Data protection notice

1
Name and address of the controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states, as well as other data protection provisions, is:

Svving Europe GmbH
Theodorstraße 42-90
22761 Hamburg
Tel. 040/88130757
Email: info@svving.com

2
General information on data processing

a) Scope of the processing of personal data

In general, we only collect and use the personal data of our users insofar as this is necessary for the provision of our website with our content and services. The collection and use of the personal data of our users only takes place with the consent of the user. An exception applies to those cases in which prior consent cannot be obtained for practical reasons and the processing of the data is permitted by statutory provisions.

1) Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of said personal data.

When processing personal data that are required for the fulfilment of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

If the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person make the processing of personal data essential, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If processing is necessary to protect a legitimate interest of our company or a third party, and if the interests, fundamental rights, and freedoms of the data subject do not outweigh the aforementioned interests, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

2) Erasure of data and storage duration

The personal data of the data subject will be erased or blocked as soon as the purpose of storage lapses. Storage can also take place if this is foreseen by the European or national legislator in Union regulations, laws, or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period stipulated by the prescribed standards lapses, unless further storage of the data is required in order to conclude or fulfil a contract.

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Provision of the website and creation of log files

Every time our website is accessed, our system automatically collects data and information from the computer system of the device accessing the website. The following data are collected for a limited period of time:

  1. Information about the browser type and the version used
  2. The operating system of the user
  3. The Internet service provider of the user
  4. The IP address of the user
  5. Date and time of the access
  6. Websites from which the user’s system came to our website

The data are stored in the log files our system. These data are only required for the analysis of any errors and are erased at the latest 14 days and in the case of a backup, after 90 days. The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f GDPR. The temporary storage of the IP address by the system is necessary for the website to be accessible to and displayed on the user’s computer. To do this, the user’s IP address must be stored for the duration of the session. The data are stored in log files and this ensures the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. Any further storage of the data in the backup is only done for the sake of security in the event of any system errors. An evaluation of the data for marketing purposes is not carried out in this context and no conclusions can be drawn about your person. Here, too, our legitimate interest in data processing is in accordance with Art. 6 para. 1 lit. f GDPR. The collection of the data for the provision of the website and the storage of the data in log files is essential for the operation of the website. Thus, the user has no possibility to object.

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Use of cookies

1. Cookies required to operate the website

We use so-called session or flash cookies on our website. Cookies are text files that are stored in or by the Internet browser on the user’s computer system. When a user visits a website, a cookie can be stored on the user’s operating system. This cookie contains a character string that enables the browser to be clearly identified the next time the website is accessed. Some of the functions of our website cannot be offered without the use of cookies. It is necessary that the browser is recognised even after changing webpages. The user data collected with the technically required cookies are not used to determine the identity of the user or to create user profiles. The legal basis for the processing of personal data by means of cookies is Art. 6 para. 1 lit. f GDPR.

You can find a list of the cookies that are used on our website, as well as descriptions, here.

Cookie settings

2. Cookies used for web analysis

a) Google services
On the basis of a consent within the meaning of letter a of article 6(1) GDPR, we use the Google Ads advertising service, together with the Google Ads conversion tracking function, as well as Google remarketing and the web analytics service, Google Analytics, Google Tag Manager services and the Google Search Console. These services are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as “Google”). According to its Terms of Service, Google reserves the right to use personal data for its own purposes. Nevertheless, Google does not disclose whether and which personal data is used by Google.

Google uses cookies for the Google Ads, Google remarketing and Google Analytics services, provided you have given your consent. The information collected by a cookie on the use of the website by the user is generally transferred to a Google LLC server in the USA and stored there. Google processes the data in the Unites States on the basis of EU standard contractual clauses and thus offers sufficient guarantees within the meaning of letter c of article 46(1), (2) GDPR. Personal data shall be processed by Google only if you have given your consent. Additional information on the cookies used by Google can be found here.

Cookie settings

Google shall use this information on our behalf for the purpose of

  • advertising our website by placing relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and by enabling the insertion of third-party advertising on our website, including access analyses;
  • in the case of Google remarketing, Google shall display relevant advertisements to visitors of the website across the Google advertising network;
  • in the case of Google Analytics, Google shall evaluate the use of our website to compile reports on user activity on this website and to provide us with additional services related with the use of this website and the Internet. Pseudonymous user profile data can be generated from the processed data.

We only use Google tools with an enabled IP anonymisation.

This means that the IP address of the user is truncated 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 is only transmitted to a Google server in the USA and truncated there in exceptional cases.

The IP address transmitted by the user’s browser is not combined with other Google data. In addition to the default settings upon commencing the use of the website, you can prevent the storage of cookies by setting your browser software accordingly. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the online offer and from processing these data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Additional information on data use by Google, settings and objection possibilities can be found on the websites of Google: https://www.google.com/intl/de/policies/privacy/partners (“Data usage by Google through the use of websites or apps of our partners”), http://www.google.com/policies/technologies/ads (“Data usage for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to display advertisements to you”).

b) YouTube
Our website includes videos from YouTube. The operator of YouTube is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

As soon as you start a YouTube video via the website, a connection to the YouTube servers is established. The YouTube server is informed which of our webpages you have visited. If you are logged into your YouTube account, you allow YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

In addition, YouTube can store various cookies on your device after starting a video. With the help of these cookies, YouTube can get information about visitors to the website. This information is used to, among other things, collect video statistics, improve user-friendliness, and prevent fraud attempts. The cookies stay stored on your device until you delete them. The information generated by a cookie on the use of the online offer by the user is usually transmitted to a Google LLC server in the USA and stored there. Google processes the data in the USA, based on EU standard contractual clauses, and thus offers sufficient guarantees within the meaning of Art. 46 para. 1, para. 2 lit. c) GDPR.

Where applicable, further data processing operations can be triggered after the start of a YouTube video; we have no influence over this. YouTube is used based on the consent you have given to YouTube (e.g. consent to the storage of cookies), Art. 6 para. 1 lit. a GDPR. You can find more information on data protection at YouTube in their privacy policy at: https://policies.google.com/privacy?hl=de

c) Instagram
Our website integrates Instagram functions. The operator of Instagram is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.

Facebook Ireland Ltd. processes personal data when you use Facebook products, including data of people who are not registered with any of the Facebook services. Further details on which personal data are processed, how they are processed, for what purposes, and on what legal basis is described by Facebook in its privacy policy (https://help.instagram.com/519522125107875?helpref=page_content); this applies to all Facebook products. You will also find information here about contact options for Facebook and the setting options for advertisements, cookies, etc. The data may be transferred to countries outside the European Union. If you are logged into your Instagram account, you allow Facebook to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your Instagram account. Instagram is used based on your consent; Art 6 para. 1 lit. a GDPR.

No cookies are set through the embedding of the Instagram function on our website.

5
Contact

You can contact us via email, by phone, or by sending us a letter. When you contact us, your details from the request, including the contact details you provided there, will only be stored by us for the purpose of processing the request and in the event of follow-up questions. The data in this context are not disclosed to third parties.

The legal basis for the processing of the data is Art. 6 para. 1 lit. f GDPR. Our interest in responding to your request outweighs your interest. Since you are writing to us, a response is also in your interest and you are aware that we have to process your data in order to answer your request.

If the objective of the email contact is to conclude a contract, the legal basis for processing is Art. 6 para. 1 lit. b GDPR.

The data will be erased as soon as they are no longer required to achieve the purpose for which they were collected. This is deemed the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively sorted out.

6
Data protection for applications and application processes

We collect and process the personal data of applicants for the purpose of settling the application process. The processing can also be done electronically. This is particularly the case if an applicant sends the respective application documents by electronic means, for example via email. If we conclude an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If no employment contract is concluded with the applicant, the application documents will be automatically erased after rejection notification, provided that erasure does not conflict with any other legitimate interests of the controller. Another legitimate interest in this sense is, for example, a burden of proof in proceedings under the German General Equal Treatment Act (AGG).

7
Social media

We have an online presence within social networks and platforms in order to communicate with the customers, interested parties, and users who have accounts and are active there, and to inform them about our services.

Facebook, Instagram

We have set a link to the Facebook and Instagram pages of Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). There is no further data exchange with Facebook on our website. When accessing the respective networks and platforms, the terms and conditions and the data processing directives of the respective operators apply. Unless otherwise stipulated in our privacy policy, we process user data when users communicate with us within social networks and platforms, e.g. write articles about our online presence or send us messages. Privacy policy of Facebook: https://de-de.facebook.com/policy.php/

YouTube

We have set a link to the YouTube pages of Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). There is no further data exchange with Google on our website. When accessing the respective networks and platforms, the terms and conditions and the data processing directives of the respective operators apply. Unless otherwise stipulated in our privacy policy, we process user data when users communicate with us within social networks and platforms, e.g. write articles about our online presence or send us messages. Privacy policy of Google: https://policies.google.com/privacy?hl=de&gl=de

LinkedIn Link

We have also set a link to the LinkedIn pages of Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). There is no further data exchange with LinkedIn on our website. When accessing the respective networks and platforms, the terms and conditions and the data processing directives of the respective operators apply. Unless otherwise stipulated in our privacy policy, we process user data when users communicate with us within social networks and platforms, e.g. write articles about our online presence or send us messages. Privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy.

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Rights of data subjects

If your personal data are processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-a-vis the controller:

a) Right to information

You can request a confirmation from the controller on whether personal data related to you have been processed by us.

If this is the case, you can request details from the controller about the following information:

  1. the purposes for which the personal data are processed;
  2. the categories of personal data which are processed;
  3. the recipients, or categories of recipients, to whom the personal data relating to you have been disclosed or are still being disclosed;
  4. the planned storage duration of your personal data or, if specifics are not available, criteria for determining the storage duration;
  5. the existence of a right to correction or erasure of your personal data, a right to restrict processing by the controller, or a right to object to this processing;
  6. the right to lodge a complaint with the competent supervisory authority;
  7. all available information on the origin of the data if the personal data are not collected from the data subject;
  8. the existence of automated decision-making, including profiling in accordance with Art. 22 paras 1 and 4 GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information about whether your personal data are being transmitted to a third country or to an international organisation. In this context, you can demand to be instructed on the suitable guarantees related to the transmission in accordance with Art. 46 GDPR.

b) Right to correction

You have a right to correction and/or completion vis-à-vis the controller, if the personal data concerning you is incorrect or incomplete. The controller must correct the information immediately.

c) Right to restrict processing

You can request that the processing of your personal data be restricted under the following conditions:

  1. if you dispute the accuracy of your personal data for a period of time that allows the controller to check the accuracy of the personal data;
  2. the processing is unlawful and you reject the option of erasing the personal data, and instead request the restriction of the use of the personal data;
  3. the controller no longer needs the personal data for the stipulated purposes of processing, but you need them to assert, exercise, or defend legal claims; or
  4. if you have objected to the processing in accordance with Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh yours.

If the processing of your personal data has been restricted, these data – apart from their storage – may only be used with your consent or to assert, exercise, or defend legal claims, or to protect the rights of another natural or legal person, or for reasons of important public interest of the Union or a Member State.

If the processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.

d) Right to erasure

1.Obligation to erase data

You can request that the controller erases your personal data immediately, and the controller is obligated to erase these data immediately if one of the following reasons applies:

  1. The personal data related to you are no longer required for the purposes for which they were initially collected or otherwise processed.
  2. You revoke your consent on which the processing was based in accordance with. Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.
  3. According to Art. 21 para. 1 GDPR, you object to the processing and there are no urgent legitimate reasons for the processing, or you object to the processing in accordance with Art. 21 para. 2 GDPR.
  4. The personal data related to you were processed unlawfully.
  5. The erasure of your personal data is required to fulfil a legal obligation under Union law or the law of Member States to which the controller is subject.
  6. The personal data related to you were collected in regard to offered services of the information society in accordance with Art. 8 para. 1 GDPR.

e) Disclosure of information to third parties

If the controller has made your personal data public and is obligated to erasure in accordance with Art. 17 para. 1 GDPR, the controller shall take appropriate measures, including technical measures, under consideration of the available technology and the implementation costs, to inform those responsible for data processing that you as the data subject have requested the erasure of all links related to this personal data, or copies or replications of this personal data.

f) Exceptions

The right to erasure does not exist if the processing is required

  1. to exercise the right to freedom of expression and information;
  2. to fulfil a legal obligation that requires processing under Union law or the law of the Member States to which the controller is subject, or to perform a task that is in the public interest or in the exercise of official authority, which has been transferred to the controller;
  3. for reasons of public interest in the area of public health according to Art. 9 para. 2 lit. h and i, as well as Art. 9 para. 3 GDPR;
  4. for archiving purposes in the public interest, for scientific or historical research purposes, or for statistical purposes according to Art. 89 para. 1 GDPR, insofar as the right stipulated under Section a) could make the realisation of the processing objectives impossible or seriously impair it; or
  5. for the exercise, assertion, or defence of legal claims.

g) Right to information

If you have asserted your right to correction, erasure, or restriction of processing vis-a-vis the controller, the controller is obligated to inform all recipients to whom your personal data have been disclosed of this correction, erasure, or restriction of processing, unless this is impossible or involves a disproportionate amount of effort.

You have the right to be informed about these recipients by the controller.

h) Right to data portability

You have the right to receive the personal data, which you have provided to the controller, in a structured, common, and machine-readable format. You also have the right to transfer these data to another controller without hindrance from the controller to whom the personal data was provided, if

  1. the processing is based on consent according to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, or is based on a contract according to Art. 6 para. 1 lit. b GDPR and
  2. the processing takes places with the assistance of automated processes.

In exercising this right, you also have the right to have your personal data transmitted directly from one controller to another controller, insofar as this is technically feasible. This must not negatively affect the freedoms and rights of other people.

The right to data portability does not apply to the processing of personal data that is necessary for the performance of a task that is in the public interest or that takes place in the exercise of official authority, which has been transferred to the controller.

i) Right of revocation

You have the right at any time, for reasons that arise from your particular situation, to object to the processing of your personal data, which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions.

The controller will no longer process your personal data, unless the controller can prove compelling legitimate reasons for the processing that outweigh your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.

If your personal data are processed in regard to direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with said direct advertising.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Irrespective of Directive 2002/58/EC, you can, in connection with the utilisation of services of the information society, to exercise your right of revocation by means of automated processes in which technical specifications are used.

j) Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. Revoking your consent does not affect the legality of the processing carried out based on your consent up until the revocation.

k) Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which has legal effects on you or which significantly affects you in a similar manner. This does not apply if the decision

  1. is required for the conclusion or fulfilment of a contract between you and the controller,
  2. is permissible based on Union law or the law of the Member State to which the controller is subject, and this law contains appropriate measures to protect your rights, freedoms, and legitimate interests,
  3. takes place with your express consent.

However, these decisions may not be based on special categories of personal data according to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g applies and appropriate measures have been taken to protect your rights, freedoms, and legitimate interests.

With regard to the cases stipulated in (1) and (3), the controller shall take appropriate measures to protect your rights, freedoms, and legitimate interests, which includes at least the right to commission the intervention of a person on the part of the controller, to express one’s own point of view, and to contest the decision.

l) Right to lodge a complaint with a competent supervisory authority

Irrespective of any other administrative or judicial remedy, you have the right to lodge a complaint with a competent supervisory authority, in particular in the Member State of your place of residence, your place of work, or the place of the alleged breach, if you are of the opinion that the processing of your personal data violates the GDPR.

The competent supervisory authority to which the complaint was submitted informs the complainant about the status and the results of the complaint, including the possibility of legal action according to Art. 78 GDPR.

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