Thank you for visiting our website. Compliance with the data protection regulations is important for us. This data protection declaration clarifies the type, scope and purpose of the processing of personal data within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile.
1. Responsible Body
This website and its services are provided by:
Lichtenbergstraße 8 (GATE)
85748 Garching bei München
Managing Directors: Artem Kuchukov, Uwe Braun
The development of the website was conceptualized with the maxim to collect as little data as possible from you. It is also possible to visit our website without providing personal information. Only when you choose to use certain services (such as the contact form) will the processing of personal data become necessary. When doing so, we always take care to process your personal data only in accordance with the legal regulations or your consent. We comply with the provisions of the General Data Protection Regulation (GDPR) applicable from 25.5.2018 and the applicable national regulations, such as the German Federal Data Protection Act, the German Teleservices Act or other more specific data protection laws.
“Personal data” means any information relating to an identified or identifiable natural person (‘the data subject’); a natural person is considered as being identifiable, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics expressing the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person;
“Processing” means any operation or series of operations performed with or without the aid of automated processes, such as collecting, organizing, storing, adapting or modifying, reading, querying, disclosure by submission, dissemination or any other form of provision, reconciliation or association, restriction, erasure or destruction;
“Restriction of processing” means the marking of stored personal data in order to limit its future processing;
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data cannot be assigned to an identified or identifiable natural person;
“Controller” means the natural or legal person, public authority, body or other party that alone or jointly with others decides on the purposes and means of processing personal data; where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or, as the case may be, the specific criteria of his appointment may be provided for under Union or national law;
“Processor” means a natural or legal person, public authority, body or party that processes personal data on behalf of the controller;
“Recipient” means a natural or legal person, public authority, agency or other entity to whom personal data are disclosed, whether or not it is a third party. However, authorities which may receive personal data under Union or national law in connection with a particular mission are not considered to be recipients; the processing of such data by the said authorities shall be in accordance with the applicable data protection rules in accordance with the purposes of the processing;
“Third party” means a natural or legal person, public authority, institution or body other than the data subject, the controller, the processor and the persons authorized under the direct responsibility of the controller or processor to process the personal data;
“Consent” of the data subject means any expression of will, in an informed and unambiguous manner, in the form of a statement or other unambiguous confirmatory act by which the data subject expresses his approval of the processing of the personal data concerning him.
In part, when you visit our website, we collect certain personal data for which we require your consent. This happens, for example, if you send us a message via our contact forms.
Declaration of Consent
5. Purpose and Legal Basis of the Processing of Personal Data
Personal data required for the establishment, implementation or processing of our services is processed on the legal basis of Art. 6 para. 1 lit. b DSGVO. Insofar as we use external service providers in the context of order data processing, processing is based on the legal basis of Art. 28 DSGVO.
The personal data are collected, processed and used by us exclusively for the following purposes:
– Provision of the online offer, its functions and contents – Legal Basis for Data Processing: Based on your consent
– Answering contact requests and communicating with users – Legal Basis for Data Processing: Based on your consent
– Marketing – Legal Basis for Data Processing: Based on your consent
– To improve our website – Legal Basis for Data Processing: Based on your consent
– For the technical realization of our offers – Legal Basis for Data Processing: Due to Legitimate Interests
6. Collected and processed personal data
We collect and process your personal data only if you voluntarily, under your knowledge, make it available, e.g. by filling out forms or sending e-mails. In the context of the available forms, these are first of all the following data:
General contact details:
The personal data you provide, and its contents remain solely with us and our affiliates. We will store and process your data only for the purposes stated in 5. Any use exceeding the stated purpose requires your express consent. The same applies to the transmission and transfer of your data to third parties.
7. General Log Files
The web server temporarily records the connection data of the requesting computer (IP address), the pages you visit with us, the date and duration of the visit, the recognition data of the browser and operating system type used, the website from which you visit us and the successful retrieval in log files. The technical administration of the websites and anonymous statistical surveys allow an evaluation of the access to the offer of KEWAZO and an evaluation with the aim to increase the data protection and data security in our company in order to ensure an optimal level of protection for the personal data processed by us. The data of the server log files are stored separately from all personal data provided by you.
Subject to any legal retention requirements, we will delete or anonymize your IP address after you leave our website.
On our website, information is collected and stored by the use of so-called browser cookies.
What are Cookies?
These are small text files that are stored on your device and that store certain settings and data in order to share it with our system through your browser. A cookie usually contains the name of the domain from which the cookie data was sent, as well as information about the age of the cookie and an alphanumeric identifier.
Cookies allow our systems to recognize the user’s device and make any presets available immediately. As soon as a user accesses the platform, a cookie is transmitted to the hard disk of the user’s computer. Cookies help us improve our website and offer you a better and more personalized service. They enable us to recognize your computer or your (mobile) device when you return to our website and thereby:
Store information about your favourite activities on the website, thus tailoring our website to your individual interests.
Accelerate the speed of processing your requests.
We work with third party services that help us to make the website and its offers more interesting to you. Therefore, when visiting the website, cookies from these partner companies (third-party providers) will also be stored on your hard drive. These are cookies that automatically delete after the given time. A list of the cookies we set can be found in the following table:
If you do not wish to use browser cookies, you can set your browser so that the storage of cookies is not accepted. Please note that in this case you may be able to use our website only partially or not at all. If you only want to accept our own cookies, but not the cookies of our service providers and partners, you can choose the setting in your browser "block third-party cookies". We assume no responsibility for the use of third-party cookies.
9. Integration of Services and Content of Third Parties
Our website uses content and services of third parties. In order for these data to be accessed and displayed in the user’s browser, the transmission of the IP address is absolutely necessary. The providers (hereinafter referred to as "third-party providers") thus are aware of the IP address of the respective user.
Although we strive to use only third-party providers who solely need the IP address to deliver content, we have no control over whether the IP address may be stored. This process might be used, inter alia, for statistical purposes. If we become aware that the IP address is being stored, we will inform you.
Use of Google Analytics
Our website uses functions of the web analytics service Google Analytics. Web analytics service provider is Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.
Google Analytics uses "cookies". These are small text files that your web browser stores on your device and that allow for an analysis of website usage. Information generated by cookies about your use of our website is transmitted to a Google server and stored there. Server location is usually the US.
Google Analytics cookies are set on the basis of Art. 6 para. 1 lit. f DSGVO. As the operator of this website, we have a legitimate interest in the analysis of user behaviour in order to optimize our website and possibly also advertising.
We use Google Analytics in conjunction with the IP anonymization feature. It ensures that Google shortens your IP address within member states of the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. There may be exceptions where Google transmits the full IP address to a server in the United States and truncates it there. Google will use this information on our behalf to evaluate your use of the website, to report on website activity, and to provide us with other services related to website activity and internet usage. There is no merger of the Google Analytics transmitted IP address with other Google data.
The setting of cookies through your web browser can be prevented. However, some features of our website may be restricted. Likewise, you can prevent the collection of data relating to your website use, including your IP address and subsequent processing by Google. This is possible by downloading and installing the browser plug-in accessible via this link.
To fully comply with legal data protection requirements, we have entered into a contract data processing agreement with Google.
Our website uses the demographics feature of Google Analytics. It can be used to generate reports that contain statements on the age, gender and interests of the site visitors. This data comes from interest-based advertising from Google and third-party visitor data. An assignment of the data to a specific person is not possible. You can disable this feature at any time. This is possible through the ad settings in your Google Account or by generally prohibiting the collection of your data by Google Analytics, as explained in the section "Objection to data collection". Alternatively, you can opt out of Google Analytics using an opt-out cookie by clicking here. If you delete the cookies in your browser, you must click this link again.
Use of YouTube
For the integration and presentation of video content, our website uses plugins from the Google-powered YouTube page. Provider of the video portal is the YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. When you visit a page with an integrated YouTube plug-in, it will connect to YouTube’s servers.
YouTube will find out which of our sites you’ve visited. YouTube can directly map your browsing behaviour to your personal profile, should you be logged into your YouTube account. By logging out beforehand you have the option to prevent this.
The use of YouTube is in the interest of an attractive presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
Use of Google Maps
For the integration and presentation of map content, our website uses the map service Google Maps. Provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Viewing a Google Maps integrated map page will track your IP address. This information is usually transmitted to and stored on a Google server in the United States. Google will know your IP address, even if there is no user account you are logged in to. If you are logged into your user account, Google can assign your surfing behaviour directly to your personal profile. By logging out beforehand you have the option of preventing this. The provider of this site has no influence on this data transfer. The use of Google Maps is in the interest of an attractive presentation of our online offers and an easy findability of the places we have indicated on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
Use of CRM system from HubSpot
We use the CRM system of the provider HubSpot, Inc.,25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA, in order to be able to process user inquiries faster and more efficiently (justified interest according to Art. 6 Para. 1 lit. f. GDPR).
HubSpot is certified under the Privacy Shield Agreement and thus offers an additional guarantee to comply with European data protection law if data is processed in the USA (https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG&status=Active).
HubSpot uses the data of the users only for the technical processing of the inquiries and does not pass them on to third parties. In order to use HubSpot, at least a correct e‑mail address must be provided. A pseudonymous use is possible. In the course of processing service requests, it may be necessary to collect further data (name, address).
If users do not agree with data collection and data storage in HubSpot’s external system, we offer them alternative contact options for submitting service requests by e‑mail, telephone, fax or post.
Users can find further information in HubSpot’s data protection declaration: https://legal.hubspot.com/privacy-policy?_ga=2.95735381.874544115.1542714681–1896463202.1530616708
Use of Facebook Social Plugins
On the basis of our legitimate interests (i.e., interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Civil Code), we make use of the information provided on this website. GDPR) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g., videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on a blue tile, the terms “like”, “like” or a “thumb up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online service that contains such a plugin, his device establishes a direct connection with Facebook’s servers. The content of the plugin is transmitted directly from Facebook to the user’s device and integrated into the online service by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the user according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by clicking the Like button or commenting, the corresponding information is transferred directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his IP address and save it. According to Facebook, only an anonymous IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the relevant rights and setting options to protect the privacy of users can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about him or her via this online service and link it to the member data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.
Use of Twitter
10. Data Security
Unfortunately, the transmission of information over the Internet is never 100% secure, which is why we cannot guarantee the security of data transmitted via the Internet to our website.
However, we secure our website through technical and organizational measures against loss, destruction, access, modification or dissemination of your data by unauthorized persons.
In particular, your personal data is encrypted with us. We use the SSL / TLS (Secure Sockets Layer / Transport Layer Security) coding system. Our security measures are continuously improved in line with technological developments.
You can contact us by e-mail or via our contact form. In this case, we will store the personal data you provide to process your request and to contact you with respect to your request. These data will be transmitted to us on a purely voluntary basis. A passing on of the personal data communicated to us in this way to third parties does not take place.
12. Rights of the data subject
Insofar as you are the affected person according to Art. 4 No. 1 DSGVO, you have the following rights regarding the processing of your personal data under the GDPR. The EU regulation text that these rights are based on can be found here.
Right to Confirmation and Information
Under the preconditions of Art. 15 DSGVO you have the right to request a confirmation as to whether personal data of you are being processed and at any time, free of charge, to receive information from the controller regarding the personal data stored about you and a copy of these data.
Right to Rectification
Under the conditions of Art. 16 DSGVO you have the right to demand the immediate correction of incorrect personal data concerning you. In addition, you have the right, under consideration of the purposes of the processing, to demand the completion of incomplete personal data, also by means of a supplementary declaration.
Right of Deletion
Under the preconditions of Art. 17 GDPR, you have the right to demand that personal data concerning you be deleted without delay, provided that one of the reasons stated in Art. 17 GDPR exists and the processing is not required.
Right to Restriction of Processing
Under the conditions of Art. 18 GDPR, you have the right to demand the restriction of processing if one of the conditions set out in Art. 18 GDPR exists.
Right to Data Portability
Under the conditions of Art. 20 GDPR, you have the right to receive the personal data you have provided us in a structured, common and machine-readable format, and you have the right to transfer this data to another person without hindrance provided that the further requirements of Article 20 GDPR are met.
Right to Revoke Consent
You have the right to withdraw your consent to the processing of personal data at any time with future effect. The revocation should be directed to the above contact details.
Right of Objection
Under the conditions of Art. 21 GDPR you have the right to object at any time to the processing of your personal data. If the conditions for an effective contradiction exist, we may no longer process them.
Right of Appeal to a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data is violating the requirements of the DSGVO.
13. Disclosure of your Personal Data
The transfer of your personal data takes place as described below.
In addition, disclosure shall take place if we are entitled or obliged to forward data due to statutory provisions and / or official or judicial orders. This may, in particular, be the provision of information for law enforcement purposes, security or enforcement of intellectual property rights.
Insofar as your data is passed on to service providers to the required extent, they will only have access to your personal data to the extent necessary to fulfil their duties. These service providers are obliged to treat your personal data in accordance with the applicable data protection laws, in particular the GDPR.
In addition to the aforementioned circumstances, we will not transmit your data without your consent to third parties. In particular, we do not share personally identifiable information with any third country or international organization.
14. Storage Period for the Personal Data
With regard to the storage period, we delete personal data as soon as their storage is no longer necessary for the fulfilment of the original purpose and there are no longer any statutory retention periods. The statutory retention periods ultimately form the criterion for the final duration of the storage of personal data. After the deadline, the corresponding data will be routinely deleted. If retention periods exist, processing is restricted by blocking the data.
15. References and Links
Third party service providers may have different and separate terms in dealing with the collection, processing and use of personal data. It is therefore advised to check the websites of third parties about their practice for the handling of personal data before entering personal data.
17. Data Protection Officer
If you have data protection questions, please contact our data protection officer.
18. Data protection information in the application process
We process the applicant data only for the purpose and within the framework of the application procedure in accordance with the legal requirements. The processing of the applicant data is carried out to fulfil our (pre)contractual obligations within the scope of the application procedure in the sense 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 framework of legal proceedings (in Germany, § 26 BDSG additionally applies).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise it results from the job descriptions and basically includes the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.
By submitting their application to us, applicants consent to the processing of their data for the purposes of the application procedure in accordance with the type and scope set out in this data protection declaration.
If special categories of personal data within the meaning of Art. 9 Para. 1 GDPR are voluntarily provided as part of the application process, they will also be processed in accordance with Art. 9 Para. 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 para. 1 GDPR are requested from applicants as part of the application procedure, their processing will also be carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data if they are required for the exercise of a profession).
If provided, applicants can submit their applications via an online form on our website. 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 are generally not sent in encrypted form and the applicants themselves must ensure that they are encrypted. We therefore cannot assume any responsibility for the transmission path of the application between the sender and the reception on our server and therefore recommend using an online form or postal dispatch. Instead of applying using the online form and e‑mail, applicants still have the option of sending their application by post.
In the event of a successful application, the data provided by the applicants can 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. Applicant data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Subject to justified revocation by the applicants, the data will be deleted after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with the provisions of tax law.
As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent as defined in Art. 6 Para. 1 lit. b. and Art. 7 GDPR.
The application documents in the talent pool will be processed solely within the framework of future job advertisements and the employee search and will be destroyed at the latest after expiry of the deadline. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application procedure and that they can revoke this consent at any time for the future and declare objections within the meaning of Art. 21 GDPR.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
Content of the newsletter
We send newsletters, e‑mails and other electronic notifications containing advertising information (hereinafter referred to as “newsletter”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
Double-Opt-In and logging
The registration to our newsletter takes place in a so-called Double-Opt-In procedure. I.e., after registration you will receive an e‑mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody 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 the storage of the registration and confirmation time, as well as the IP address. Likewise, the changes of your data stored with the shipment service provider are logged.
To subscribe to the newsletter, it is sufficient to enter your e‑mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of addressing you personally.
The dispatch of the newsletter and the performance measurement associated with it are based on the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 Para. 2 No. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing in accordance with Art. 6 Para. 1 lt. f. GDPR in connection with § 7 Abs. 3 UWG.
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e‑mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
The newsletter is sent using "MailChimp", a newsletter sending platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
The email addresses of our newsletter recipients, as well as their other data described in the context of this notice, are stored on MailChimp's servers in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, MailChimp may use this data to optimize or improve its own services, e.g., to technically optimize the dispatch and display of the newsletters or for economic purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them or to pass them on to third parties.
Statistical collection and analyses
The newsletters contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. As part 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 initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times.
The statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our endeavour nor that of MailChimp to observe individual users. 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.
Online retrieval and data management
Legal basis Data Protection Regulation
In accordance with the requirements of the Basic Data Protection Regulation (DSGVO) applicable as of May 25, 2018, we inform you that the consent to the sending of e-mail addresses is based on Art. 6 Para. 1 lit. a, 7 DSGVO as well as § 7 Para. 2 No. 3, or Para. 3 UWG. The use of the dispatch service provider MailChimp, implementation of statistical surveys and analyses as well as logging of the registration process, are carried out on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users.
We would also like to point out that you can object to the future processing of your personal data in accordance with the legal requirements pursuant to Art. 21 DSGVO at any time. The objection can be made in particular against the processing for purposes of direct advertising.