This data protection declaration explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

RESPONSIBLE

Tengo International GmbH
Gärtnerstr. 40, 45128 Essen
Nordrhein-Westfalen
Deutschland

Authorized representative: Tengiz Kotoian

Register court: Essen District Court
Register number: HRB 31728

tax number: 111/5740/1018

Responsibility for content according to §6 MDStV
Tengiz Kotoian

TYPES OF DATA PROCESSED:

– Inventory data (e.g., names, addresses).
– Contact details (e.g., e-mail, telephone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).

AFFECTED PERSONS CATEGORIES

Visitors and users of the online offer (in the following we also refer to the persons concerned collectively as “users”).

PURPOSE OF PROCESSING

– Provision of the online offer, its functions and content.
– Answering contact inquiries and communicating with users.
– Safety measures.
– Reach measurement / marketing

TERMS USED

“Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.

“Processing” is any process carried out with or without the aid of automated processes or any such series of processes in connection with personal data. The term goes far and includes practically every handling of data.

“Pseudonymization” the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data cannot be assigned to an identified or identifiable natural person.

“Profiling” means any type of automated processing of personal data that consists of using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal To analyze or predict the preferences, interests, reliability, behavior, whereabouts or relocation of this natural person.

“Responsible” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.

“Processor” means a natural or legal person, authority, institution or other body that processes personal data on behalf of the person responsible.

ESSENTIAL LEGAL BASIS

In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Article 6 Paragraph 1 lit. Answering inquiries is Art. 6 Para. 1 lit.b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit.c GDPR, and the legal basis for processing to safeguard our legitimate interests is Art . 6 para. 1 lit.f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1) (d) GDPR serves as the legal basis.

SECURITY MEASURE

In accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons, we make suitable technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, ensuring availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

COOPERATION WITH PROCESSORS AND THIRD PARTIES

If we disclose data to other persons and companies (contract processors or third parties) as part of our processing, transmit them to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the data is transmitted to third parties, such as to payment service providers, according to Art. 6 Paragraph 1 lit.

If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

TRANSFER TO THIRD COUNTRIES

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it happens to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

DATA SUBJECT RIGHTS

You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 GDPR the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, in accordance with Art. 18 GDPR, to request a restriction on the processing of the data.

You have the right to request that you receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties.

In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with the competent supervisory authority.

RIGHT OF WITHDRAWAL

You have the right to revoke your consent in accordance with Article 7 (3) GDPR with effect for the future

RIGHT TO OBJECT

You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can in particular be made against processing for direct marketing purposes.

COOKIES AND RIGHT TO OBJECT IN DIRECT ADVERTISING

“Cookies” are small files that are stored on the users’ computers. Various information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie can, for example, store the content of a shopping cart in an online shop or a login status. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our data protection declaration.

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

A general objection to the use of cookies used for online marketing purposes can be made for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU side http://www.youronlinechoices.com/ be explained. Furthermore, cookies can be saved by deactivating them in the browser settings. Please note that then you may not be able to use all of the functions of this online offer.

DELETION OF DATA

The data processed by us will be deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention requirements. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, more relevant for taxation Documents, etc.) and 6 years according to § 257 Paragraph 1 No. 2 and 3, Paragraph 4 HGB (commercial letters).

According to legal requirements in Austria, storage takes place in particular for 7 years in accordance with Section 132 (1) BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, list of income and expenses, etc.), for 22 years in connection with land and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the mini-one-stop-shop (MOSS) is used.

BUSINESS-RELATED PROCESSING

We also process
– Contract data (e.g., subject of the contract, term, customer category).
– Payment data (e.g., bank details, payment history)
by our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

PRIVACY NOTICE IN THE APPLICATION PROCESS

We process the applicant data only for the purpose and within the scope of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre) contractual obligations in the context of the application procedure within the meaning of Article 6 Paragraph 1 lit. b. GDPR Art. 6 Paragraph 1 lit.f.

The application process requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise it results from the job description and generally includes personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting the application to us, the applicants consent to the processing of their data for the purposes of the application process in accordance with the type and scope set out in this data protection declaration.

Insofar as special categories of personal data within the meaning of Art. 9 Paragraph 1 GDPR are voluntarily communicated within the scope of the application process, they are also processed in accordance with Art. 9 Paragraph 2 lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin) . Insofar as special categories of personal data within the meaning of Art. 9 Paragraph 1 GDPR are requested from applicants during the application process, they are also processed in accordance with Art. 9 Paragraph 2 lit. a GDPR (e.g. health data if this is necessary for the exercise of the profession are).

If made available, applicants can submit their applications to us using an online form on our website. The data is encrypted and transmitted to us in accordance with the state of the art.
Applicants can also send us their applications via email. Please note, however, that e-mails are generally not sent in encrypted form and that the applicants themselves must ensure that they are encrypted. We can therefore not assume any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or sending it by post. Because instead of applying via the online form and email, applicants still have the option of sending us their application by post.

The data provided by the applicants can be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicant’s data will be deleted. The applicant’s data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

The deletion takes place, subject to a justified revocation by the applicant, after a period of six months, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

CONTACT

When contacting us (e.g. via the contact form, email, telephone or via social media), the information provided by the user is processed in order to process the contact request and its processing in accordance with Art. 6 Para. 1 lit.b) GDPR. The user information can be stored in a customer relationship management system (“CRM system”) or a comparable request organization.

We delete the inquiries if they are no longer required. We review the requirement every two years; The statutory archiving obligations also apply.

HOSTING

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offer.

We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer based on our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 Para. 1 lit.f GDPR in conjunction with Art. 28 GDPR (conclusion of an order processing contract).

COLLECTION OF ACCESS DATA AND LOGFILES

We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 Paragraph 1 lit. The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider .

For security reasons (e.g. to investigate acts of abuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

GOOGLE ANALYTICS

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use Google Analytics, a web analysis service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee that it will comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the internet. In doing so, pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address will only be transmitted to a Google server in the USA and shortened there in exceptional cases.

The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; Users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information on the use of data by Google, setting and objection options, please refer to Google’s data protection declaration (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The personal data of the users will be deleted or anonymized after 14 months.

GOOGLE UNIVERSAL ANALYTICS

We use Google Analytics in the design as “Universal-Analytics” a. “Universal Analytics” refers to a process by Google Analytics in which the user analysis is carried out on the basis of a pseudonymous user ID and a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”) .

GOOGLE ADWORDS AND CONVERSION MEASUREMENT

We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR) , USA, (“Google”).

Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing process Google “AdWords” to place advertisements in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. This allows us to display advertisements for and within our online offer in a more targeted manner in order to only present users with advertisements that potentially correspond to their interests. If, for example, a user is shown advertisements for products that he was interested in on other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google advertising network is active, a code is immediately executed by Google and so-called (re) marketing tags (invisible graphics or code, also called ” Web Beacons ”) integrated into the website. With their help, an individual cookie, i.e. a small file, is saved on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user has visited, which content he is interested in and which offers the user has clicked, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer.

We also receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to generate conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information with which users can be personally identified.

The user data is processed pseudonymously within the Google advertising network. This means that Google does not store and process, for example, the name or email address of the user, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. In other words, from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about the users is transmitted to Google and stored on Google’s servers in the USA.

For more information on the use of data by Google, setting and objection options, please refer to Google’s data protection declaration (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

ONLINE PRESENCES IN SOCIAL MEDIA

We maintain an online presence within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

Unless otherwise stated in our data protection declaration, we process the data of the users as long as they communicate with us within the social networks and platforms, e.g. write articles on our online presence or send us messages.

INTEGRATION OF THIRD PARTY SERVICES AND CONTENT

We use content or service offers from third-party providers within our online offer based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. Integrate services such as videos or fonts (hereinafter uniformly referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as being linked to such information from other sources.

GOOGLE RECAPTCHA

We integrate the function for recognizing bots, e.g. when entering online forms (“ReCaptcha”) provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

GOOGLE MAPS

We integrate maps from the “Google Maps” service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, the users’ IP addresses and location data, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data can be processed in the USA. Data protection: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

The legal bases for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.