Privacy Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").

The terms used are not gender-specific.

Last Update: 6. March 2025

  

Table of contents

A. General information

• Controller
• Contact information of the data protection officer
• Overview of processing operations
• Legal Bases for the Processing
• Security Precautions
• Transmission of Personal Data
• Data Processing in Third Countries
• Erasure of data

B. Data collection when using this website

• Use of Cookies
• Provision of online services and web hosting
• Newsletter and Electronic Communications
• Direct marketing
• Contact and demo request/ download request
• Job Application Process
• Profiles in Social Networks (Social Media)
• Processing of personal data at events

C. Web Analysis, Monitoring and Optimization

• Google Analytics
• Google Ads
• Google Remarketing
• Google Conversion-Tracking
• Google Maps
• SalesViewer
• Changes and Updates to the Privacy Policy
• Rights of Data Subjects
• Terminology and Definitions

 

A. General information

Controller

Com In GmbH & Co. KG
Consulting + Solutions
Graf-Schack-Allee 11
19053 Schwerin

Vertretungsberechtigte Personen: Herr Torsten Hecht

E-Mail-Adresse: info@comin.de

Contact information of the data protection officer

datenschutz@comin.de

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

• Inventory data.
• Contact data.
• Content data.
• Usage data.
• Meta, communication and process data.
• Job applicant details.

Special Categories of Data

• Health Data.

Categories of Data Subjects

• Communication partner.
• Users.
• Job applicants.
  
  

Purposes of Processing

• Contact requests and communication.
• Security measures.
• Direct marketing.
• Web Analytics.
• Targeting.
• Conversion tracking.
• Managing and responding to inquiries.
• Job Application Process.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online services and usability.
• Information technology infrastructure.

 

Legal Bases for the Processing

Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

• Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legitimate Interests (Article 6 (1) (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller 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.
• Job application process as a pre-contractual or contractual relationship (Article 6 (1)(b) GDPR) - If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(c) GDPR  or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.

In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states may apply.

 

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.

TLS encryption (https): To protect your data transmitted via our online services, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

 

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

 

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission or if certifications or binding internal data protection regulations justify the processing (Article 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

We would like to point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.

 

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Statutory retention obligations arise, for example, from § 257 para. 1 HGB (6 years for trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and from § 147 para. 1 AO (10 years for books, records, management reports, accounting documents, commercial and business letters, tax-relevant documents, etc.).

Our further information on individual processing operations may also contain additional and specific information on data retention and erasure applicable to the respective processing operations.

 

B. Data collection when using this website

 

Use of Cookies

Cookies are small text files or other data records that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the contents accessed or the functions used. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Information on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is strictly necessary in order to provide an information society service explicitly requested by the subscriber or user. Essential cookies usually include cookies with functions related to the display and operability of the onlineservice, load balancing, security, storage of users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the onlineservice requested by users. The revocable consent will be clearly communicated to the user and will contain the information on the respective cookie use.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the use of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online services and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For which purposes the cookies are processed by us, we do clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Retention period: With regard to the retention period, a distinction is drawn between the following types of cookies:

• Temporary cookies (also known as "session cookies"): Temporary cookies are deleted at the latest after a user has left an online service and closed his or her end device (i.e. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Article 21 GDPR. Users can also declare their objection by means of the settings of their browser, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes, can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

• Processing Cookie Data on the Basis of Consent: We use a cookie management solution in which users' consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user or and/or his/her device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and used end device; Legal Basis: Consent (Article 6 (1) (a) GDPR).

 

Provision of online services and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.

• Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of Processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).); Security measures.
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

We use the host provider 1&1 IONOS SE (1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany) to operate this website; in addition, various landing pages and our blog are hosted by HubSpot Ireland Ltd, One Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland (US parent company HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA). This is done on our behalf and on the basis of our legitimate interests in the efficient and secure provision of this website metadata and communication data of the users of this website in accordance with Art. 6 para. 1 sentence 1 lit. f), Art. 28 GDPR.

Further information on processing methods, procedures and services used:

Collection of Access Data and Log Files: The access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider.The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

 

Newsletter and Electronic Communications

We send newsletters, e-mails and other electronic communications (hereinafter referred to as "newsletters") only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and our company as well as events tailored to the interests of users.

In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.

Double opt-in procedure: The registration to our newsletter takes place in general in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with external e-mail addresses.

The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address solely for this purpose in a blocklist.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, promotions and offers.

• Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Usage data (e.g. websites visited, interest in content, access times).
• Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services).
• Purposes of Processing: Direct marketing (e.g. by e-mail or postal); Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles).
• Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).
• Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing methods, procedures and services used:

• Measurement of opening rates and click rates: The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file, which is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from its server. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected. This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until the profiles are deleted. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening rates and click rates as well as the storage of the measurement results in the profiles of the users and their further processing are based on the consent of the users. A separate objection to the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
• Google Analytics: Measuring the success of email campaigns and building user profiles with a storage period of up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://business.safety.google/adsprocessorterms; Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated; Further Information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
• The data is processed for the duration of the subscription within an electronic newsletter system. We use the service provider HubSpot for this purpose and for sending the newsletter. This is operated by HubSpot Ireland Ltd, One Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland (with the US parent company HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA) and processes the data on our behalf. It cannot be ruled out that HubSpot Ireland Ltd. transmits personal data to its US parent company; insofar as HubSpot in the USA has joined the EU-US Data Privacy Framework (so-called “DPF”) and is certified, the transmission is based on the corresponding adequacy decision of the European Commission. This certification confirms that the data protection requirements are complied with. If such certification is not or not yet available, the transfer of data is temporarily based on the EU standard contractual clauses to ensure an adequate level of data protection.
  Detailed information on HubSpot's privacy policy can be found at: https://legal.hubspot.com/privacy-policy.

As the processing of the data is based on the consent of the data subject, the data subject has the right to withdraw this consent at any time with effect for the future or to object to the processing for the purpose of sending the newsletter. In such a case, the data subject will be removed from our mailing list immediately. The revocation can be made either by e-mail to our data protection officer or via the unsubscribe link contained in every advertising or newsletter e-mail. So that we can correctly allocate the revocation, we ask you to indicate which data the unsubscription relates to.

 

Direct marketing

Com In has a legitimate interest in direct marketing in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR (Recital 47 GDPR). We therefore reserve the right to send our customers - i.e. persons with whom we have a business relationship - advertising by email or post. This may include, for example, information about our company, upcoming events or invitations to evaluate our products and services.

We use the service provider HubSpot to send these messages. This is operated by HubSpot Ireland Ltd, One Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland, and processes the data on our behalf. The US parent company of HubSpot, HubSpot, Inc. has its registered office at 25 First Street, 2nd Floor, Cambridge, MA 02141, USA.

It is possible that HubSpot Ireland Ltd. transfers personal data to its parent company in the USA. If HubSpot is certified under the EU-US Data Privacy Framework (DPF), the data will be transferred on the basis of the corresponding adequacy decision of the European Commission. This certification confirms compliance with the required data protection standards. If such certification is not or not yet available, data will be transferred during the transition period on the basis of the EU standard contractual clauses to ensure an adequate level of data protection.

Further information on HubSpot's privacy policy can be found here: https://legal.hubspot.com/privacy-policy.

Data subjects have the option of objecting to the sending of advertising messages at any time. This can be done either by sending an email to our data protection officer or via the unsubscribe link in an advertising email. In order to be able to correctly assign the objection, we recommend sending the e-mail from the address that was used during registration.

 

Contact and demo request, download request

You have the option of contacting us by e-mail, telephone or our contact form using the contact details provided on our website in order to request a demo or download or to contact us in any other way.

To process your request, we process your name, your email address, your gender, the company name, your telephone number and the content of your message, insofar as this information is required for the provision of the demo/download or the processing of your contact requests or the preparation of an offer. This data is processed either on the basis of our legitimate interest in efficient customer service in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR or, if the request is related to contractual obligations, in accordance with Art. 6 para. 1 sentence 1 lit. b) GDPR.

For our contact forms, we use the “HubSpot” component of HubSpot Ireland Ltd, One Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland (with the US parent company HubSpot, Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141, USA). In this context, we have concluded an order processing agreement with HubSpot, which obliges HubSpot to process personal data exclusively in accordance with our instructions. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f) GDPR, based on our legitimate interest in the fast and efficient processing of inquiries.

We would like to point out that it cannot be ruled out that HubSpot Ireland Ltd. transfers personal data to the US parent company HubSpot, Inc. If HubSpot in the USA participates in the EU-US Data Privacy Framework (DPF) and is certified accordingly, the data transfer is based on the adequacy decision of the European Commission. This certification confirms that HubSpot complies with the required data protection standards. If such certification is not available, the transfer will be based on the EU standard contractual clauses during a transitional period to ensure an adequate level of data protection.

Further details on HubSpot's privacy policy can be found at: https://legal.hubspot.com/privacy-policy.

If a business relationship exists or a business relationship is initiated based on previous communication, your request and your contact details may be stored in a customer relationship management system (CRM).

We use the CRM system “HubSpot” from HubSpot Ireland Ltd, One Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland (with the US parent company HubSpot, Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141, USA). Here, too, we have concluded an order processing agreement with HubSpot, which ensures the processing of data in accordance with our instructions. The processing is based on Art. 6 para. 1 sentence 1 lit. f) GDPR and is carried out in our legitimate economic interest in being able to systematically manage customer and prospect data.

If there is no further need for storage and there are no statutory retention obligations to the contrary, the data will be deleted.

There is also the possibility that HubSpot Ireland Ltd. will transfer personal data to the US parent company. If HubSpot is certified under the EU-US Data Privacy Framework, data will be transferred in accordance with the European Commission's adequacy decision. Otherwise, the EU standard contractual clauses will apply during the transition period to ensure an adequate level of data protection.

Initiative Contact for business purposes: We process personal data (e.g. name, business email address, position and company affiliation) in order to contact potential business partners as part of our business activities.
Processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest lies in direct advertising for our products and services that may be of interest to the persons contacted in a professional context. Contact is made exclusively to business email addresses and in relation to topics relevant to the company.
Data subjects have the right to object to the processing of their data for advertising purposes at any time in accordance with Art. 21 GDPR. A corresponding objection can be made informally by e-mail to “datenschutz@comin.de”.

 

Job Application Process

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information contained therein.

In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.

For our application management system, we use the “Personio” software from Personio SE & Co. KG, Rundfunkplatz 4, 80335 Munich, Germany, for our application management system. The Personio careers page is integrated via an iFrame on our website. If you apply for a job using the online form, your personal data will be processed directly in Personio. Personio SE & Co. KG processes the applicant data on our behalf in accordance with Art. 28 GDPR (order processing). This may involve the transfer of personal data to Personio servers within the EU. No data will be passed on to third parties without your express consent. (For more information on the processing of personal data through the online application process, see also https://comin.jobs.personio.de/privacy-policy)

If made available, applicants can submit their applications via an online form. The data will be transmitted to us encrypted according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and the reception on our server. For the purposes of searching for applicants, submitting applications and selecting applicants, we may make use of the applicant management and recruitment software, platforms and services of third-party providers in compliance with legal requirements. Applicants are welcome to contact us about how to submit their application or send it to us by regular mail.

Processing of special categories of data: This data is processed for the purpose of processing your application and carrying out the selection procedure. The legal basis for the processing is Art. 6 para. 1 lit. b GDPR (implementation of pre-contractual measures) and Art. 6 para. 1 lit. f GDPR (legitimate interest in efficient applicant management).
If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can exercise his/her rights arising from labour law and social security and social protection law and fulfil his/her duties in this regard, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Article 9 (2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(h) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.

Ereasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' data will also be deleted if an application is withdrawn, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, the deletion will take place at the latest after the expiry of a period of six months, so that we can answer any follow-up questions regarding the application and comply with our duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Admission to a talent pool - Admission to an talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

• Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
• Data subjects: Job applicants.
• Purposes of Processing: Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship).
• Legal Basis: Job application process as a pre-contractual or contractual relationship (Article 6 (1)(b) GDPR).

 

Profiles in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

Unless otherwise stated, your data is processed on the basis of our legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. Our aim is to optimize our offering and provide you with a more user-friendly experience. These objectives correspond to our legitimate interests. When integrating social media content that uses cookies, this is done on the basis of your consent in accordance with Art. 6 (1) p. 1 lit. a), Art. 7 GDPR. You have the right to withdraw this consent at any time and to adjust your cookie preferences (e.g. delete or block cookies). The processed data will only be stored for the required period or in accordance with legal requirements.

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

• Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of Processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

 

Links to social media platforms

Our website contains links to our presence on various social networks. These are integrated as linked graphics of the respective platforms. When you visit our website, no automatic connection to the servers of the networks is established. You will only be redirected to the respective social network when you click on the corresponding graphic.

After forwarding, the respective network collects certain information. It is possible that this data will be processed in the USA.

The data collected primarily includes the IP address, date, time and the page visited. If you are logged into your user account on the respective network, the operator may be able to assign the information collected to your personal profile. Interactions such as the use of “share” or “like” functions can be stored in your personal account and possibly published. To avoid a direct assignment to your user account, you should log out before clicking on the graphic or the corresponding button.

For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

Further information on processing methods, procedures and services used:

• LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement: https://legal.linkedin.com/dpa; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://legal.linkedin.com/dpa; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Each time you access a page on this website that contains LinkedIn functions, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited this website with your IP address. If you click on the LinkedIn “Recommend” button and are logged into your LinkedIn account, LinkedIn will be able to associate your visit to this website with you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn.

• Facebook: Profiles within the social network Facebook - We are jointly responsible (so called "joint controller") with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see "Things that you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How we use this information?" Facebook also collects and uses information to provide analytics services, known as "page insights," to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook ("Information about Page-Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Subsidiary of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further Information: Joint Controllership Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
• Xing: Each time one of our pages containing XING functions is accessed, a connection to XING servers is established. To the best of our knowledge, no personal data is stored in the process. In particular, no IP addresses are stored or usage behavior evaluated.
  Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.xing.com; Privacy Policy: https://privacy.xing.com/en.

 

Processing of personal data at events

When you participate in one of our events, we collect and process your personal data. This includes, among other things

• Name
• your address
• company name
• telephone number
• Country
• E-mail address
• Job title
• f applicable: Photos and video recordings that will be made of you during the event

The collection and processing of this data serves the planning and execution of the event as well as the fulfillment of contractual obligations in order to enable you to participate. If necessary, we will pass on your data to cooperation partners who support us with the organization - for example, external service providers for guest management or the operators of the event venues. In addition, your details (e.g. name and company affiliation) may be passed on to moderators, agencies or event partners if this is necessary for the running of the event. After the event, we will use your data to provide you with relevant materials.

Photo and video recordings: Photos and videos are regularly taken at our events. These may be published on our website, on social media channels, in internal and external reports and in our newsletters. In some cases, this may also be done in connection with your name. In addition to the image and video recordings, the cameras used automatically record metadata such as recording time and location. The legal basis for the creation and storage of these recordings results from our legitimate interest in documenting the event and promoting similar events. The recordings are published on the basis of Sections 22 and 23 of the German Art Copyright Act (KUG) or with your express consent.

You have the option to object to the recording and storage of photos or videos at any time. Please inform the photographer on site or send an email to datenschutz@comin.de.

Please note that external reporters may also be present at our events to take photos and videos. As we have no influence on their recordings and the further processing of this data, we cannot provide any detailed information on this.

 

C. Web Analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

• Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Provision of our online services and usability.
• Security measures: IP Masking (Pseudonymization of the IP address).
• Legal Basis: Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

 

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of this service, the usage behavior of website visitors can be analyzed. Various data is collected, including the number of page views, the time spent on the site, the operating system used and the origin of the users. This information may be merged by Google into a user profile and assigned to a specific end device.

Google Analytics uses technologies such as cookies or device fingerprinting to recognize users and analyse their behaviour. The information collected about the use of the website is usually transferred to a Google server in the USA and stored there.

Google Analytics: Web analytics, reach measurement and measurement of user traffic; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR) as there is a legitimate interest in the evaluation of user behavior in order to optimize the website and advertising measures; GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://business.safety.google/adsprocessorterms; Opt-Out: You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated; Further Information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed). You can find more information on how Google Analytics handles user data in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

 

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms into Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on the user data available at Google (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively, for example by analyzing which search terms led to the display of our advertisements and how many advertisements led to corresponding clicks. The use of Google Ads is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in marketing its products and services as effectively as possible.

 

Google Remarketing

This website uses the functions of Google Analytics Remarketing. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Remarketing analyzes your user behavior on our website (e.g. clicks on certain products) in order to classify you into certain advertising target groups and then display suitable advertising messages to you when you visit other online offers (remarketing or retargeting). Furthermore, the advertising target groups created with Google Remarketing can be linked to Google's cross-device functions. In this way, interest-based, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one device (e.g. cell phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have a Google account, you can object to personalized advertising by clicking on the following link:  https://www.google.com/settings/ads/onweb/.

The use of Google Remarketing is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in marketing its products as effectively as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time. Further information and the data protection provisions can be found in Google's privacy policy at: https://policies.google.com/technologies/ads?hl=de.

 

Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of Google conversion tracking, Google and we can recognize whether the user has performed certain actions. For example, we can analyze which buttons on our website were clicked how often and which products were viewed or purchased particularly frequently. This information is used to create conversion statistics. We find out the total number of users who have clicked on our ads and what actions they have taken. We do not receive any information with which we can personally identify the user.

Google itself uses cookies or comparable recognition technologies for identification purposes. The use of Google Conversion Tracking is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time. You can find more information about Google Conversion Tracking in Google's privacy policy: https://policies.google.com/privacy?hl=de.

 

Google Maps

The map service Google Maps is integrated on this website via an API. The service is provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. In order to use the map functions, your IP address must be recorded and stored. As a rule, this data is transferred to a Google server in the USA, where it is stored. We have no influence on this data transfer.

The integration of Google Maps serves to present our online offers in an appealing way and to make the locations indicated on our website easier to find. This constitutes a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. If we obtain your consent to the use of Google Maps, the data processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR. Your consent can be withdrawn at any time.

Further information on the processing of user data by Google can be found in Google's privacy policy: https://policies.google.com/privacy?hl=en.

 

Use of SalesViewer® technology

This website uses SalesViewer® technology from SalesViewer® GmbH on the basis of the website operator’s legitimate interests (Section 6 paragraph 1 lit.f GDPR) in order to collect and save data on marketing, market research and optimisation purposes. In order to do this, a javascript based code, which serves to capture company-related data and according website usage. The data captured using this technology are encrypted in a non-retrievable one-way function (so-called hashing). The data is immediately pseudonymised and is not used to identify website visitors personally. The data stored by Salesviewer® will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. The data recording and storage can be repealed at any time with immediate effect for the future, by clicking on https://www.salesviewer.com/opt-out in order to prevent SalesViewer® from recording your data. In this case, an opt-out cookie for this website is saved on your device. If you delete the cookies in the browser, you will need to click on this link again.

 

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Rights of Data Subjects

As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

• Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right of withdrawal for consents: You have the right to revoke consents at any time.
• Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
• Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
• Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

 

If you wish to exercise your rights under the General Data Protection Regulation (GDPR), you can contact the data controller using the contact details above or contact our data protection officer directly.

Please note that the security of data transmission by email cannot be fully guaranteed. We therefore recommend that you send confidential information preferably by post. Should you nevertheless contact us by e-mail, please use an e-mail address that is linked to our system so that we can clearly assign your identity.

 

Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.

• Controller: "Controller" means 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.
• Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
• 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.
• Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
• Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  No automated decision-making, including profiling, takes place on our website.
• Targeting: "Tracking" is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
• Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.