We are very delighted that you have shown interest in our enterprise. Data protection is of aparticularly high priority for the management of the oneIDentity+. The use of the Internet pages ofthe oneIDentity+ is possible without any indication of personal data; however, if a data subjectwants to use special enterprise services via our website, processing of personal data could becomenecessary. If the processing of personal data is necessary and there is no statutory basis for suchprocessing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number ofa data subject shall always be in line with the General Data Protection Regulation (GDPR), and inaccordance with the country-specific data protection regulations applicable to the oneIDentity+. Bymeans of this data protection declaration, our enterprise would like to inform the general public ofthe nature, scope, and purpose of the personal data we collect, use and process. Furthermore, datasubjects are informed, by means of this data protection declaration, of the rights to which they areentitled.

As the controller, the oneIDentity+ has implemented numerous technical and organizationalmeasures 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 absoluteprotection may not be guaranteed. For this reason, every data subject is free to transfer personal datato us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of the oneIDentity+ is based on the terms used by the Europeanlegislator for the adoption of the General Data Protection Regulation (GDPR). Our data protectiondeclaration should be legible and understandable for the general public, as well as our customersand business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“datasubject”). An identifiable natural person is one who can be identified, directly or indirectly, inparticular by reference to an identifier such as a name, an identification number, location data, anonline identifier or to one or more factors specific to the physical, physiological, genetic, mental,economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by thecontroller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets ofpersonal data, whether or not by automated means, such as collection, recording, organisation,structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure ordestruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting theirprocessing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personaldata to evaluate certain personal aspects relating to a natural person, in particular to analyse orpredict aspects concerning that natural person’s performance at work, economic situation, health,personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can nolonger be attributed to a specific data subject without the use of additional information, providedthat such additional information is kept separately and is subject to technical and organisationalmeasures to ensure that the personal data are not attributed to an identified or identifiable naturalperson.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, publicauthority, agency or other body which, alone or jointly with others, determines the purposes andmeans of the processing of personal data; where the purposes and means of such processing aredetermined by Union or Member State law, the controller or the specific criteria for its nominationmay be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processespersonal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which thepersonal data are disclosed, whether a third party or not. However, public authorities which mayreceive personal data in the framework of a particular inquiry in accordance with Union or MemberState law shall not be regarded as recipients; the processing of those data by those public authoritiesshall be in compliance with the applicable data protection rules according to the purposes of theprocessing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject,controller, processor and persons who, under the direct authority of the controller or processor, areauthorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication ofthe data subject’s wishes by which he or she, by a statement or by a clear affirmative action,signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other dataprotection laws applicable in Member states of the European Union and other provisions related todata protection is:

oneIDentity+Steinheilstraße 1085737 IsmaningGermany

Phone: 0176 23232261
Email: mirja.bittrich@one-identity-plus.comWebsite: www.one-identity-plus.com

3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Dr. Daniel DünnebackeoneIDentity+Steinheilstraße 1085737 IsmaningGermany

Phone: +49 89 321216-8111
Email: Daniel.Duennebacke@one-identity-plus.comWebsite: www.one-identity-plus.com

Any data subject may, at any time, contact our Data Protection Officer directly with all questionsand suggestions concerning data protection.

4. Cookies

The Internet pages of the oneIDentity+ use cookies. Cookies are text files that are stored in acomputer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookieID is a unique identifier of the cookie. It consists of a character string through which Internet pagesand servers can be assigned to the specific Internet browser in which the cookie was stored. Thisallows visited Internet sites and servers to differentiate the individual browser of the dats subjectfrom other Internet browsers that contain other cookies. A specific Internet browser can berecognized and identified using the unique cookie ID.

Through the use of cookies, the oneIDentity+ can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user inmind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that usescookies, e.g. does not have to enter access data each time the website is accessed, because this istaken over by the website, and the cookie is thus stored on the user’s computer system. Anotherexample is the cookie of a shopping cart in an online shop. The online store remembers the articlesthat a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of acorresponding setting of the Internet browser used, and may thus permanently deny the setting ofcookies. Furthermore, already set cookies may be deleted at any time via an Internet browser orother software programs. This is possible in all popular Internet browsers. If the data subjectdeactivates the setting of cookies in the Internet browser used, not all functions of our website maybe entirely usable.

5. Collection of general data and information

The website of the oneIDentity+ collects a series of general data and information when a datasubject or automated system calls up the website. This general data and information are stored inthe server log files. Collected may be (1) the browser types and versions used, (2) the operatingsystem used by the accessing system, (3) the website from which an accessing system reaches ourwebsite (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internetsite, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessingsystem, and (8) any other similar data and information that may be used in the event of attacks onour information technology systems.

When using these general data and information, the oneIDentity+ does not draw any conclusionsabout the data subject. Rather, this information is needed to (1) deliver the content of our websitecorrectly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide lawenforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the oneIDentity+ analyzes anonymously collected data and informationstatistically, with the aim of increasing the data protection and data security of our enterprise, and toensure an optimal level of protection for the personal data we process. The anonymous data of theserver log files are stored separately from all personal data provided by a data subject.

6. Registration on our website

The data subject has the possibility to register on the website of the controller with the indication ofpersonal data. Which personal data are transmitted to the controller is determined by the respectiveinput mask used for the registration. The personal data entered by the data subject are collected andstored exclusively for internal use by the controller, and for his own purposes. The controller mayrequest transfer to one or more processors (e.g. a parcel service) that also uses personal data for aninternal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet serviceprovider (ISP) and used by the data subject—date, and time of the registration are also stored. Thestorage of this data takes place against the background that this is the only way to prevent themisuse of our services, and, if necessary, to make it possible to investigate committed offenses.Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aimof criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended toenable the controller to offer the data subject contents or services that may only be offered toregistered users due to the nature of the matter in question. Registered persons are free to change thepersonal data specified during the registration at any time, or to have them completely deleted fromthe data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as towhat personal data are stored about the data subject. In addition, the data controller shall correct orerase personal data at the request or indication of the data subject, insofar as there are no statutorystorage obligations. The entirety of the controller’s employees are available to the data subject inthis respect as contact persons.

7. Contact possibility via the website

The website of the oneIDentity+ contains information that enables a quick electronic contact to ourenterprise, 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 acontact form, the personal data transmitted by the data subject are automatically stored. Suchpersonal data transmitted on a voluntary basis by a data subject to the data controller are stored forthe purpose of processing or contacting the data subject. There is no transfer of this personal data tothird parties.

8. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the periodnecessary to achieve the purpose of storage, or as far as this is granted by the European legislator orother 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 legislatoror another competent legislator expires, the personal data are routinely blocked or erased inaccordance with legal requirements.

9. Rights of the data subjecta) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from thecontroller the confirmation as to whether or not personal data concerning him or her are beingprocessed. If a data subject wishes to avail himself of this right of confirmation, he or she may, atany time, contact any employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from thecontroller free information about his or her personal data stored at any time and a copy of thisinformation. Furthermore, the European directives and regulations grant the data subject access tothe 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 organisations;
• 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 logicinvolved, as well as the significance and envisaged consequences of such processing for thedata subject.
• Furthermore, the data subject shall have a right to obtain information as to whether personal dataare transferred to a third country or to an international organisation. Where this is the case, the datasubject 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, contactany employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from thecontroller 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 haveincomplete 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 anyemployee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from thecontroller the erasure of personal data concerning him or her without undue delay, and the controllershall have the obligation to erase personal data without undue delay where one of the followinggrounds applies, as long as the processing is not necessary:

The personal data are no longer necessary in relation to the purposes for which they werecollected 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 noother legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and thereare no overriding legitimate grounds for the processing, or the data subject objects to theprocessing pursuant to Article 21(2) of the GDPR.

Thepersonaldatahavebeenunlawfullyprocessed.

The personal data must be erased for compliance with a legal obligation in Union orMember State law to which the controller is subject.

The personal data have been collected in relation to the offer of information society servicesreferred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure ofpersonal data stored by the oneIDentity+, he or she may, at any time, contact any employee of thecontroller. An employee of oneIDentity+ shall promptly ensure that the erasure request is compliedwith immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erasethe personal data, the controller, taking account of available technology and the cost ofimplementation, shall take reasonable steps, including technical measures, to inform othercontrollers processing the personal data that the data subject has requested erasure by suchcontrollers of any links to, or copy or replication of, those personal data, as far as processing is notrequired. An employees of the oneIDentity+ will arrange the necessary measures in individualcases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from thecontroller 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 thecontroller to verify the accuracy of the personal data.

The processing is unlawful and the data subject opposes the erasure of the personal data andrequests instead the restriction of their use instead.

The controller no longer needs the personal data for the purposes of the processing, but theyare required by the data subject for the establishment, exercise or defence of legal claims.

The data subject has objected to processing pursuant to Article 21(1) of the GDPR pendingthe verification whether the legitimate grounds of the controller override those of the datasubject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction ofthe processing of personal data stored by the oneIDentity+, he or she may at any time contact anyemployee of the controller. The employee of the oneIDentity+ will arrange the restriction of theprocessing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personaldata concerning him or her, which was provided to a controller, in a structured, commonly used andmachine-readable format. He or she shall have the right to transmit those data to another controllerwithout hindrance from the controller to which the personal data have been provided, as long as theprocessing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) ofArticle 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, andthe processing is carried out by automated means, as long as the processing is not necessary for theperformance of a task carried out in the public interest or in the exercise of official authority vestedin 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 toanother, where technically feasible and when doing so does not adversely affect the rights andfreedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employeeof the oneIDentity+.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on groundsrelating to his or her particular situation, at any time, to processing of personal data concerning himor her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profilingbased on these provisions.

The oneIDentity+ shall no longer process the personal data in the event of the objection, unless wecan demonstrate compelling legitimate grounds for the processing which override the interests,rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If the oneIDentity+ processes personal data for direct marketing purposes, the data subject shallhave the right to object at any time to processing of personal data concerning him or her for suchmarketing. This applies to profiling to the extent that it is related to such direct marketing. If thedata subject objects to the oneIDentity+ to the processing for direct marketing purposes, theoneIDentity+ 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, toobject to processing of personal data concerning him or her by the oneIDentity+ for scientific orhistorical 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 publicinterest.

In order to exercise the right to object, the data subject may contact any employee of theoneIDentity+. In addition, the data subject is free in the context of the use of information societyservices, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automatedmeans using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to adecision based solely on automated processing, including profiling, which produces legal effectsconcerning him or her, or similarly significantly affects him or her, as long as the decision (1) is notis necessary for entering into, or the performance of, a contract between the data subject and a datacontroller, or (2) is not authorised by Union or Member State law to which the controller is subjectand which also lays down suitable measures to safeguard the data subject’s rights and freedoms andlegitimate 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 datasubject and a data controller, or (2) it is based on the data subject’s explicit consent, theoneIDentity+ shall implement suitable measures to safeguard the data subject’s rights and freedomsand 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 the oneIDentity+.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or herconsent 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 the oneIDentity+.

10. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of applicants for the purpose of theprocessing of the application procedure. The processing may also be carried out electronically. Thisis the case, in particular, if an applicant submits corresponding application documents by e-mail orby means of a web form on the website to the controller. If the data controller concludes anemployment contract with an applicant, the submitted data will be stored for the purpose ofprocessing the employment relationship in compliance with legal requirements. If no employmentcontract is concluded with the applicant by the controller, the application documents shall beautomatically erased two months after notification of the refusal decision, provided that no otherlegitimate interests of the controller are opposed to the erasure. Other legitimate interest in thisrelation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

On this website, the controller has integrated the component of Google Analytics (with theanonymizer 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 servicecollects, 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. Webanalytics are mainly used for the optimization of a website and in order to carry out a cost-benefitanalysis of Internet advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, BarrowStreet, Dublin, D04 E5W5, Ireland.

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 datasubject is abridged by Google and anonymised when accessing our websites from a Member Stateof the European Union or another Contracting State to the Agreement on the European EconomicArea.

The purpose of the Google Analytics component is to analyze the traffic on our website. Googleuses the collected data and information, inter alia, to evaluate the use of our website and to provideonline reports, which show the activities on our websites, and to provide other services concerningthe use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. Thedefinition of cookies is explained above. With the setting of the cookie, Google is enabled toanalyze 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 thesettlement of commissions to Google. During the course of this technical procedure, the enterpriseGoogle gains knowledge of personal information, such as the IP address of the data subject, whichserves Google, inter alia, to understand the origin of visitors and clicks, and subsequently createcommission settlements.

The cookie is used to store personal information, such as the access time, the location from whichthe access was made, and the frequency of visits of our website by the data subject. With each visitto our Internet site, such personal data, including the IP address of the Internet access used by thedata subject, will be transmitted to Google in the United States of America. These personal data arestored by Google in the United States of America. Google may pass these personal data collectedthrough the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at anytime by means of a corresponding adjustment of the web browser used and thus permanently denythe setting of cookies. Such an adjustment to the Internet browser used would also prevent GoogleAnalytics from setting a cookie on the information technology system of the data subject. Inaddition, cookies already in use by Google Analytics may be deleted at any time via a web browseror other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generatedby Google Analytics, which is related to the use of this website, as well as the processing of thisdata by Google and the chance to preclude any such. For this purpose, the data subject mustdownload 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 informationabout the visits of Internet pages may not be transmitted to Google Analytics. The installation of thebrowser add-ons is considered an objection by Google. If the information technology system of thedata subject is later deleted, formatted, or newly installed, then the data subject must reinstall thebrowser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the datasubject or any other person who is attributable to their sphere of competence, or is disabled, it ispossible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved underhttps://www.google.com/intl/en/policies/privacy/ and underhttp://www.google.com/analytics/terms/us.html. Google Analytics is further explained under thefollowing Link https://www.google.com/analytics/.

12. Data protection provisions about the application and use of YouTube

On this website, the controller has integrated components of YouTube. YouTube is an Internet videoportal that enables video publishers to set video clips and other users free of charge, which alsoprovides free viewing, review and commenting on them. YouTube allows you to publish all kinds ofvideos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, andvideos made by users via the Internet portal.

The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street,Dublin, D04 E5W5, Ireland.

With each call-up to one of the individual pages of this Internet site, which is operated by thecontroller 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 todownload a display of the corresponding YouTube component. Further information about YouTubemay be obtained under https://www.youtube.com/yt/about/en/. During the course of this technicalprocedure, YouTube and Google gain knowledge of what specific sub-page of our website wasvisited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-pagethat contains a YouTube video, which specific sub-page of our Internet site was visited by the datasubject. This information is collected by YouTube and Google and assigned to the respectiveYouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subjecthas visited our website, if the data subject at the time of the call to our website is logged in onYouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such atransmission of this information to YouTube and Google is not desirable for the data subject, thedelivery may be prevented if the data subject logs off from their own YouTube account before acall-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 andGoogle.

13. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consentfor a specific processing purpose. If the processing of personal data is necessary for theperformance of a contract to which the data subject is party, as is the case, for example, whenprocessing operations are necessary for the supply of goods or to provide any other service, theprocessing is based on Article 6(1) lit. b GDPR. The same applies to such processing operationswhich are necessary for carrying out pre-contractual measures, for example in the case of inquiriesconcerning our products or services. Is our company subject to a legal obligation by whichprocessing of personal data is required, such as for the fulfillment of tax obligations, the processingis based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary toprotect the vital interests of the data subject or of another natural person. This would be the case, forexample, if a visitor were injured in our company and his name, age, health insurance data or othervital information would have to be passed on to a doctor, hospital or other third party. Then theprocessing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be basedon Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not coveredby any of the abovementioned legal grounds, if processing is necessary for the purposes of thelegitimate interests pursued by our company or by a third party, except where such interests areoverridden by the interests or fundamental rights and freedoms of the data subject which requireprotection of personal data. Such processing operations are particularly permissible because theyhave been specifically mentioned by the European legislator. He considered that a legitimateinterest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2GDPR).

14. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest isto carry out our business in favor of the well-being of all our employees and the shareholders.

15. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutoryretention period. After expiration of that period, the corresponding data is routinely deleted, as longas it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

16. Provision of personal data as statutory or contractual requirement; Requirementnecessary to enter into a contract; Obligation of the data subject to provide the personal data;possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or canalso result from contractual provisions (e.g. information on the contractual partner). Sometimes itmay be necessary to conclude a contract that the data subject provides us with personal data, whichmust subsequently be processed by us. The data subject is, for example, obliged to provide us withpersonal data when our company signs a contract with him or her. The non-provision of thepersonal data would have the consequence that the contract with the data subject could not beconcluded. Before personal data is provided by the data subject, the data subject must contact anyemployee. The employee clarifies to the data subject whether the provision of the personal data isrequired by law or contract or is necessary for the conclusion of the contract, whether there is anobligation to provide the personal data and the consequences of non-provision of the personal data.

17. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

This Privacy Policy has been generated by the Privacy Policy Generator of the External DataProtection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW.