In the following, we inform you about the collection of personal data when using our website. Personal data in the sense of Art. 4 No. 1 of the EU General Data Protection Regulation (GDPR) is all information that can be related to you personally, such as name, address, e-mail addresses, user behavior.

 

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I. Name and contact details of the data controller and the data protection officer

The controller for the processing activities pursuant to Art. 4 No. 7 GDPR is:

CABKA Group GmbH
Wintersteinstraße 22

10587 Berlin

Germany

contact@cabka.com

You can reach our data protection officer, Mr. Christian Krösch, attorney at law, SLK Compliance Services GmbH, Königsbrücker Straße 76, 01099 Dresden, Germany, by phone: +49 351 89676360 or e-mail: datenschutz[at]slk-compliance.de.

II. General information on the collection, disclosure and storage period of personal data

Primarily, the data processing serves the provision of access to our website as well as the establishment and fulfillment of a contractual relationship with you. When you contact us by e-mail, via a contact form or by telephone, the data you provide (e.g. your e-mail address, name and telephone number, if applicable) will be stored by us in order to process your request. The primary legal basis for this is Art. 6 (1) b) GDPR. In addition, your separate consent pursuant to Art. 6 (1) a) GDPR may be used, if applicable. We also process your data in order to be able to fulfill our legal obligations, in particular in the area of commercial and tax law. This is done on the basis of Art. 6 (1) c) GDPR. As far as necessary, we also process your data on the basis of Art. 6 (1) f) GDPR in order to protect legitimate interests of us or of third parties. These interests may arise, for example, for advertising, as far as you have not objected to the use of your data, the assertion of legal claims and defense in legal disputes, ensuring the IT security of our company and for measures for business management and further development of services and products.

We will only disclose your personal data to third parties if you have given your consent in accordance with Art. 6 (1) a) GDPR, if the disclosure is necessary for the assertion, exercise or defense of legal claims or for the protection of our legitimate interests in accordance with Art. 6 (1) f) GDPR (e.g. affiliated companies, courts, tax advisors, lawyers) and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data, in the event that there is a legal obligation for the disclosure pursuant to Art. 6 (1) c) GDPR (e.g. tax authorities) as well as this is legally permissible and necessary for the processing of contractual relationships with you pursuant to Art. 6 (1) b) GDPR (e.g. banks, logistics service providers, IT service providers).

Depending on which services you use on our website or request from us, your personal data may be transferred to a third country. If we transfer personal data to recipients outside the European Economic Area (EEA), the transfer will only take place as far as the third country has been confirmed by the EU Commission to have an adequate level of data protection, other adequate data protection guarantees (e.g. binding corporate data protection rules or EU standard contractual clauses) are in place or an exception for the transfer according to Art. 49 GDPR applies.

We delete your personal data as soon as it is no longer necessary for the purposes stated in this privacy notice. After termination of the contractual relationship, your personal data will be stored as long as we are legally obliged to do so. This regularly results from legal obligations to provide proof and to retain data. The storage periods thereafter amount to up to ten years. In addition, personal data may be retained for the period during which claims can be asserted against us (statutory limitation period of three or up to thirty years).

You only need to provide us with the personal data that is necessary for the provision and use of certain functions of our website or the establishment and performance of a contractual relationship and the fulfillment of the associated contractual obligations, or which we are required to collect by law. Without this data, we will not be able to provide the website and certain functions of the website and to enter into and perform a contract with you.
III. Collection and processing activities of personal data on our website

Visiting our website

In the case of mere informational use of the website, i.e. if you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to our server and that are technically necessary for the presentation of our website and the guarantee of stability and security. These are the IP address, the request of your browser and the time of this request. In addition, the status and the amount of data transferred are recorded as part of this request. We also collect product and version information about the browser used and the operating system of your system. We further record from which website our page was accessed.

The temporary storage of the IP address by the system is necessary to enable delivery of the website to your browser. For this purpose, your IP address must remain stored for the duration of the session. The processing activities of the remaining data are carried out to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the stability and security of our systems. The legal basis is Art. 6 (1) f) GDPR, based on a weighing of our legitimate and overriding interests mentioned above.

We transfer the collected data to external service providers (hosting provider, IT service provider, web agency), which support us in data processing for the above-mentioned purposes.

The data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. Otherwise, deletion takes place at the latest within 7 days after calling up the website.

Cookies

When you use our website, we may collect information through the use of cookies or similar technologies ("cookies"). Cookies are small text files that are placed on your terminal device by your browser to store certain information. If you later visit our website again using the same terminal device, the information stored in Cookies is subsequently sent back either to our website or to another website to which the Cookie belongs. Through the stored and returned information, the respective website recognizes that you have already called up and visited it with the browser of your end device. Only the cookie itself is identified on your end device. We use cookies to improve our website, to store information about your preferred activities on the website and thus to tailor our website to your individual interests, as well as to comply with legal requirements.

This website uses the following types of cookies, the scope and functionality of which are explained below:

- Strictly necessary cookies

- Functional cookies

- Performance cookies

Strictly necessary cookies are cookies without which you would not be able to use our website as intended or without which we would not be able to provide our website to you. These include functions such as setting and saving your privacy preferences, filling in and saving user input, and security functions. These cookies are used without your consent. However, you have the option to disable these cookies via your browser settings. The legal basis for the processing of personal data using strictly necessary cookies is Art. 6 (1) c) GDPR or Art. 6 (1) f) GDPR, based on a consideration of our legitimate and overriding interests in the technically smooth provision of our website and the services offered through it.

Functional cookies allow us to store functions you have requested or information you have provided and, based on this, to offer you a better or more individualized use of our website. The legal basis for the processing activities using functional cookies is your consent according to Art. 6 (1) a) GDPR.

We use performance cookies to understand how visitors use our website, in particular which areas they visit and how much time they spend on the website. In addition, we collect information and register error messages with the aim of improving our website. The legal basis for the processing activities using performance cookies is your consent according to Art. 6 (1) a) GDPR.

You have the option via your browser to delete all cookies once they have been set. In addition, you can set your browser so that websites are prevented from storing and reading cookies. You can revoke your given consent to the use of cookies, unless they are strictly necessary, at any time with effect for the future. You will find the link to the cookie settings in the footer of our website.

Consent Management Platform

We use a Consent Management Platform (CMP) for the central management of your consents and the associated control of cookies. In doing so, we collect your consent or revocation of consent (cookie preferences), communication data (e.g. IP address, browser information) and usage data (e.g. date and time of visit).

We use the CMP to obtain, manage and document your consent to store certain cookies on your terminal device. The legal basis for the processing activities is Art. 6 (1) c) GDPR.

In addition to the processing of the above data, we transfer the collected data for processing to Intrado Digital Media, LLC, 1350 Broad, 25th Floor, New York, New York 10018, USA and other external service providers (e.g. platform, hosting, support service providers) in accordance with the above purposes (performance of cookie consent management).

In cases where personal data is transferred to Intrado Digital Media, LLC, 1350 Broad, 25th Floor, New York, New York 10018, USA, these transfers are subject to the standard contractual clauses pursuant to Art. 46 GDPR. These are available here: https://www.intrado.com/sites/default/files/2021-07/Digital-Media-SCCs-Addendum.pdf

The personal data collected will be deleted as soon as they are no longer needed for the processing purposes. As long as processing activities to which the consent relates take place, the collected data will be stored for the purpose of fulfilling the accountability obligation pursuant to Art. 5 (2) GDPR. Insofar as the data provided is subject to retention obligations under tax and commercial law, it will be stored for the duration of the retention obligations of up to ten years and then deleted, as far as you have not consented to storage beyond this or the further processing of the data is necessary for the assertion, exercise or defense of legal claims (statutory limitation period of three years, § 195 BGB, accountability according to Art. 5 (2) GDPR).

Adobe Analytics

We use Adobe Analytics, a web analytics service provided by Adobe Systems Software Ireland Limited 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland ("Adobe"). Adobe Analytics uses cookies, which are stored on your terminal device and which enable an analysis of your use of the website.

Communications data (e.g., IP address, browser information, device information), usage data (e.g., web pages visited, interest in content, date, time, and duration of visit), and location data (e.g., geographic location of device) are collected. The IP address is completely replaced by the value (x.x.x.x) after the geolocation is collected and is no longer available as a data point. With this basic replacement method, it is not possible to infer a unique, specific IP address through reverse engineering. Neither we nor Adobe can access the IP address.

We use Adobe Analytics to help us analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offer and make it more interesting for you as a user. The legal basis for the use of Adobe Analytics is your consent in accordance with Art. 6 (1) a) GDPR.

In addition to the processing of the above data by Adobe, we transfer the collected data to external service providers (e.g. platform, hosting, support and analytics service providers) for processing in accordance with the above purposes (performance and support of web analytics).

For the exceptional cases where personal data is transferred under Adobe's own responsibility to Adobe Inc. 345 Park Avenue, San Jose, CA 95110-2704, USA, these transfers are subject to the standard contractual clauses pursuant to Art. 46 GDPR. The order processing conditions for cloud services with reference to the standard contractual clauses are available here: https://www.adobe.com/legal/terms/enterprise-licensing/data-protection.html

The personal data collected will be deleted as soon as they are no longer needed for the processing purposes, which is regularly the case after 25 months from the collection of the data.

New Relic

We use the optimization service New Relic, of New Relic Inc, 188 Spear Street, Suite 1000, San Francisco, CA 94105, USA ("New Relic"). New Relic uses cookies that are stored on your terminal device and that enable optimization and analysis of your use of the website.

Communication data (e.g. IP address, browser information, device information), usage data (e.g. web pages visited, date, time and duration of the visit) and location data (e.g. geographic location of the device) are collected. The IP address is deleted after New Relic has collected the geolocation data.

We use New Relic to monitor performance and analyze our website. The knowledge gained enables us to identify weaknesses and improve our offer. The legal basis for the use of New Relic is your consent in accordance with Art. 6 (1) a) GDPR.

In addition to the processing of the above data by Google, we transfer the collected data to external service providers (e.g. platform, hosting, support and analysis service providers) for processing in accordance with the above purposes (performance and support for optimization).

The transfers of personal data to New Relic are subject to the standard contractual clauses pursuant to Art. 46 GDPR. The order processing conditions for New Relic with reference to the standard contractual clauses are available here: https://newrelic.com/termsandconditions/dataprotection

The personal data collected will be deleted as soon as they are no longer needed for the processing purposes.

IV. Further information on data processing within and outside our website

Contact and communication

We collect your personal data as a customer, business partner, interested third party or supplier if you provide it to us voluntarily by e-mail, via a contact form on our website, by mail or by telephone. We then collect the information that comes about as part of the contact and/or cooperation. This includes in particular names and transmitted contact data, date and reason for contact.

The personal data collected from you will be used for the purpose of providing you with the requested products or services and corresponding with you (legal basis Art. 6 (1) b) GDPR), for the fulfillment of legal obligations (legal basis Art. 6 (1) c) GDPR) or on the basis of legitimate interests of us or of third parties (legal basis Art. 6 (1) f) GDPR), which are described in this Privacy Policy.

You are not obliged to provide the aforementioned personal data. The data provided may be necessary for the conclusion of a contract. Without the provision of the data, communication, conclusion of a contract or contract processing may not be possible.

A transfer of the data relevant in the respective individual case takes place on the basis of the legal provisions or a contractual agreement to public bodies in the presence of overriding legal provisions, to external service providers or other contractors and to other external bodies, as far as you have given your consent or a transfer is permissible for predominant interest.

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Insofar as the data disclosed is subject to retention obligations under tax and commercial law, it will be stored for the duration of the retention obligations of ten years and then deleted, as far as you have not consented to storage beyond this or the further processing of the data is necessary for the assertion, exercise or defense of legal claims (statutory limitation period of three or up to thirty years).

Newsletter

With your consent, you can subscribe to our newsletter, with which we inform you about our offers. The advertised goods and services are named in the declaration of consent.

For the registration to our newsletter we use the so-called double opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within [24 hours], your information will be blocked and automatically deleted after one month. In addition, we store your respective IP addresses used and times of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data. The legal basis is Art. 6 (1) a) and c), Art. 7 (1), Art. 5 (2) GDPR.

Mandatory data for sending the newsletter is only your e-mail address, which is marked separately. The provision of further data is voluntary and will be used to address you personally. After your confirmation, we store your specified data for the purpose of sending the newsletter. The legal basis is Art. 6 (1) a) GDPR. The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. Accordingly, the user's e-mail address will be stored as long as the subscription to the newsletter is active. We may store inactive e-mail addresses for up to three years in order to prove consent previously given and to be able to defend against possible claims. The legal basis is Art. 6 (1) c), Art. 5 (2) GDPR.

You can revoke your consent to the sending of the newsletter and personal evaluation of your usage behavior (performance measurement) at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in each newsletter email or by sending a message to the contact details provided in the imprint.

The newsletter is sent by Intrado Digital Media, LLC, 1350 Broad, 25th Floor, New York, New York 10018, USA. Your e-mail address as well as your other data mentioned in these instructions for receiving the newsletter will be stored on the servers of Intrado Digital Media in the USA. Intrado Digital Media uses this information to send and measure the success of the newsletter on our behalf. The use of Intrado Digital Media is based on our legitimate interests pursuant to Art. 6 (1) f) GDPR. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users. Transfers to Intrado Digital Media, LLC are subject to the standard contractual clauses pursuant to Art. 46 GDPR. These are available here: https://www.intrado.com/sites/default/files/2021-07/Digital-Media-SCCs-Addendum.pdf

Our newsletters contain so-called web beacons, i.e. a pixel-sized file that is retrieved when the newsletter is opened. As part of this retrieval, technical information, such as data on the browser and your system, as well as your IP address and the time of retrieval are collected, which serve to technically improve the services based on the technical data or the target groups and their reading behavior. In addition, your usage behavior is evaluated to determine whether the newsletters were opened, when they were opened and which links were clicked. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to be able to offer different content according to the individual interests of our users. This performance measurement is included in the consent pursuant to Art. 6 (1) a) GDPR to send the newsletter. A revocation can therefore only be made together with the consent to send the newsletter.

V. Objection or revocation against the processing activities of your data

If you have given your consent to the processing activities of your data, you may revoke it at any time. Such revocation will affect the permissibility of the processing activities of your personal data after you have expressed it to us.

As far as we base the processing of your personal data on the balance of interests, you may object to the processing activities. This is the case if the processing activities are not necessary, in particular, for the performance of a contract with you, which will be presented by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as performed by us. In the event of your justified objection, we will review the situation and either discontinue or adjust the processing activities or show you our compelling legitimate grounds on the basis of which we will continue the processing.

Of course, you can object to the processing of your personal data for purposes of advertising and data analysis at any time. You can inform us of your objection to advertising by using the contact details provided in section I above.

VI. Your rights

In accordance with Article 15 GDPR, you have the right to request information about your personal data processed by us. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected from us, and the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details.

Pursuant to Art. 16 GDPR, you may request the correction of incorrect or incomplete personal data stored by us without undue delay. In accordance with Art. 17 GDPR, you have the right to request the erasure of your personal data stored by us, as far as the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims.

Pursuant to Art. 18 GDPR, you have the right to request the restriction of the processing of your personal data, as far as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer need the data, but you need it for the assertion, exercise or defense of legal claims or you have objected to the processing pursuant to Art. 21 GDPR.

In accordance with Art. 20 GDPR, you have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller.

In accordance with Art. 7 (3) GDPR, you have the right to revoke your consent once given to us at any time. This has the consequence that we may no longer continue the data processing based on this consent for the future.

You also have the right under Article 77 GDPR to lodge a complaint about the processing of your personal data by us with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you believe that the processing activities of the personal data concerning you violate the GDPR.