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Privacy Policy

Privacy Policy

We are delighted that you are interested in our company. Data protection is a particularly high priority for the management of Equinox FinTech Solutions GmbH. This Privacy Policy explains how Equinox FinTech Solutions GmbH collects and uses personal data from customers and other individuals who access or use our websites, including paperfly.io and equinox-fintech.de, our mobile applications, our Paperfly web app, platforms on which our Paperfly Portal application is embedded, and/or any of our other websites, products, or services that link to this Privacy Policy. By using our services, you acknowledge that we collect and use your personal data as described in this Privacy Policy.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Equinox FinTech Solutions GmbH. With this Privacy Policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. This Privacy Policy also informs data subjects of the rights to which they are entitled.

As the controller, Equinox FinTech Solutions GmbH has implemented numerous technical and organizational measures to ensure the most comprehensive protection possible for personal data processed via this website, our mobile applications, our Paperfly web app, or platforms on which our Paperfly Portal application is embedded. However, internet-based data transmissions may generally have security vulnerabilities, meaning absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.


1. Definitions

The Privacy Policy of Equinox FinTech Solutions GmbH is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would first like to explain the terms used.

In this Privacy Policy, we use the following terms, among others:

  • a) Personal data
    Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific factors that are an expression of the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • b) Data subject
    A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
  • c) Processing
    Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • d) Restriction of processing
    Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future.
  • e) Profiling
    Profiling means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
  • f) Pseudonymization
    Pseudonymization means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures that ensure the personal data is not attributed to an identified or identifiable natural person.
  • g) Controller or controller responsible for processing
    Controller or controller responsible for processing means the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its nomination may be provided for by Union law or the law of the Member States.
  • h) Processor
    Processor means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
  • i) Recipient
    Recipient means a natural or legal person, public authority, agency, or other body to which personal data is disclosed, whether or not it is a third party. However, public authorities that may receive personal data in the context of a specific investigation mandate under Union law or the law of the Member States are not regarded as recipients.
  • j) Third party
    Third party means a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or processor, are authorized to process the personal data.
  • k) Consent
    Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, in the form of a statement or other clear affirmative action, by which the data subject indicates agreement to the processing of personal data relating to them.


2. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature is:

Equinox FinTech Solutions GmbH

Nevinghoff 14-18

48147 Münster

Germany

Tel.: +49 251 322009 10

Email: info@equinox-fintech.de

Website: www.equinox-fintech.de


3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Dr. Sebastian Kraska

IITR Datenschutz GmbH

Marienplatz 2

80331 Munich

Germany

Tel.: +49 89 18917360

Email: email@iitr.de

Any data subject may contact our Data Protection Officer directly at any time with any questions or suggestions regarding data protection.


4. Collection of General Data and Information

Each time the website of Equinox FinTech Solutions GmbH is accessed by a data subject or an automated system, the website collects a range of general data and information. This general data and information is stored in the server log files. The data collected may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (known as a referrer), (4) the subpages accessed on our website via an accessing system, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used to avert threats in the event of attacks on our information technology systems.

When using this general data and information, Equinox FinTech Solutions GmbH does not draw any conclusions about the data subject. Rather, this information is required in order to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore analyzed by Equinox FinTech Solutions GmbH both statistically and with the aim of improving data protection and data security within our company, ultimately ensuring an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.


5. Registration on Our Website

The data subject has the option to register on the controller’s website by providing personal data. The personal data transmitted to the controller is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller’s own purposes. The controller may arrange for the data to be passed on to one or more processors, such as a parcel service provider, which also uses the personal data exclusively for internal purposes attributable to the controller.

When a data subject registers on the controller’s website, the IP address assigned by the data subject’s internet service provider (ISP), as well as the date and time of registration, are also stored. This data is stored because it is the only way to prevent misuse of our services and, where necessary, to enable the investigation of criminal offenses. In this respect, storing this data is necessary to protect the controller. As a rule, this data is not disclosed to third parties unless there is a legal obligation to disclose it or the disclosure serves the purpose of criminal prosecution.

The registration of the data subject, with the voluntary provision of personal data, enables the controller to offer the data subject content or services which, by their nature, can only be offered to registered users. Registered persons may at any time amend the personal data provided during registration or request that it be completely deleted from the controller’s database.

The controller will, upon request, provide any data subject at any time with information about which personal data relating to the data subject is stored. Furthermore, the controller will rectify or delete personal data at the request or notification of the data subject, provided that there are no statutory retention obligations to the contrary. All employees of the controller are available to the data subject as contact persons in this regard.


6. Contact via the Website

Due to statutory requirements, the website of Equinox FinTech Solutions GmbH contains information that enables quick electronic contact with our company and direct communication with us, including a general electronic mail address (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted voluntarily by a data subject to the controller is stored for the purpose of processing the inquiry or contacting the data subject. This personal data is not disclosed to third parties.


7. Routine Erasure and Blocking of Personal Data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage, or where this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies, or if a retention period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with statutory requirements.


8. Rights of the Data Subject

  • a) Right to Confirmation
    Every data subject has the right, granted by the European legislator, to obtain confirmation from the controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.
  • b) Right of Access
    Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller, at any time and free of charge, information about the personal data stored concerning them and a copy of that information. Furthermore, the European legislator has granted the data subject access to the following information:
    Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.
    If a data subject wishes to exercise this right of access, they may contact an employee of the controller at any time.
    • the purposes of the processing
    • the categories of personal data being processed
    • the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations
    • where possible, the planned period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
    • the existence of a right to rectification or erasure of personal data concerning them, or to restriction of processing by the controller, or a right to object to such processing
    • the existence of a right to lodge a complaint with a supervisory authority
    • where the personal data is not collected from the data subject: any available information as to its source
    • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and — at least in such cases — meaningful information about the logic involved, as well as the significance and intended consequences of such processing for the data subject
  • c) Right to rectification
    Every person affected by the processing of personal data has the right, granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. In addition, taking into account the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement.
    If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.
  • d) Right to erasure (right to be forgotten)
    Every person affected by the processing of personal data has the right, granted by the European legislator, to request that the controller erase personal data concerning them without undue delay, where one of the following grounds applies and insofar as processing is not required:
    Where one of the grounds stated above applies and a data subject wishes to request the erasure of personal data stored by Equinox FinTech Solutions GmbH, they may contact an employee of the controller at any time. The employee of Equinox FinTech Solutions GmbH will ensure that the erasure request is complied with without undue delay.
    Where personal data has been made public by Equinox FinTech Solutions GmbH and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, Equinox FinTech Solutions GmbH will, taking into account available technology and the cost of implementation, take appropriate measures, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of all links to, or copies or replications of, that personal data, insofar as processing is not required. The employee of Equinox FinTech Solutions GmbH will take the necessary steps in each individual case.
    • The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
    • The data subject withdraws the consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
    • The data subject objects to the processing pursuant to Art. 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
    • The personal data has been processed unlawfully.
    • The erasure of the personal data is required to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
    • The personal data was collected in relation to information society services offered pursuant to Art. 8(1) GDPR.
  • e) Right to restriction of processing
    Every person affected by the processing of personal data has the right, granted by the European legislator, to request that the controller restrict processing where one of the following conditions applies:
    Where one of the above conditions applies and a data subject wishes to request the restriction of personal data stored by Equinox FinTech Solutions GmbH, they may contact an employee of the controller at any time. The employee of Equinox FinTech Solutions GmbH will arrange for the restriction of processing.
    • 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, the data subject opposes the erasure of the personal data and requests the restriction of its use instead.
    • The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defense of legal claims.
    • The data subject has objected to processing pursuant to Art. 21(1) GDPR, and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.
  • f) Right to data portability
    Every person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning them, which the data subject has provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit that data to another controller without hindrance from the controller to whom the personal data was provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, provided that 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, when exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.
    To exercise the right to data portability, the data subject may contact an employee of Equinox FinTech Solutions GmbH at any time.
  • g) Right to object
    Every person affected by the processing of personal data has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them that is carried out on the basis of Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions.
    In the event of an objection, Equinox FinTech Solutions GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defense of legal claims.
    Where Equinox FinTech Solutions GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing purposes. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Equinox FinTech Solutions GmbH processing data for direct marketing purposes, Equinox FinTech Solutions GmbH will no longer process the personal data for these purposes.
    In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them by Equinox FinTech Solutions GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.
    To exercise the right to object, the data subject may contact any employee of Equinox FinTech Solutions GmbH or another employee directly. The data subject is also free, in connection with the use of information society services and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
  • h) Automated individual decision-making, including profiling
    Every person affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing — including profiling — that produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into or performing a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and such law provides suitable measures to safeguard the data subject’s rights, freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.
    Where the decision (1) is necessary for entering into or performing a contract between the data subject and the controller or (2) is based on the data subject’s explicit consent, Equinox FinTech Solutions GmbH will implement appropriate measures to safeguard the data subject’s rights, freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
    If the data subject wishes to exercise rights relating to automated decision-making, they may contact an employee of the controller at any time.
  • i) Right to withdraw consent under data protection law
    Every person affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.
    If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.


9. Data protection for applications and the application process

The controller collects and processes applicants’ personal data for the purpose of managing the application process. Processing may also take place electronically. This is particularly the case when an applicant submits application documents to the controller electronically, for example by email or via a web form on the website. If the controller enters into an employment contract with an applicant, the submitted data will be stored for the purpose of managing the employment relationship in compliance with statutory requirements. If the controller does not enter into an employment contract with the applicant, the application documents will be automatically deleted two months after the rejection decision has been communicated, unless deletion is prevented by other legitimate interests of the controller. Such a legitimate interest may, for example, be an obligation to provide evidence in proceedings under the German General Equal Treatment Act (AGG).


10. Privacy policy provisions on the use of Google Analytics (with anonymization function)

The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analytics service. Web analytics refers to the collection, compilation, and evaluation of data about the behavior of visitors to websites. Among other things, a web analytics service records data about the website from which a data subject arrived at a website (known as the referrer), which subpages of the website were accessed, and how often and for how long a subpage was viewed. Web analytics is primarily used to optimize a website and to analyze the cost-effectiveness of online advertising.

The operating company for the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the “_gat._anonymizeIp” extension for web analytics via Google Analytics. This extension enables Google to truncate and anonymize the IP address of the data subject’s internet connection when our website is accessed from a Member State of the European Union or from another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing activity on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s information technology system. Cookies have already been explained above. By placing the cookie, Google is enabled to analyze the use of our website. Each time an individual page of this website, operated by the controller and on which a Google Analytics component has been integrated, is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the data subject’s IP address, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

Personal information, such as the access time, the location from which access originated, and the frequency of visits to our website by the data subject, is stored by means of the cookie. Each time our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose the personal data collected through this technical process to third parties.

As described above, the data subject can prevent our website from setting cookies at any time by adjusting the settings of the internet browser used, thereby permanently objecting to the setting of cookies. Such a browser setting would also prevent Google from placing a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by Google Analytics relating to the use of this website, as well as the processing of this data by Google. To do so, the data subject must download the browser add-on at https://tools.google.com/dlpage/gaoptout and install it. This browser add-on uses JavaScript to inform Google Analytics that no data or information about visits to websites may be transmitted to Google Analytics. Google treats the installation of the browser add-on as an objection. If the data subject’s information technology system is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or by another person within their sphere of control, the browser add-on can be reinstalled or reactivated.

Further information and Google’s applicable privacy policy can be accessed at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.


11. Privacy policy provisions on the use of Google AdWords

The controller has integrated Google AdWords on this website. Google AdWords is an online advertising service that allows advertisers to place ads both in Google search engine results and in the Google advertising network. Google AdWords enables an advertiser to define specific keywords in advance, so that an ad is displayed in Google search results only when the user retrieves a keyword-relevant search result using the search engine. In the Google advertising network, ads are distributed on topic-relevant websites by means of an automated algorithm and in accordance with the previously defined keywords.

The operating company for Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to promote our website by displaying interest-based advertising on third-party websites and in Google search engine results, as well as by displaying third-party advertising on our website.

If a data subject reaches our website via a Google ad, Google places a so-called conversion cookie on the data subject’s information technology system. Cookies have already been explained above. A conversion cookie expires after thirty days and is not used to identify the data subject. If the cookie has not yet expired, the conversion cookie is used to track whether certain subpages, such as the shopping cart of an online shop system, have been accessed on our website. The conversion cookie allows both us and Google to determine whether a data subject who reached our website via an AdWords ad generated revenue, i.e., completed or abandoned a purchase.

The data and information collected through the use of the conversion cookie is used by Google to compile visit statistics for our website. We, in turn, use these visit statistics to determine the total number of users referred to us through AdWords ads, in other words to assess the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertising customers receive information from Google that could be used to identify the data subject.

Personal information, such as the websites visited by the data subject, is stored by means of the conversion cookie. Each time our website is visited, personal data, including the IP address of the internet connection used by the data subject, is therefore transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose the personal data collected through this technical process to third parties.

As described above, the data subject can prevent our website from setting cookies at any time by adjusting the settings of the internet browser used, thereby permanently objecting to the setting of cookies. Such a browser setting would also prevent Google from placing a conversion cookie on the data subject’s information technology system. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to interest-based advertising by Google. To do so, the data subject must access the link www.google.de/settings/ads from each internet browser they use and adjust the desired settings there.

Further information and Google’s applicable privacy policy can be accessed at https://www.google.de/intl/de/policies/privacy/.


12. Privacy policy provisions on the use of X

The controller has integrated components of X on this website. X is a multilingual, publicly accessible microblogging service on which users can publish and distribute so-called tweets, i.e., short messages limited to 280 characters. These short messages can be accessed by anyone, including people who are not registered with X. Tweets are also displayed to the respective user’s so-called followers. Followers are other X users who follow a user’s tweets. X also enables users to reach a broad audience through hashtags, links, and retweets.

The operating company of X is X-Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Each time an individual page of this website, operated by the controller and on which an X component (X button) has been integrated, is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective X component to download a display of the corresponding X component from X. Further information about X buttons is available at https://about.twitter.com/de/resources/buttons available. As part of this technical process, X-Corp. is informed which specific subpage of our website is visited by the data subject. The purpose of integrating the X component is to enable our users to share the content of this website, to raise awareness of this website in the digital world, and to increase our visitor numbers.

If the data subject is logged in to X at the same time, X-Corp. recognizes, each time the data subject accesses our website and for the entire duration of their visit to our website, which specific subpage of our website the data subject visits. This information is collected by the X component and assigned by X-Corp. to the data subject’s respective X account. If the data subject clicks one of the X buttons integrated into our website, the data and information transmitted in this way are assigned to the data subject’s personal X user account and stored and processed by X-Corp.

X-Corp. receives information via the X component that the data subject has visited our website whenever the data subject is logged in to X at the time they access our website; this occurs regardless of whether the data subject clicks the X component or not. If the data subject does not want this information to be transmitted to X-Corp., they can prevent the transmission by logging out of their X account before accessing our website.

The applicable privacy policy of X-Corp. is available at https://twitter.com/privacy?lang=de available.


13. Privacy Policy on the Use of Paperfly for Microsoft Teams

Microsoft Teams (abbreviated as MS Teams or simply Teams) is a platform that combines chat, meetings, notes, and attachments. The service is integrated into the Office 365 office suite with Microsoft Office and Skype/Skype for Business.

The operating company of Microsoft Teams is Microsoft Corporation, Redmond, WA 98052-6399.

When using Paperfly in the Microsoft Teams context, data for usage statistics may be generated automatically. This data is controlled by Microsoft and can be accessed in the Microsoft Teams Admin Center under Analytics & Reports.

The applicable Microsoft privacy policy is available at https://privacy.microsoft.com/de-de/privacystatement available.


14. Legal basis for processing

Art. 6(1)(a) GDPR serves as the legal basis for our company for processing operations in 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 a party, for example in processing operations required for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations that are necessary to take pre-contractual measures, such as inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, for example to fulfill tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance details, or other vital information had to be disclosed to a doctor, hospital, or other third parties. In such cases, the processing would be based on Art. 6(1)(d) GDPR.
Finally, processing operations may be based on Art. 6(1)(f) GDPR. Processing operations that are not covered by any of the legal bases mentioned above are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not override that interest. Such processing operations are permitted in particular because they have been specifically mentioned by the European legislator. In this regard, the legislator considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).


15. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is conducting our business activities for the benefit and well-being of all our employees and shareholders.


16. Period for which personal data is stored

The criterion for the duration of storage of personal data is the respective statutory retention period. After this period expires, the corresponding data is routinely deleted, provided it is no longer required for contract performance or contract initiation.


17. Statutory or contractual requirements to provide personal data; necessity for entering into a contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We inform you that the provision of personal data may in part be required by law (e.g., tax regulations) or may also result from contractual arrangements (e.g., information about the contractual partner).
In some cases, it may be necessary for a data subject to provide us with personal data in order to enter into a contract, which we must then process. For example, the data subject is required to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.
Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or by contract, or is necessary for entering into the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.


18. Existence of automated decision-making

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

Münster, March 24, 2025.

 

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Privacy Policy – 01.05.2019

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