

 

Agency services

We process our customers’ data as part of our contractual services which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In doing so, we process data (e.g. customer data, such as names or addresses), contact data (e.g. email, telephone number), content data (e.g. text entries, photographs, videos), contract data (e.g. subject matter of contract, term), payment data (e.g. bank details, payment history), usage data and metadata (e.g. in context of evaluating and measuring the success of marketing measures). Categorically, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers, as well as their customers, users, website visitors or employees, and third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfillment of the contractual services and refer to the necessity of their indication. Disclosure to external parties only takes place if it is required as part of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the customer, as well as the legal requirements of a commissioned processing pursuant to Art. 28 GDPR and do not process the data for any other purposes than those specified in the order.

We delete the data after expiration of legal warranty and comparable obligations. The necessity of keeping the data is checked every three years; in the case of legal requirements of archiving, deletion takes place after their expiry (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). In the case of data disclosed to us by the customer as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.

 

Contractual services

We process the data of our contractual partners and interested parties as well as other clients, customers, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 Para. 1 lit. b. GDPR to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.

The processed data includes the data of our contractual partners (e.g. name and address), contact data (e.g. email address and telephone number) as well as contract data (e.g. services used, contract contents, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).

Categorically, we do not process special categories of personal data, unless these are components of a commissioned or contractual processing.

We process data that are necessary for the justification and fulfillment of the contractual services and refer to the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if it is required as part of a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the customer and legal requirements.

In the context of the use of our online services, we may store the IP address and the time of the user action. The storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorized use. In principle, this data will not be transferred to third parties, unless it is necessary for the pursuit of our claims according to Art. 6 para. 1 lit. f. GDPR or there is a legal obligation to do so according to Art. 6 para. 1 lit. c. GDPR.

The deletion of the data takes place when the data is no longer required for the fulfillment of contractual or legal duties of care, as well as for dealing with any warranty and comparable obligations, whereby the necessity of the storage of the data is reviewed every three years; otherwise, the legal requirements for storage apply.

 

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing is based on Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by this processing. The purpose and our interest in the processing is based on the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.

In this context, we disclose or transmit data to the tax authorities, advisors, such as tax consultants or auditors, as well as other authorities and payment service providers.

Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them. We permanently store this data, which is mostly company-related.

 

Business analysis and market research

In order to run our business economically, to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc. In doing so, we process general data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 (1) lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluation, marketing and market research. In doing so, we may take into account the profiles of registered users with details, for example, of the services they have used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the operational economy. These analyses are for us only and are not disclosed externally, unless they are anonymous analyses with summarized values.

If these analyses or profiles are personal, they are deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. In other respects, the macroeconomic analyses and general trend determinations are prepared anonymously whenever possible.

 

Microsoft Cloud Services

We use the cloud and cloud software services offered by Microsoft (so-called Software as a Service, e.g. Microsoft Office) for the following purposes: document storage and management, calendar management, sending emails, spreadsheets and presentations, exchanging documents, content and information with certain recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, the personal data of users are processed to the extent that they become part of the documents and content processed within the services described or are part of communication processes. This may include, for example, general data and contact data of users, data on transactions, contracts, other processes and their contents. Microsoft also processes usage data and metadata that Microsoft uses for security and service optimization purposes.

In the course of using publicly available documents, web pages or other content, Microsoft may store cookies on users’ computers for purposes of web analytics or to remember users’ preferences.

We use Microsoft cloud services based on our legitimate interests according to Art. 6 (1) lit. f GDPR in efficient and secure administration and collaboration processes. Furthermore, the processing is carried out on the basis of an order processing agreement with Microsoft.

For more information, see Microsoft’s privacy policy (https://privacy.microsoft.com/de-de/privacystatement) and Microsoft’s cloud services security notice (https://www.microsoft.com/de-de/trustcenter). You can object to the processing of your data in the Microsoft Cloud in accordance with legal requirements. Additionally, the deletion of data within Microsoft’s cloud services is determined by other processes in the context of which the data are processed (e.g. deletion of data no longer required for contractual purposes or storage of data required for taxation).

Microsoft Cloud Services are provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. Insofar as processing of data takes place in the USA, we refer to Microsoft’s certification under the Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAKandstatus=Active).

 

Data protection information in the application process

We process applicant data only for the purpose of and within the scope of the application process in accordance with legal requirements. Applicant data is processed to fulfill our (pre)contractual obligations within the scope of the application process and the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR, insofar as data processing becomes necessary for us, e.g. within the scope of legal proceedings (in Germany, § 26 BDSG also applies).

The application process requires applicants to provide us with information. The necessary applicant data are marked, if we offer an online form, otherwise result from the job descriptions and basically include the personal information, postal and contact addresses and the documents belonging to the application, such as cover letter, resume and certificates. In addition, applicants may voluntarily provide us with additional information.

By submitting the application to us, the applicants consent to the processing of their data for the purposes of the application process in accordance with the nature and scope from this privacy policy.

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily submitted within the scope of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a GDPR (e.g. health data if required for professional activity).

If provided, applicants may submit their applications to us using an online form on our website. The data is transmitted to us encrypted according to the state of the art.
Furthermore, applicants can send us their applications via email. Please note, however, that emails are generally not encrypted and applicants must ensure that they are encrypted on their side. We cannot take any responsibility for the communication path of the application between the sender and the reception on our server, and therefore rather recommend to use an online form or postal delivery. Instead of applying via the online form and email, applicants still have the option of sending us their application by regular mail.

The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Subject to a justified withdrawal by the applicant, the data will be deleted after the expiration of a period of six months so that we can answer any follow-up questions about the application and satisfy our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

 

Contact

When contacting us (e.g. via contact form, email, telephone or social media), the user’s details are processed for the purpose of handling the contact request and processing takes place according to Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) GDPR. User information may be stored in a customer relationship management system (“CRM System”) or a similar system.

We delete the requests if they are no longer necessary. We review this necessity every two years; Furthermore, the legal requirements for archiving apply.

 

Hosting and emailing

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email sending, security services and technical maintenance services, which we use for the purpose of operating our online offer.

In doing so, we or our hosting provider process general data, contact data, content data, contract data, usage data, metadata and communication data of customers, interested parties and visitors of our online offer on the basis of our legitimate interests in an efficient and secure provision of the online offer according to Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing agreement).

 

Integration of third-party services and content

Within our online offer, we use content or service offers of third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) in order to integrate their content and services, such as videos or fonts (hereinafter referred to as “content”).

This always assumes that the third-party providers of this content are aware of the IP address of the user, since without the IP address they would not be able to send content to a browser. Thus, the IP address is required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. These “pixel tags” can be used to evaluate information such as visitor traffic on the website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.

 

Youtube

We embed the videos of the platform “YouTube” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

 

Google Maps

We embed the maps of the service “Google Maps” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, in particular, IP addresses and location data of the users, however they are not collected without consent (usually controlled in the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Created with “Datenschutz-Generator.de” by the lawyer Dr. Thomas Schwenke