DEUBLIN welcomes your visit to our website as well as your interest in our company and our products.
Data protection has a high priority for DEUBLIN (hereinafter also referred to as "we", "us"). Therefore, the principle applies: Where personal data is processed, a high level of data protection and data security must be guaranteed. This applies to data from customers, suppliers and business partners as well as employee data.
As a global company we want to comply with the different legal requirements that apply worldwide to the collection and processing of personal data. The European Data Protection Regulation (GDPR) establishes a common European standard supplemented by existing national regulations.
In the following, we will inform you about how we implement this standard within the company.
The use of the Internet pages of DEUBLIN is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to DEUBLIN. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, DEUBLIN has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
Personal Information
For the purpose of this Privacy Policy Statement, "personal information" means information about any identified or identifiable individual. This Privacy Policy Statement only sets forth our policy towards personal information collected through the Site, but does provide some details on other information collected (e.g., through cookies) solely for informational purposes. This Privacy Policy Statement does not apply to personal information collected by or provided to DEUBLIN in connection with the submission of a resume or application for employment with DEUBLIN, which is subject to a separate privacy notice.
Please note that any comments, suggestions or materials provided to us shall be deemed to be of a non-confidential and non-proprietary nature (becoming the property of DEUBLIN upon our receipt of same) and we shall be entitled to use and distribute such comments, suggestions or materials to any other parties and for any other purposes, including, but not limited to, developing and marketing products or services incorporating or based on any such comments, suggestions or materials.
What Personal Information We Collect
In connection with the Site, we only collect personal information from you when you voluntarily provide it to us, such as when you purchase, order or request information about our products and services, subscribe to our e-mail distribution list, create an account or provide us with comments, suggestions or other input. Examples of personal information we collect are:
- contact information (such as name, address, e-mail address and telephone number);
- financial information, such as credit card information provided when purchasing products or services from the Site; and
- unique identifiers, such as account information.
Other automatic, non-personal information we may collect and analyze include: login; password; computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform; purchase history, which we sometimes aggregate with similar information from other customers; the full Uniform Resource Locator (URL) clickstream to, through, and from the Site, including date and time; cookie number; products you viewed or searched for; and the phone number you used to call our 800 number. During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.
We may supplement the information that you provide with information that is received from third parties. Examples of information we receive from other sources include updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily.
The Site is intended for use by individuals over the age of 18. We will not knowingly collect, retain or use personal information from any individual under the age of 18. If you are under the age of 18, you should consult with your parents prior to use or access of the Site.
How We Use Your Personal Information
We may collect personal data with your consent or for purpose that are necessary for DEUBLIN’s legitimate interest in the operation of our business, such as:
- to provide you with timely and reliable services, including shipping of orders, communicating with you and the intended recipient of your orders about the status of a shipment, customer support, account management and billing, verifying credit, customer authentication and related services;
- to develop and maintain our relationship with you, send you information about our company and our relationship with you, and otherwise contact you when necessary;
- to develop and improve our products, services and websites and to advise you about new products and services that may be of interest to you;
- to help diagnose problems with our servers, and to administer the Site;
- to assist law enforcement agencies, to collect outstanding debts, to protect our business interests and the interests of our customers, and to generally meet requirements imposed by law based on our good faith belief of what is necessary to meet the requirements imposed by law; and
- to prevent fraud and to otherwise, in good faith, protect the users of the Site or the public in general.
DEUBLIN does not make decisions that have legal effects on data subjects due solely to automated processing of personal data.
Cookies
A cookie is a small piece of data that a website can send to your browser, which may then be stored on your hard drive so the website can recognize you as you browse between web pages on the website. These cookies may collect the operating system and browser that you are using, and accumulate and report anonymous, statistical information on website usage. We may use cookies to deliver content specific to your interests, to save your information so you don't have to re-enter it each time you visit the Site, to determine the type of information that you are looking for on the Site, to improve the Site and for other purposes. We also may use information about the website you visited immediately prior to the Site to assess the viability of links to the Site that we have created on third party websites.
We do not use cookies to identify or track any personal information other than personal information linked to your browser and IP address, which may be considered personal information in some countries. If you do not wish to have a cookie sent to your browser, you can change the settings on your internet browser to stop it from automatically accepting cookies, or you can exercise choices to opt-out of advertising cookies at www.networkadvertising.org/choices. If you opt not to accept cookies, however, you may not be able to benefit from all features of our Site.
We may use various social media plugins on our Site. When you access a page on our Site containing a plugin, the plugin provider may store a cookie in your browser. We have no control over the scope of the data collected by the provider by means of the plugin. The plugins may provide their hosts with information such as the date and time of your visit to our websites, your IP address, or your browser type. If you are logged into your account with the plugin provider while visiting our websites, the provider may match this information and any data you enter. For the scope of the data collection and further processing of your data by the provider as well as your related rights, please see the privacy policies of the provider.
“Do Not Track” signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked. Our Site operates no differently if these “Do Not Track” signals are enabled or disabled.
When We Disclose Your Personal Information
We may disclose personal information to third parties engaged to assist us in providing products or services to you or to carry out one or more of the purposes described above, such as in connection with shipping products to you.
We reserve the right to cooperate fully with local, state and federal officials in any investigation relating to any personal information (including private electronic communications transmitted on the Site or any other website owned or operated by DEUBLIN) or relating to any purportedly unlawful activities. We may also use and disclose personal information in order to investigate, establish, or enforce our legal rights.
We reserve the right to disclose and transfer personal information to a third party in the event of a proposed or actual sale, merger or other transfer of the assets or shares of DEUBLIN Company or a division thereof, provided that the information does not constitute all or substantially all of the assets being transferred.
How We Protect Your Personal Information
We make commercially reasonable efforts to ensure that personal information collected from you and under our control is protected against loss, misuse, alteration or unauthorized access. Access to your personal information is designed to be restricted to selected DEUBLIN employees or representatives. In addition, we employ reasonable information security techniques, such as firewalls and access control procedures, to protect personal information against loss and unauthorized access.
Should you register for an online account with DEUBLIN, you are responsible for protecting against unauthorized access to your account password and to your computer.
Criminals use various techniques to gather your personal information for use in identity theft, credit fraud and other illegal activities. Our Site is not immune from such attacks. These attempts may be sophisticated in nature and designed to appear that they are requests from companies with which you may have a legitimate relationship. Do not provide your personal information to a third party unless you are certain of that party’s identity. If you are concerned that a third party is trying to obtain your information by impersonating DEUBLIN, please contact DEUBLIN at privacy@deublin.com
Shipping to Third Parties
When personal information is provided to us about the intended recipient of a shipment, we use that information solely for the purposes of processing the shipment and, in some cases, to communicate with the intended recipient to provide information pertaining to the status of the shipment. We rely on our customers to obtain the intended recipient's consent to our use of their personal information for these limited purposes.
Links to Third Party Sites
The Site may offer links to other websites. In addition, you may have visited the Site through a link or a banner advertisement on another website. In such cases, the website you linked from or link to may collect information from people who click on the banner or link. We are not responsible for the privacy practices employed by any other website. We make no guarantees, representations or warranties as to the privacy practices of any other website, including websites that may be reached by links in the Site. After leaving the Site, whether via a link contained on the Site or through the use of your web browser or some other navigational tool, this Privacy Policy Statement is no longer in effect. It is important to familiarize yourself with the privacy policies of other websites before providing them with your personal information.
Data Retention
We store personal data for different periods of time consistent with the purposes for which they were originally collected, as subsequently further authorized, or when required or allowed under applicable law.
Access to Personal Information and Withdrawal of Consent
You may contact us at privacy@deublin.com to request access to or correction or update of your personal information.
For European Union residents, we undertake marketing only with your expressive affirmative consent and in compliance with applicable data privacy laws. EU residents will not be added to the marketing lists unless they have already provided express affirmative consent consistent with applicable data protection laws. For United States residents, we undertake marketing only in compliance with the CAN-SPAM Act, the Telephone Consumer Protection Act, and other applicable law.
You may request to no longer receive future communications from us, and you may withdraw consent to our collection and retention of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent, please contact us at privacy@deublin.com.
If you believe that DEUBLIN may be processing data about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as when only our client or vendor, the data controllers, have the right to provide such access, or if responding to the request would be unreasonably expensive.
Subscription to our Newsletters
On the website of DEUBLIN, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
DEUBLIN informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
Newsletter-Tracking
The newsletter of DEUBLIN contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, DEUBLIN may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. DEUBLIN automatically regards a withdrawal from the receipt of the newsletter as a revocation.
Contact possibility via the website
The website of DEUBLIN contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
Rights of the Data Subject
Right of Confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
Right of Access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the
European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
Right to Rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
Right to Erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by DEUBLIN, he or she may, at any time, contact any employee of the controller. An employee of DEUBLIN GmbH shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of DEUBLIN will arrange the necessary measures in individual cases.
Right of Restriction of Processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by DEUBLIN, he or she may at any time contact any employee of the controller. The employee of DEUBLIN will arrange the restriction of the processing.
Right to Data Portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of DEUBLIN.
Right to Object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
DEUBLIN shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
If DEUBLIN processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to DEUBLIN to the processing for direct marketing purposes, DEUBLIN will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by DEUBLIN for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of DEUBLIN. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, DEUBLIN shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of DEUBLIN.
Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of DEUBLIN.
Data protection provisions about the application and use of Facebook
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.
A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
Data protection provisions about the application and use of Google+
On this website, the controller has integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.
The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the Internet browser on the information technology system of the data subject automatically downloads a display of the corresponding Google+ button of Google through the respective Google+ button component. During the course of this technical procedure, Google is made aware of what specific sub-page of our website was visited by the data subject. More detailed information about Google+ is available under https://developers.google.com/+/.
If the data subject is logged in at the same time to Google+, Google recognizes with each call-up to our website by the data subject and for the entire duration of his or her stay on our Internet site, which specific sub-pages of our Internet page were visited by the data subject. This information is collected through the Google+ button and Google matches this with the respective Google+ account associated with the data subject.
If the data subject clicks on the Google+ button integrated on our website and thus gives a Google+ 1 recommendation, then Google assigns this information to the personal Google+ user account of the data subject and stores the personal data. Google stores the Google+ 1 recommendation of the data subject, making it publicly available in accordance with the terms and conditions accepted by the data subject in this regard. Subsequently, a Google+ 1 recommendation given by the data subject on this website together with other personal data, such as the Google+ account name used by the data subject and the stored photo, is stored and processed on other Google services, such as search-engine results of the Google search engine, the Google account of the data subject or in other places, e.g. on Internet pages, or in relation to advertisements. Google is also able to link the visit to this website with other personal data stored on Google. Google further records this personal information with the purpose of improving or optimizing the various Google services.
Through the Google+ button, Google receives information that the data subject visited our website, if the data subject at the time of the call-up to our website is logged in to Google+. This occurs regardless of whether the data subject clicks or doesn’t click on the Google+ button.
If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of his Google+ account before calling up our website.
Further information and the data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. More references from Google about the Google+ 1 button may be obtained under https://developers.google.com/+/web/buttons-policy.
Data protection provisions about the application and use of Google AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
Data protection provisions about the application and use of YouTube
On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.
YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company 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. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Changes to this Privacy Policy Statement
We reserve the right to modify this Privacy Policy Statement at any time without notice. The Privacy Policy Statement posted at any time or from time to time via the Site shall be deemed to be the Privacy Policy Statement then in effect. By continuing to use the Site following the posting of changes, you expressly accept and agree to abide by the terms set forth in the amended Privacy Policy Statement.
Data Controller
DEUBLIN Company is responsible for your privacy protection and is the data controller. Its address is 2050 Norman Drive; Waukegan, Illinois 60085 or privacy@deublin.com.
Contacting the Site
If you have any questions about this Privacy Policy Statement, the practices of the Site, or your dealings with the Site, you can contact:
DEUBLIN Company
2050 Norman Drive
Waukegan, Illinois 60085
privacy@deublin.com
This Privacy Policy Statement was last updated and is effective as of May 24, 2018
Preamble |
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The DEUBLIN Company is the leading manufacturer of Unions – mechanical devices used to transfer fluid from a stationary source into a rotating piece of machinery. Rotating Unions are used in numerous manufacturing processes to cool, heat, or transfer fluid (pneumatic or hydraulic) power. We sell our products to national and international customers and are positioned within the relevant market as supplier of innovative and customer-focused solutions with high-quality products. Our products are sold primarily to business customers in a variety of industries, and only occasionally to individual consumers. |
1. |
Purpose |
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Compliance with the statutory data protection regulations is a key support for the relationship with our customers, business partners, applicants, interested persons and employees. With this Policy, DEUBLIN Company defines a formal data protection management system for the processing of personal data. This does not affect or diminish the confidentiality obligations in employment contracts. The objectives of the Data Protection Policy are:
In addition to this guideline, data protection-relevant agreements with the responsible EU works councils, which also include procedures for safeguarding data protection, must be respected. |
2. |
Scope |
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This Data Protection Policy applies to the DEUBLIN Company. It applies whenever the DEUBLIN Company acts as the processor or as the controller of personal data, for their employees as well as for persons such as temporary workers. It covers all processing of personal data in the company. This Policy applies to DEUBLIN Company and its employees (or employees of functional equivalents, such as temporary workers, interns, etc.) who process personal data themselves as "responsible persons" or on behalf of "processors". Anonymized data (such as for statistical evaluations) as well as company data or data of legal persons are not subject to the Data Protection Policy, unless they permit conclusions to a certain person. This Policy applies to DEUBLIN Company affiliates and their employees (or employees of functional equivalents, such as temporary workers, interns, etc.) who process personal data from DEUBLIN or otherwise about persons who reside in the European Economic Area. DEUBLIN intends to prevent the occurrence of conduct not in compliance with this Policy and to stop any such conduct that may occur as soon as reasonably possible after its discovery. Covered Individuals who violate this Policy may be subject to disciplinary action, up to and including termination and reporting to appropriate law enforcement officials, subject to local law. |
3. a. |
Definitions Personal data |
is any information that relates to an identified or identifiable natural person (hereinafter referred to as "the data subject"); a natural person is identified as being identifiable directly or indirectly, in particular by means of assignment to an identifier such as a name, identifier, location data, an online identifier or one or more particular features. |
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b. |
Special categories of personal data |
include information on racial and ethnic origin, political opinion, trade union affiliation, political opinion, religious or ideological conviction, genetic data, biometric data for definite identification of a person, health, sexual life, or sexual orientation. These are subject to special protection regulations. |
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c. |
Processing |
of personal data is any process carried out with or without the help of automated procedures or any such series of operations in connection with personal data such as collection, gathering, organization, ordering, storage, adaptation or modification, reading, use, disclosure by transmission, publishing or any other form of providing information, matching or linking, limitation, deletion or destruction. |
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d. |
Anonymization |
Data are anonymized when a no personal reference is possible permanently and by anyone, or if the reference can only be recovered with a disproportionate amount of time, costs and labor power. An essential part of the anonymization is, in any case, the deletion of explicit or direct identification features, such as names and addresses, person identifiers, account numbers. |
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e. |
Data transmission |
is the transfer of data to a third party (other controller), including the retrieval of the data. |
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f. |
An order processing |
is carried out when an (external) contractor is charged with the processing of personal data and he processes these data strictly according to the instructions of DEUBLIN Company as a customer (e.g. storage of data in the data center, printing / sending of salary statements, destruction of data media or paper waste, possible data access from maintenance work). DEUBLIN has to select a processor, in particular, according to compliance with data protection regulations. |
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4. a. |
Responsibilities Management |
The managing directors of DEUBLIN are responsible for data processing in their area of responsibility. It is the responsibility of the management to ensure a legally compliant data processing through organizational, technical and personnel measures and guidelines. |
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b. |
Employees |
Each employee is responsible for the compliance and implementation of these requirements in his area and must ensure that the data protection requirements comply with in the selection of any contractors who are to be employed, by means of appropriate selection and monitoring. Employees, who maintain customer contacts due to their role, only collect data essential for the conduct of the business. |
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c. |
Data Protection Coordinator |
DEUBLIN does not require appointment of a formal data protection officer (DPO), but has appointed a data protection coordinator (DPC), Jan Sabel, IT Manager at DEUBLIN to serve as the group data protection representative. Each local HR manager may also be consulted regarding country-specific issues, and, if required under local law, individual country entities may be required to appoint a DPO with duties limited to that country. If a formal data protection officer is required under European or national law or otherwise considered prudent to appoint, management will appoint and empower a formal data protection officer (DPO) in writing. The DPC is responsible in particular for informing and advising management and employees of DEUBLIN in regard to operation of the data processing, monitoring of compliance with data protection requirements, as well as cooperation with the supervisory authority. The DPC shall monitor, where necessary, the legal basis of all procedures and contracts which contain personal data in cooperation with the Legal Department. The DPC shall prepare an annual activity report, report to the management as necessary and advise necessary measures. The DPC is the initial point of contact for the supervisory authority for all questions relating to the processing of personal data, although all contacts from supervisory authorities must be immediately reported to DEUBLIN Company legal in Waukegan, Illinois. |
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d. |
HR Manager |
Regarding personnel data, the "HR managers" are responsible for compliance with data protection in their offices. They handle personal files and data (any records of the company about employees) strictly confidential. The transmission of personnel data within the DEUBLIN Company group is only permissible in accordance with the provisions of the General Data Protection Regulation (GDPR) as well as the existing works council agreements. The "HR Manager" ensures the signing of the required commitments to data secrecy for new hires. |
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5. |
Data Protection Principles |
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Personal data may only be processed if there is a statutory permit list pursuant to Article 6 of the General Data Protection Regulation (GDPR). When DEUBLIN processes personal data, it must be processed only in a manner that is consistent with and reasonably proportionate to the purposes for which it is collected. |
a. |
Admissibility and Legality of Data Processing |
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Personal data may be processed only if:
The personal data is to be collected from the person concerned, their company, or publically-available materials. |
b. |
Transparency |
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As a company, DEUBLIN is obliged to inform affected persons in a clear, understandable form, in a clear, easy and accessible manner whether and how their personal data is processed. The data subject must ideally be informed prior to the collection of the data and before consent is given, but can also receive notice through information provided on our website in the context of Internet interactions. The person concerned must be informed:
Much of the processing of personal data by DEUBLIN will be in connection with the fulfillment of contracts or otherwise within the legitimate interest of DEUBLIN to process information related to orders for its products. When consent is the basis for processing, in principle, a declaration of consent is to be obtained in writing and, if possible, not coupled with general terms and conditions. In exceptional cases, e.g. in case of telephone advice or a customer complaint, the consent may also be given orally. A consent given in this way must be documented. If the data has not been collected by the person concerned, the affected person must be informed within one month after obtaining his personal data. The consent of the person concerned must be given voluntarily without any compulsion, for a specific situation, in knowledge of the facts and unambiguously in the form of a written declaration or other clear action. Consent is not given as voluntary if personal data are used for different processing operations without a separate consent, although this is appropriate in the individual case. A consent shall be invalid if the performance of a contract or the provision of a service is made conditional upon the person concerned consenting to a data processing, even though this is not necessary for the performance of the contract or the service (non-coupling obligation). Thus, the customer's consent to the processing of his personal data in the case of a customer request may not be linked to the fact that his personal data is used for the sending of a newsletter. The person concerned has the right to revoke his consent at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. The data subject is informed of this prior to submitting consent. The revocation of the consent must be documented in writing. |
c. |
Purpose Limitation and Deletion Obligation |
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DEUBLIN Processes Personal Data only in a fair and lawful manner in compliance with applicable Data Protection Laws and contractual obligations with its Customers and Third Parties, and takes steps to ensure the reliability of Personal Data obtained from Third Parties. DEUBLIN takes steps to ensure that its collection and Processing of Personal Data is relevant and not excessive for the specified purpose. Personal data may only be collected for established, unambiguous and legal purposes and may not be further processed in a manner incompatible with these purposes. The data shall be stored in a form which allows the identification of the persons concerned, at most for as long as necessary and to the extent necessary for the purposes for which they are processed. After this purpose, they shall be deleted. The purposes shall be communicated to the data subject prior to data collection. Changes of the purpose are permissible only within strict legal limits. For example, data collected for contractual purposes may not be used for advertising purposes. The person concerned is to be informed about a change of purpose. If Personal Data needs to be used for another purpose or handled in a way that the Data Subject has not had reasonable notice of or consented to, the Data Subject may first need to be informed of, and consent to, the new use, depending on the relevant context and circumstances and in accordance with the requirements of local law. |
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Data Minimization |
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In principle, the less personal data is processed, the better. Personal data should be collected, used and otherwise processed only when necessary for achieving the respective purpose of collection. Therefore, the collection and storage of personal data must be limited to the necessary extent and the data processing systems must be designed accordingly. In input masks, only those fields that are actually required for the purpose being pursued should be mandatory for input. Anonymized or pseudonymized data are preferably to be used as long as the purpose pursued can be achieved in this way without undue additional effort. Personal data which is no longer required for the achievement of a purpose, e.g. the fulfillment of the contract is to be deleted. If the deletion contains a legal retention period, the data may be kept for this purpose, but must be blocked for other purposes. Appropriate deletion, anonymization and archiving concepts must be introduced in the respective DEUBLIN affiliates. |
e. |
Design of Technical Systems |
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IT systems must be designed in such a way as to effectively implement the objectives of this Policy, in particular, it is important to ensure that they only collect as much data as is necessary to fulfill the objective pursued. This is to be ensured, in particular, by means of data-protecting presets. The requirements of data protection must be taken into account when developing, designing and implementing new IT systems and applications. |
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Correctness and Timeliness |
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Personal data are to be stored correct, complete and, where necessary, kept up-to-date. Adequate measures must be taken to ensure that the data is regularly updated in databases, and that non-relevant or obsolete data is deleted. |
g. |
Confidentiality, Availability and (Data) Integrity |
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DEUBLIN shall take appropriate technical and organizational measures (TOMs) in order to achieve these objectives. These TOMs are to be introduced and documented by DEUBLIN on the basis of a risk analysis. The TOMs are to be checked annually and also before the introduction of new applications or IT systems and, if necessary, adapted to the current situation / threat situation. |
h. |
Accountability |
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The management is responsible for compliance with the data protection principles and must be able to verify their compliance. In addition, the management has to verify the implementation of the necessary prerequisites for complying with data protection regulations in account reports. |
6. a. |
Handling of Certain Groups of Personal Data Data Processing for the Employment Relationship and Employment Data |
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In the recruitment process or in employment relationship, personal data may only be processed if necessary for the initiation, basis, execution and termination of the employment relationship. After rejection, the data of the applicant must be deleted, taking into account legal compliance requirements, unless the applicant has agreed to a further storage for a subsequent selection process in writing. Personal data may only be used for the purpose of detecting criminal offenses in the case of a justified suspicion, that is, if actual evidence (to be documented) give rise to the suspicion that the person concerned has committed a criminal offense in the employment relationship and does not prejudge the legitimate interest of the person concerned. In the case of this type of data use, the persons concerned must be informed about this after the completion of the measures, of the fact that the collected data are to be handed over to the investigating authorities in a logged form. |
b. |
Customers, Prospective Customers, Business Partners |
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Personal data from customers, business partners or interested parties may only be processed for initiating, justifying, conducting or terminating a contract or legal transaction as well as for customer support. Corresponding restrictions imposed by the interested party or business partners must be observed as well as the obligation to delete the data after the end of the business relationship. There are separate legal requirements for customer loyalty or advertising measures. The processing of personal data for advertising purposes is permitted provided that this is compatible with the original purpose of the data collection. If data is collected exclusively for advertising purposes, the person concerned may disclose their data voluntary. The person concerned is to be informed about the voluntary nature and the use of his data for advertising purposes, a consent of the person concerned is to be obtained. If the advertisement is to be made electronically (e.g. in the case of advertising newsletters), an explicit, verifiable consent of the person concerned is required. In the case of electronic consent, the so-called "double opt-in procedure" must always be applied. All advertising mails must be accompanied by a note that the person concerned can refuse to obtain advertising mail in future at any time. If the advertising approach is made by telephone, an explicit consent of the person concerned is also required. A presumed consent is required in the case of telephone advertising addressed to traders or legal persons. This is the case if the sending of the advertising is objectively in the interests of the person concerned and so far he has not given or rejected explicit consent. The caller’s phone number must always be visible to the person concerned. Advertising by means of letters or advertising mails (handouts, brochures, etc.) is, in principle, possible provided that the person concerned has not expressed any contrary will. |
c. |
User Data on the Internet and Social Media |
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Should personal data be processed on corporate websites or in apps, the affected persons are to be informed of this in privacy statements and, if necessary, by cookie notes. These are to be integrated in such a way that they are easily recognizable, directly accessible and constantly available to those concerned. If usage profiles are generated to evaluate the user behavior of websites and apps (tracking), affected persons must be informed of this in the data protection notes. Furthermore, an order processing agreement must be concluded with the provider of the tracking solution, as long as it works with any reference to persons. If the tracking is carried out under a pseudonym, the person concerned is to be offered a possibility of objecting in the data protection instructions. If access to personal data is permitted in the case of websites or apps in a domain that is subject to registration, the authentication of the data subjects shall be designed in such a way as to ensure appropriate protection for the respective access. It is always necessary to apply a double-opt-in method. The processing or combination of personal data from social media platforms and existing customer data always requires the consent of the user. For example, if a user is a fan of a Facebook business page, the user does not automatically have permission to use his or her data for advertising or data collation. |
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Transfer of Personal Data to Third Parties |
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The transmission of personal data is subject to special risks. A distinction must be made between a data transfer to third parties and the transfer of data within the scope of order processing. |
a. |
Order Processing within the DEUBLIN Group |
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In the case of order processing, the conclusion of a written data protection agreement with both external contractors as well as between companies within the DEUBLIN group is compulsory. As part of the selection process, the project owner has to make sure of contractor’s compliance with the contractual obligations before commissioning and to document this accordingly. In particular, it must be considered that the Contractor is able to ensure the required level of data protection. Compliance with the data security requirements can be demonstrated by a contractor in particular by providing a suitable certification, e.g. by ISO27001 test certificates, audit reports by competent supervisory authorities, etc. Depending on the risk of data processing, the controls must be repeated regularly during the contract period, audit results must be documented in writing. DEUBLIN has established procedures to allow for the transfer of Personal Data in compliance with applicable Data Protection Laws within the DEUBLIN group through execution of standard contractual clauses that ensure appropriate protections of covered Personal Data. |
b. |
Transfer of Personal Data Outside of the DEUBLIN Group |
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Any transfer of data to recipients within or outside the DEUBLIN group needs a legal basis; either a law or a contract must permit data transmission or the consent of the data subject must be available. Before DEUBLIN transfers Personal Data to a Third Party, DEUBLIN must ensure sufficient security measures and protections are in place and must do so only in compliance with any applicable contractual restrictions. A data transfer or data exchange, including the processing of personal data of customers and employees, may be carried out for internal administrative purposes within the DEUBLIN group, provided that the legitimate interests of the data subject are not infringed. The transfer of employment data is subject to special examination, the necessity in regard to the employment relationship must be proofed. The recipient of the data must be contractually obliged to use it only for the purposes specified. When transferring data to a recipient outside the European Union or the European Economic Area, it must be ensured that an equivalent level of data protection recognized by the EU is ensured. (SCC, Privacy Shield, BCRs). DEUBLIN’s DPC must be consulted and approve the following new types of data transfers if they are outside of already established operations:
Such Personal Data may be transferred to a Third Party only in the following circumstances:
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8. |
Rights of the Data Subject |
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Any data subject may exercise the following rights against DEUBLIN. Any assertion of rights by data subjects must be forwarded immediately to the DPC. The DPC will process the request with the responsible department and meet specific deadlines and requirements. The exercise of their rights must not lead to any disadvantages for the data subjects. DEUBLIN should design its systems to allow the exercise of such data protection rights with reasonable speed and cost in accordance with applicable Data Protection Laws. As required by Data Protection Laws, DEUBLIN will permit Data Subjects to request the correction of any incorrect or misleading Personal Data about them and will make reasonable efforts to correct or destroy, as appropriate, Personal Data that is inaccurate, misleading, or outdated, or which DEUBLIN is not permitted to store. |
a. |
Right of Access |
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The person concerned may at any time request from DEUBLIN, if and which personal data concerning him for which purposes is processed and/or transferred. In particular, he has in particular a right of information about:
If the information is not available online, the first copy must be free of charge. As far as the inquiry of the person concerned is done electronically, the information is provided by a read-only PDF file. The information is always sent to the (electronic) address, that has been stored at DEUBLIN. The granting of information is excluded or may be restricted if these rights and freedoms of other persons, in particular business secrets or intellectual property rights, would be affected. In case of doubt as to the identity of the applicant concerned, DEUBLIN must request additional information. If these are not sufficient, a statement can be refused with justification, until the necessary proof has been given. If, in accordance with the respective labor law, extended access rights are provided in employment documents (for example personnel records), these remain unaffected. |
b. |
Right to Copy and Data Portability |
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A person concerned may request a copy of the relevant personal data which he has provided to DEUBLIN. This presupposes that the processing was carried out by means of automated procedures and on the basis of the consent of the data subject or the execution of a contract. The copy must be made available in a structured, standard and machine-readable form or, if required, to be transmitted to third parties, if this is technically feasible. A copy must be made available to the person concerned free of charge. The rights and freedom of other persons shall not be affected by this right. In the case of justified doubts about the identity of the person asking, additional information must be requested. If these are not sufficient, a statement can be refused with justification, until the necessary proof has been given. |
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Right to Object |
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The person concerned is entitled at any time to oppose the processing of his data, which is necessary for the performance of a task or to safeguard the legitimate interests of DEUBLIN or a third party, as far as interests or fundamental rights and fundamental freedoms of the data subject which require the protection of personal data, do not prevail. In the event of an objection, the personal data may not be processed unless DEUBLIN can give proof that the processing of the data prevail over the interests, rights and freedoms of the data subject or the processing serves to assert, exercise or defend legal claims. The data subject may object to the processing of his personal data for the purposes of direct advertising. In that case, the data may not be processed for these purposes any more. The person concerned must be informed of his / her right of objection at the earliest time of communication, in an understandable form and separate form from other information. In addition, he may request the restriction of the processing of his data under the following conditions:
In cases of limitation of processing, DEUBLIN may initially only store and no longer process the data in any other way, unless statutory or official requirements stipulate otherwise. Exceptions from this are, next to a consent of the person affected, only possible for assertion, exercise or defense legal claims or to protect the rights of another natural or legal persons. The data subject shall be informed if the processing is carried out on the basis of one of the abovementioned exceptions. |
d. |
Right of Rectification |
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Should personal data be incorrect or incomplete, the person concerned may immediately request their correction or supplement, provided that this is appropriate with regard to the respective processing purposes. |
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Right to Restriction of Processing |
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The person concerned is entitled to demand the blocking of his personal data. The data shall be blocked if the person concerned disputes the data on the assertion, exercise or defense of legal claims, or if he has opposed the processing and has not yet determined whether the data must be deleted. Use of the blocked data by DEUBLIN is only permitted to assert, exercise or defend legal claims, to protect the rights of another natural or legal person or for reasons of a major public interest. In case the data blocking is lifted, the affected person must be informed beforehand. |
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Right to Restriction / Right to be Forgotten |
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The data subject is entitled to demand the deletion of his / her data. A basis for the claim for cancellation exist if the legal basis for the processing of the data is missing or omitted or if the data subject revokes his consent to data processing and there is no other legal basis for the processing. The same applies if the purpose of the data processing is limited by time sequence or for other reasons, in particular if it is no longer necessary. Where personal data that has to be deleted or has been made public by DEUBLIN, appropriate measures, including those of a technical nature, must be taken, taking into account the available technology and the implementation costs, in order to inform the third parties who are now processing the personal data that the person concerned has requested the deletion of all links to these personal data or of copies or replication of these personal data. Existing retention obligations and the protection of interests which are contrary to a deletion must be taken into account. |
9. |
Data Protection Breaches, Reporting Obligations |
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In the case of a breach of the protection of personal data it is irrelevant whether this occurred unintentionally or unlawfully. To avoid or limit damage to data subjects and the company, reasonably suspected breaches of data protection or security must be reported immediately and efficiently to the DPC and DEUBLIN Company legal, who shall consider whether report to the supervisory authorities is required. Each employee is obliged to report immediately to his or her supervisor or data protection officer any violations of this Privacy Policy or other rules for the protection of personal data. Responsible management is obligated to inform the data protection officer immediately about data protection incidents. In cases of unauthorized transfer of personal data to third parties, unauthorized access by third parties to personal data, or loss of personal data, the notifications provided in the company must be carried out without delay so that existing reporting obligations of data protection incidents to the competent supervisory authority (deadline within 72 hours) can be met. Legal counsel should determine whether the relevant reporting thresholds have been met. If the violation of personal data is likely to lead to a high risk for the personal rights and freedoms of natural persons, next to competent supervisory authority, the person concerned must also be informed without delay of the nature of the infringement and of the countermeasures taken. |
10. |
Records of Processing Activities |
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DEUBLIN must create records of processing activities, the purpose of the records of processing activities is to create a documentation,
The purpose of the records of processing activities is to provide transparency for the processing of personal data both within the company and (at the request of) the data protection officer and the data protection supervisory authority. The records must be sufficiently informative to enable a preliminary assessment of the adequacy of technical and organizational data protection measures. In particular, the list shall contain information on:
The list shall be updated at least once a year by DEUBLIN in collaboration with the DPC. If necessary, the records have to be updated of scheduled changes, in particular
New procedures should be described in accordance with the present outline and must be reported to the DPC. The data protection officer examines and releases the procedures. |
11. |
Data Protection Impact Assessment |
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DEUBLIN’s routine operations will likely not require frequent data protection impact assessments. Nevertheless, where automated processing, especially when using new technologies, entails a high risk for the rights and freedoms of the person concerned, they are subject to the examination before the start of processing (data protection impact assessment). A data protection impact assessment shall be carried out by DEUBLIN if:
In the implementation of the data protection impact assessment, the counsel of the DPC is to be sought. |
12. |
Data Protection Training |
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At the beginning of the employment relationship with DEUBLIN, each employee has to sign a commitment to data protection. Data protection training for employees must take place at least every third year. These trainings are organized by the relevant HR departments. (With responsible management and data protection officer) In addition, according to the requirements or in the case of comprehensive legal changes, separate training courses are organized according to job function. All training courses on data protection are compulsory. Compliance is provided by participants' lists, which are signed by the employees. These lists are stored and managed by the responsible HR department. |
13. |
Documentation and Control of Data Protection |
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As a data processing company, the companies of the DEUBLIN group must be able to prove their processing of personal data is in accordance with the data protection laws. The DPC must therefore be informed in time before the introduction of new procedures for the processing of data, in particular new IT systems or automated processing of personal data. In consultation with the data protection officer, technical and organizational measures for the protection of personal data are to be defined, implemented and documented. These measures must be based on the state of the art, the risks arising from the processing and the need to protect the data. Compliance with the guidelines on data protection and applicable data protection laws is regularly checked by data protection audits and other controls. The implementation is the responsibility of the data protection officer. The management of the company must be informed of any significant results within the scope of the respective reporting requirements. |
14. |
Recourse Mechanisms |
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DEUBLIN encourages employees and any other person to contact DEUBLIN to raise any complaints they may have with regard to the processing of their personal information by contacting DEUBLIN at [email] or by mail at [appropriate general physical mail]. DEUBLIN shall monitor this email address and its mail for customer complaints and respond to any complaints within 30 days. |
15. |
Automated Decisions |
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DEUBLIN does not make decisions that may have a legal effect or significantly affect data subjects based solely on automated decision-making (i.e. without human involvement) within the meaning of Data Protection Laws. In the event that DEUBLIN relies solely on automated decision-making that could have a significant legal effect on a Data Subject, it will provide the Data Subject with an opportunity to express his/her views and will provide any other safeguards as required by law. |
16. |
Update Service and Contact |
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The Data Protection Coordinator is responsible for the maintenance of this Policy. Any employee may contact the data protection officer with suggestions, inquiries, requests for information or complaints concerning data protection or data security issues. Inquiries and complaints are treated confidentially on request. You can contact the Data Protection Coordinator as follows: Jan Sabel (Data Protection Coordinator DEUBLIN) |
Preamble
The processing of your personal data – e.g. name, home address or contact details as phone number or mail address – will always be executed in accordance with the European General Data Protection Regulation (GDPR) and in accordance with national data protection regulations.
With this data protection information we inform you about the type, scope and purpose of the collected and processed data and about your data protection rights.
1. |
Affected persons |
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The present data protection information is valid for all natural persons that are customers, suppliers or business partners of DEUBLIN or employees of the customers, suppliers or business partners of DEUBLIN and informs you in which way DEUBLIN (hereinafter to be referred to as “we”, “us”) and their affiliated companies and subsidiaries will collect and process your personal data related to business relation. |
2. |
Categories of personal data |
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DEUBLIN collects, processes and uses the following categories of your data related to our relationship:
Information for the use of our websites When you visit our website it is possible that we collect certain data relating to the user, which your web-browser automatically submits to us, whenever you call up a website on the internet or an application on your mobile device. This data will automatically be recorded by our servers. Some of these include the IP-address, browser type and -language, date and time of your visit as well as the internet addresses (URL), that you have called up shortly before or after the visit of our websites. Depending on the abode of the user and the concerned data in each case, this may involve technical or personal data. In relation to this, please also make a note of the Data Protection Declaration on our internet presence. Information for the use of our newsletters The information provided to us with your consent to our newsletter according to Art. 6 par. 1 lit. a GDPR collected personal data will only be used for our communication with you and the sending of our newsletter. |
3. |
Purpose of the data processing |
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Where required, we only process your personal data to provide an effective implementation of our relationship. This includes
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4. |
Legal bases for data processing |
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We always process your personal data in accordance with the European General Data Protection Regulation (GDPR) and the relevant data protection regulations of the Federal Data Protection Act (BDSG). Below you find a description of the legal basis, in accordance to which we process your personal data. Please note that these information are only examples and cannot present a complete or final list of possible legal bases for the data processing. |
a. |
Consent (Art. 6 Par. 1 lit.a GDPR) |
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We use certain personal data only with your expressed and free previous consent. You may withdraw this consent at any time in order to terminate a future processing. |
b. |
Performance of a contract with you (Art. 6 Par. 1 lit.b GDPR) |
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We process certain personal data related to your contract. This amongst others includes the administrative processing of your personal data in order to process, plan and organize goods and services according to your contract. |
c. |
Fulfillment of legal obligations (Art. 6 Par. 1 lit.c GDPR) |
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DEUBLIN is subject to a series of legal requirements e. g. to ensure the fulfillment of legal obligations within DEUBLIN (Compliance). Legal obligations as these may require the processing of certain sensitive personal data. |
d. |
Protection of legitimate interests of DEUBLIN or a third party (Art. 6 Par. 1 lit.f GDPR) |
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DEUBLIN uses certain personal data for the protection of legitimate interests of the company or third parties. This only applies in cases that your personal interests as the affected person do not take precedence over DEUBLIN’s interests. |
5. |
Recipients or categories of recipients of personal data |
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DEUBLIN principally ensures that only a limited amount of authorized persons has access to your personal data, who need to have access to this data for the above mentioned administrative purposes. Your personal data will not be passed on, sold or otherwise transferred to any third party, unless required for the fulfilment of the contract or you have expressively agreed to it. Within the processing of your queries and your use of our services we also engage external contractors. These service providers are bound by contract to comply with the data protection regulations and only process personal data according with our instructions. Subject to these conditions recipients of personal data may be service providers, processors or other third parties for the following purposes:
The processing of the data will in principle take place in Germany or other states of the European Union. If some of your personal data, which we collect and process, should be forwarded to recipients outside the European Economic Area, we have taken appropriate measures to ensure the requirements of the Data Protection Regulation, e. g. the conclusion of appropriate EU-model contracts, privacy shield certifications (US), accepted code of conduct rules or accepted accreditation mechanisms according to article 42 GDPR. |
6. |
Duration of data processing |
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Your personal data will be deleted routinely according to Art. 17 par. 1 lit. a GDPR, if they are no longer necessary for the fulfilment of the contract and are no longer subject to legal storage periods. The deletion shall be replaced by the blocking of the personal data stored where legal or factual obstacles stand counter to deletion, e. g. existence of special commercial or tax laws, to keep evidence subject to statutes of limitation or outstanding claims. |
7. |
Automate decision making |
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For the purpose of establishing our business relationship we in principle do not use automate decision making according to Art. 25 GDPR. If we should use this procedure in exceptional cases, we will inform you about it in advance, as far as it is prescribed by law. |
8. |
Data security |
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DEUBLIN has taken technical and organizational measures that are appropriate to prevent your personal data from unprofessional or unauthorized use or access and to protect your personal data from accidental or unlawful loss, destruction, alteration or damage. Such measures shall ensure a level of security appropriate to the risks of processing and the nature of the personal data to be protected. Our security measures are continuously improved in line with technological progress. |
9. |
Rights of the individuals affected |
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As an individual affected you have legal rights concerning your personal data, that DEUBLIN collects and processes. According to the law you have the following rights:
and, as far as certain reasons apply and the legal requirements are fulfilled,
Furthermore you have the right to appeal to the responsible authority for data protection at any time. |
10. |
Validity of the information on data privacy |
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This information on data privacy is currently valid and dates from May 25, 2018. |
Preamble
The processing of your personal data – e.g. name, home address or contact details as phone number or mail address – will always be executed in accordance with the European General Data Protection Regulation (GDPR) and in accordance with national data protection regulations.
With this data protection information we inform you about the type, scope and purpose of the collected and processed data and about your data protection rights.
1. |
Affected persons |
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The present data protection information is valid for all natural persons that apply for a job at DEUBLIN and informs you in which way DEUBLIN (hereinafter to be referred to as “we”, “us”) and their affiliated companies and subsidiaries will collect and process your personal data related to your application. |
2. |
Categories of personal data |
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DEUBLIN collects, processes and uses the following categories of your data related to your application:
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3. |
Purpose of the data processing |
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Where required, we only process your personal data to provide an effective implementation of your application. This includes
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4. |
Legal bases for data processing |
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We always process your personal data in accordance with the European General Data Protection Regulation (GDPR) and the relevant data protection regulations of the Federal Data Protection Act (BDSG). Below you find a description of the legal basis, in accordance to which we process your personal data. Please note that these information are only examples and cannot present a complete or final list of possible legal bases for the data processing. |
a. |
Consent (Art. 6 Par. 1 lit.a GDPR) |
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We use certain personal data only with your expressed and free previous consent. You may withdraw this consent at any time in order to terminate a future processing. |
b. |
Performance of a contract with you (Art. 6 Par. 1 lit.b GDPR) |
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We process certain personal data related to your employment contract. This amongst others includes the administrative processing of your personal data in order to process, plan and organize your activity and your working place. |
c. |
Fulfillment of legal obligations (Art. 6 Par. 1 lit.c GDPR) |
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DEUBLIN is subject to a series of legal requirements e. g. to ensure the fulfillment of legal obligations within DEUBLIN (Compliance). Legal obligations as these may require the processing of certain sensitive personal data. |
d. |
Protection of legitimate interests of DEUBLIN or a third party (Art. 6 Par. 1 lit.f GDPR) |
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DEUBLIN uses certain personal data for the protection of legitimate interests of the company or third parties. This only applies in cases that your personal interests as the affected person do not take precedence over DEUBLIN’s interests. |
5. |
Recipients or categories of recipients of personal data |
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DEUBLIN principally ensures that only a limited amount of authorized persons has access to your personal data, who need to have access to this data for the above mentioned administrative purposes. Our mother company, the DEUBLIN Company located in Waukegan, Illinois, USA, as well as all our affiliated companies may receive your personal data which is necessary for the processing of your application, depending on the kind of job you apply for. Within the processing of your queries and your use of our services we also engage external contractors. These service providers are bound by contract to comply with the data protection regulations and only process personal data according to our instructions. Subject to these conditions recipients of personal data may be service providers, processors or other third parties for the following purposes:
The processing of the data will in principle take place in Germany or other states of the European Union. If some of your personal data, which we collect and process, should be forwarded to recipients outside the European Economic Area, we have taken appropriate measures to ensure the requirements of the Data Protection Regulation, e. g. the conclusion of appropriate EU-model contracts, privacy shield certifications (US), accepted code of conduct rules or accepted accreditation mechanisms according to Art. 42 GDPR. |
6. |
6. Duration of data processing |
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We delete your applicant details 3 months after a negative hiring decision by DEUBLIN or after you have declined an offer by DEUBLIN. DEUBLIN may keep your applicant data for 2 years if you have agreed to it in order to be considered for a different position at DEUBLIN or another company of the DEUBLIN group. If you accept an offer by DEUBLIN, we will keep your applicant details for the duration of your employment. |
7. |
Automate decision making |
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For the purpose of establishing employment we in principle do not use automate decision making according to Art. 25 GDPR. If we should use this procedure in exceptional cases, we will inform you about it in advance, as far as it is prescribed by law. |
8. |
Data security |
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DEUBLIN has taken technical and organizational measures that are appropriate to prevent your personal data from unprofessional or unauthorized use or access and to protect your personal data from accidental or unlawful loss, destruction, alteration or damage. Such measures shall ensure a level of security appropriate to the risks of processing and the nature of the personal data to be protected. Our security measures are continuously improved in line with technological progress. |
9. |
Rights of the individuals affected |
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As an individual affected you have legal rights concerning your personal data, that DEUBLIN collects and processes. According to the law you have the following rights:
and, as far as certain reasons apply and the legal requirements are fulfilled,
Furthermore you have the right to appeal to the responsible authority for data protection at any time. |
10. |
Validity of the information on data privacy |
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This information on data privacy is currently valid and dates from May 25, 2018. |