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Privacy Policy

We are very pleased that you are interested in our organization. The protection of your Personal Data is particularly important to our management. As a rule, you can use our websites without disclosing any Personal Data to us. However, if you wish to use more specific services via our websites, including our other websites, applications and social media pages, we may have to process your Personal Data. If we wish to process data about you and we cannot rely on any other legal basis, we will always ask you for your Consent first (e.g. via a cookie banner).

We always comply with applicable data protection laws when handling your Personal Data (such as name, address, email or telephone number). With this Privacy Policy, we inform you about which data we process. This Privacy Policy also explains to you what rights you have as a Data Subject.

We have taken various technical and organizational measures to protect your data on our websites in the best possible way. Nevertheless, there are always risks on the internet and complete protection is not possible. For this reason, you can also transmit your Personal Data to us by other means, for example by telephone, if you prefer.

This Privacy Policy is not only intended to fulfill the obligations under GDPR and to comply with the law of the Member States of the European Union (EU) and the European Economic Area (EEA). This Privacy Policy is also intended to comply with legislation such as UK data protection laws (UK-GDPR), Swiss Federal Data Protection Act and Swiss Data Protection Ordinance (DSG, DSV), California Consumer Privacy Act (CCPA/CPRA), China's Personal Information Protection Law (PIPL), Delaware Personal Data Privacy Act (DPDPA), Tennessee Information Protection Act (TIPA), Minnesota Consumer Data Privacy Act (MCDPA), Iowa Act Relating to Consumer Data Protection (ICDPA), Maryland Online Data Privacy Act (MODPA), Nebraska Data Privacy Act (NDPA), New Hampshire Consumer Data Privacy Law (SB255), New Jersey Data Privacy Law (SB332), South Carolina Consumer Privacy Bill (House Bill 4696) and other global data protection regulations and shall be interpreted accordingly. The following Privacy Policy shall be interpreted for each country, state or federal state in such a way that the terms and legal bases used correspond to the terms and legal bases used in the respective state or federal state.

For reasons of better readability, the simultaneous use of the language forms male, female, diverse and other gender identities (m/f/d/other) is avoided on our websites, in publications, in communication and in our Privacy Policy. All formulations used apply equally to all genders.

If you have any suggestions for improving the texts in this Privacy Policy or if you want to hire an External Data Protection Officer, please contact the author of the text: Prof. Dr. h.c. Heiko Jonny Maniero, LL.B., LL.M. mult., M.L.E..

1. Definitions

In our Privacy Policy, we use special terms from various data protection laws. We want our statement to be easy to understand and therefore explain these terms in advance.

The following definitions shall be interpreted or expanded, as appropriate, based on the case law of the General Court of the European Union (EGC), the European Court of Justice (ECJ), the Swiss Federal Supreme Court (SFSC), the Supreme Court of the United Kingdom (UKSC) or on national data protection laws or national case law of a state or federal state, including but not limited to California, including case law, also under common law, if this is necessary for the application of the law in individual cases.

We use the following terms, among others, in this Privacy Policy:

a) Personal Data

Personal Data means any information relating to an identified or identifiable natural person. 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, or who must be regarded as such under national data protection legislation or national jurisdiction of a state or federal state, including under common law.

b) Data Subject

Data Subject is any identified or identifiable natural person whose Personal Data is processed by the Controller, a Processor, an international organization or another data recipient, and persons who must be regarded as such under national data protection laws or national jurisdiction of a state or federal state, including case law, also under common law.

c) Processing

Processing is any operation or set of operations which is performed on Personal Data or on sets of Personal 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 or destruction.

d) Restriction of Processing

Restriction of Processing is the marking of stored Personal Data with the aim of limiting their Processing in the future.

e) Profiling

Profiling is any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymization

Pseudonymization is the Processing of Personal Data in such a manner 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 to ensure that the Personal Data are not attributed to an identified or identifiable natural person.

g) Controller

The Controller is the natural or legal person, public authority, agency or other body which, 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 or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

A Processor is a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

i) Recipient

A Recipient is a natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not. However, public authorities which may receive Personal Data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third Party

A 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, are authorised to process Personal Data.

k) Consent

Consent is any freely given, specific, informed and unambiguous indication of the 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

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 the European Economic Area, British data protection laws, Swiss data protection laws (DSG, DSV), Californian data protection law (CCPA/CPRA), Chinese data protection law (PIPL), as well as international laws and provisions with a data protection nature is:

LAVEGO AG

Zielstattstraße 10a Rückgebäude

81379 München

Phone.: +49 89 7279-1000

eMail: info@lavego.de

Website: https://www.lavego.de

3. Name and contact details of the data protection officer

Prof. Dr. h.c. Heiko Jonny Maniero

Franz-Joseph-Str. 11

80801 München

Deutschland

Phone.: +49 (0)178 - 6264376

eMail: info@dg-datenschutz.de

4. Collection of general data and information

Our websites collect a range of general data and information each time the websites are accessed by a Data Subject or an automated system. This general data and information are stored in the log files of the respective server. Among other things, the (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our websites (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our websites, (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 for security purposes in the event of attacks on our information technology systems can be recorded.

When using this general data and information, we generally do not draw any conclusions about the Data Subject. Rather, this information is required to (1) correctly deliver the content of our websites, (2) optimize the content of our websites and the advertising for them, (3) ensure the long-term functionality of our information technology systems and the technology of our websites and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. This anonymously collected data and information is therefore evaluated by us both statistically and with the aim of increasing data protection and data security in our organisation to ultimately ensure an optimal level of protection for the Personal Data processed by us. The data of the server log files are stored separately from all Personal Data provided by a Data Subject.

The purpose of processing is to avert danger and ensure IT security, as well as the aforementioned purposes. The legal basis is Art. 6 (1) (f) GDPR. Our legitimate interest is the protection of our information technology systems. The log files are deleted after the stated purposes have been achieved.

5. Contact possibility via the website and other data transfers and your Consent

Our website contains information that enables quick electronic contact with our organisation as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address) and possibly a telephone number. If a Data Subject contacts us by email, via a contact form, via an input form or in any other way, the Personal Data transmitted by the Data Subject will be stored automatically. This Personal Data transmitted to us on a voluntary basis by a Data Subject is processed for the purposes of usage or contacting the Data Subject.

We obtain your Consent for the transmission, storage and Processing of your contact data and inquiries and for contacting you in accordance with Art. 6 (1) (a) GDPR and Art. 49 (1) (1) (a) GDPR as follows:

By transmitting your Personal Data, you voluntarily consent to the Processing of the Personal Data you have entered or transmitted for the purposes of processing the inquiry and contacting you. By transmitting your data to us, you also voluntarily give your explicit Consent in accordance with Art. 49 (1) (1) (a) GDPR to data transfers to third countries to and by the companies named in this Privacy Policy and for the purposes stated, in particular for such transfers to third countries for which there is or is not an adequacy decision by the EU/EEA and to companies or other bodies that are not subject to an existing adequacy decision on the basis of self-certification or other accession criteria and in which or for which there are significant risks and no suitable guarantees for the protection of your Personal Data (e.g. due to Section 702 FISA, Executive Order EO12333 and the CloudAct in the USA). When you gave your voluntary and explicit Consent, you were aware that there may not be an adequate level of data protection in third countries and that your data subject rights may not be enforceable. You can withdraw your Consent under data protection law at any time with effect for the future. The withdrawal of Consent does not affect the lawfulness of Processing based on Consent before its withdrawal. With a single action (entry and transmission), you give several Consents. These are Consents under EU/EEA data protection law as well as those under the CCPA/CPRA, ePrivacy and telemedia law, and other international legislation, which are required, among other things, as a legal basis for any planned further Processing of your Personal Data. With your action, you also confirm that you have read and taken note of this Privacy Policy.

6. Routine deletion and restriction of Personal Data

We process and store Personal Data for the period required to achieve the purpose of processing or if this has been provided for by the European legislator or another legislator in laws or regulations to which we are subject, or if a legal basis for the Processing exists.

If the purpose of processing no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, or if the legal basis for the Processing no longer applies, the Personal Data will be routinely restricted or deleted in accordance with the statutory provisions.

7. Rights of the Data Subject according to GDPR

a) Right to confirmation

Each Data Subject has the right to obtain from the Controller confirmation as to whether or not Personal Data concerning him or her is being processed.

If a Data Subject wishes to exercise this right, he or she may contact us at any time.

b) Right to information

Each Data Subject has the right to obtain from the Controller free information about the Personal Data stored about him/her and a copy of this data at any time. Furthermore, the European legislator has granted the Data Subject access to the following information:

• the purposes of processing,

• the categories of Personal Data that are processed,

• 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 organizations,

• 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 a right to lodge a complaint with a supervisory authority,

• if the Personal Data is not collected from the Data Subject: All available information about the origin of the data,

• the existence of automated decision-making, including Profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing for the Data Subject.

Furthermore, the Data Subject has a right to information as to 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 obtain information about the appropriate safeguards in connection with the transfer.

If a Data Subject wishes to exercise this right, he or she may contact us at any time.

c) Right to rectification

Each Data Subject has the right to demand the immediate correction of incorrect Personal Data concerning them. Furthermore, the Data Subject has the right to request the completion of incomplete Personal Data, including by means of a supplementary declaration, taking into account the purposes of the Processing.

If a Data Subject wishes to exercise this right, he or she may contact us at any time.

d) Right to erasure (right to be forgotten)

Each Data Subject has the right, to obtain from the Controller the erasure of Personal Data concerning him or her without undue delay, and the Controller shall have the obligation to erase Personal Data without undue delay where one of the following grounds applies, as long as the Processing is not necessary:

• Personal Data was collected or otherwise processed for purposes for which it is no longer necessary.

• The Data Subject withdraws Consent on which the Processing is based according to Art. 6 (1) (a) GDPR, or Art. 9 (2) (a) GDPR, and where there is no other legal ground 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.

• Personal Data was processed unlawfully.

• The deletion of Personal Data is necessary to fulfill 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 in accordance with Art. 8 (1) GDPR.

If one of the aforementioned reasons applies, and a Data Subject wishes to request the erasure of Personal Data stored by us, he or she may contact us at any time.

If we have made the Personal Data public and if our organisation is obliged to delete the Personal Data in accordance with Art. 17 (1) GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data Controllers who process the published Personal Data that the Data Subject has requested the deletion of all links to this Personal Data or of copies or replications of this Personal Data from these other data Controllers, insofar as the Processing is not necessary.

e) Right to Restriction of Processing

Each Data Subject has the right to obtain from the Controller 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 the Controller to verify the accuracy of the Personal Data.

• The Processing is unlawful, and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead.

• The Controller no longer needs the Personal Data for the purposes of the Processing, but they are required by the Data Subject for the establishment, exercise or defense of legal claims.

• The Data Subject has objected to Processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the Controller override those of the Data Subject.

If one of the aforementioned conditions is met, and a Data Subject wishes to request the restriction of the Processing of Personal Data stored by us, he or she may contact us at any time.

f) Right to data portability

Each Data Subject has the right to receive the Personal Data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another Controller without hindrance from the Controller to which the Personal Data have been provided, where 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, unless the Processing is 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, in 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.

If a Data Subject wishes to exercise this right, he or she may contact us at any time.

g) Right to object

Each Data Subject has the right to object, on grounds relating to his or her particular situation, at any time, to Processing of Personal Data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to Profiling based on these provisions.

In the event of an objection, we will no longer process the Personal Data unless we can demonstrate compelling legitimate grounds for the Processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims.

If we process Personal Data for direct marketing purposes, the Data Subject shall have the right to object at any time to Processing of Personal Data concerning him or her for such marketing. This also applies to Profiling insofar as it is associated with such direct advertising. If the Data Subject objects to us to the Processing for direct marketing purposes, we 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, to object to Processing of Personal Data concerning him or her by us for scientific or historical 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 public interest.

If a Data Subject wishes to exercise this right, he or she may contact us at any time. The Data Subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated decisions in individual cases including Profiling

Each Data Subject has the right not to be subject to a decision based solely on automated Processing, including Profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of 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 which also lays down suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests, or (3) is 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 Data Subject and a data Controller, or (2) it is based on the Data Subject's explicit Consent, we shall implement suitable measures to safeguard the Data Subject's rights and freedoms and 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 a Data Subject wishes to exercise this right, he or she may contact us at any time.

i) Right to withdraw Consent under data protection law

Each Data Subject has the right to withdraw Consent to the Processing of Personal Data at any time.

If a Data Subject wishes to exercise this right, he or she may contact us at any time.

8. General purpose of Processing, categories of processed data and categories of recipients

The general purpose of processing of Personal Data is the handling of all activities relating to the Controller, customers, interested parties, business partners or other contractual or pre-contractual relationships between the aforementioned groups (in the broadest sense) or legal obligations of the Controller. This general purpose applies if no more specific purposes for specific Processing are specified.

The categories of Personal Data that we process are customer data, prospective customer data, employee data (including applicant data) and supplier data. The categories of recipients of Personal Data are public bodies, external bodies, internal processing, intragroup processing and other bodies.

A list of our Processors and data recipients in third countries and, if applicable, international organizations is either published on our website or can be requested from us free of charge.

9. Legal basis for the Processing

Art. 6 (1) (a) GDPR serves as the legal basis for Processing operations for 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 party, as is the case, for example, when Processing operations are necessary for the supply of goods or to provide any other service or consideration, Processing is based on Art. 6 (1) (b) GDPR. The same applies to such Processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If we are subject to a legal obligation which requires the Processing of Personal Data, such as for the fulfillment of tax obligations, Processing is based on Art. 6 (1) (c) GDPR.

In rare cases, it may be necessary to process Personal Data 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 in our organisation and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other Third Party. The Processing would then be based on Art. 6 (1) (d) GDPR.

If the Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller, the legal basis is Art. 6 (1) (e) GDPR.

Ultimately, Processing operations could be based on Art. 6 (1) (f) GDPR. This legal basis is used for Processing operations which are not covered by any of the abovementioned legal grounds, if Processing is necessary for the purposes of the legitimate interests pursued by our organisation or by a Third Party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data. We are permitted to carry out such Processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed, for example, if the Data Subject is a customer of the Controller (Recital 47 Sentence 2 GDPR).

10. Legitimate interests in Processing pursued by the Controller or a Third Party and direct marketing

If the Processing of Personal Data is based on Art. 6 (1) (f) GDPR and no more specific legitimate interests are stated, our legitimate interest is the performance of our business activities for the benefit of the well-being of our staff and our shareholders.

We may send you direct advertising about our own goods or services that are similar to the goods or services you have requested, commissioned or purchased. You may object to direct advertising at any time (e.g. by email). You will not incur any costs other than the transmission costs according to the basic rates. The Processing of Personal Data for direct marketing purposes is based on Art. 6 (1) (f) GDPR. The legitimate interest is direct marketing.

11. Duration for which the Personal Data is stored

The criterion for the duration of the storage of Personal Data is the respective statutory retention period. If there is no statutory retention period, the criterion is the contractual or internal retention period. After this period has expired, the corresponding data is routinely deleted if it is no longer required to fulfill or initiate a contract. This applies in particular to all Processing operations for which no more specific criteria have been defined.

12. Legal or contractual provisions for the provision of Personal Data; necessity for the conclusion of the contract; obligation of the Data Subject to provide the Personal Data; possible consequences of non-provision

We would like to inform you that the provision of Personal Data is partly required by law (e.g. tax regulations) or may also result from contractual obligations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a Data Subject to provide us with Personal Data that must subsequently be processed by us. For example, Data Subjects are obliged to provide us with Personal Data if our organisation concludes a contract with them. Failure to provide Personal Data would mean that the contract with the Data Subject could not be concluded. The Data Subject must contact us before providing Personal Data. We will inform the Data Subject on a case-by-case basis whether the provision of the Personal Data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the Personal Data and what the consequences would be if the Personal Data were not provided.

13. Existence of automated decision-making

As a responsible company, we do not normally use automated decision-making or Profiling. If, in exceptional cases, we carry out automated decision-making or Profiling, we will inform the Data Subject either separately or via a sub-item in our Privacy Policy (here on our website). In this case, the following applies:

Automated decision-making, including Profiling, may take place if (1) this is necessary for the conclusion or performance of a contract between the Data Subject and us, or (2) this is permissible on the basis of Union or Member State legislation to which we are subject and this legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the Data Subject, or (3) this takes place with the explicit Consent of the Data Subject.

In the cases referred to in Art. 22 (2) (a) and (c) GDPR, we shall implement suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests. In these cases, you have the right to obtain human intervention on the part of the Controller, to express your point of view and to contest the decision.

Meaningful information on the logic involved and the scope and intended effects of such Processing for the Data Subject will be provided in this Privacy Policy where applicable.

14. Recipients in a third country and appropriate or adequate safeguards and how to obtain a copy of them or where they are available.

According to Art. 46 (1) GDPR, the Controller or Processor may only transfer Personal Data to a third country if the Controller or Processor has provided appropriate safeguards and if enforceable rights and effective legal remedies are available to the Data Subjects. Appropriate safeguards can be provided by standard contractual clauses without the need for special approval from a supervisory authority, Art. 46 (2) (c) GDPR.

The EU standard contractual clauses or other appropriate safeguards are agreed with all recipients from third countries prior to the first transfer of Personal Data, or the transfers are based on adequacy decisions. Consequently, it is ensured that appropriate safeguards, enforceable rights and effective legal remedies are guaranteed for all Processing of Personal Data. Any Data Subject can obtain a copy of the standard contractual clauses or adequacy decisions from us. In addition, the standard contractual clauses and adequacy decisions are available in the Official Journal of the European Union.

Art. 45 (3) GDPR authorizes the European Commission to decide by means of an implementing decision that a non-EU country ensures an adequate level of protection. This means a level of protection for Personal Data that essentially corresponds to the level of protection within the EU. Adequacy decisions mean that Personal Data can flow from the EU (as well as from Norway, Liechtenstein and Iceland) to a third country without further obstacles. Similar regulations apply to the United Kingdom, Switzerland and some other countries.

In all cases where the European Commission, or a government or competent authority of another country, has decided that a third country ensures an adequate level of protection and/or a valid framework exists (e.g., EU-U.S. Data Privacy Framework, Swiss-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework), all transfers by us to the members of such frameworks (e.g. self-certified entities) are based solely on the membership of that entity in the respective framework or on the respective adequacy decisions. If we or one of our group companies is a member of such a framework, all transfers to us or our group company are based exclusively on the membership of the respective company in this framework. If we or one of our group companies is located in a third country with an adequate level of protection, all transfers to us or our group company are based solely on the respective adequacy decisions.

Any Data Subject can obtain a copy of the frameworks from us. In addition, the frameworks are also available in the Official Journal of the European Union or in the published legal materials or on the websites of data protection supervisory authorities or other authorities or institutions.

15. Right to lodge a complaint with a data protection supervisory authority

As the Controller, we are obliged to inform the Data Subject of the existence of the right to lodge a complaint with a supervisory authority. The right to lodge a complaint is regulated in Art. 77 (1) GDPR. According to this provision, without prejudice to any other administrative or judicial remedy, every Data Subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the Data Subject considers that the Processing of Personal Data relating to him or her infringes the General Data Protection Regulation. The right to lodge a complaint has been restricted by the EU legislator to the effect that it can only be exercised with a single supervisory authority (Recital 141 Sentence 1 GDPR). This provision is intended to avoid duplicate complaints in the same matter by the same Data Subject. If a Data Subject wishes to complain about us, it is therefore requested that only one supervisory authority is contacted.

16. Data protection for applications and in the application process

We collect and process Personal Data of applicants in the application process. Processing may also take place electronically. This is particularly the case if an applicant submits relevant application documents to us electronically, for example by email or via a web form on our or third-party websites.

For applicant data, the purpose of data processing is to carry out a review of the application in the application process. For this purpose, we process all data provided by you. Based on the data submitted as part of the application, we check whether you will be invited to an interview (part of the selection process). Then, in the case of generally suitable applicants, in particular during the interview, we process certain other Personal Data provided by you that is essential for our selection decision.

The legal basis for data Processing is Art. 6 (1) (b) GDPR, Art. 9 (2) (b) and (h) GDPR, Art. 88 (1) GDPR and national legislation.

If we do not conclude an employment contract with the applicant, the application documents will be deleted no later than six months after notification of the rejection decision, provided that no other legitimate interests of the Controller stand in the way of deletion. Another legitimate interest in this sense is, for example, the provision of evidence in legal proceedings.

17. Cookies and external connections, advertising IDs and your Consent

We use cookies, advertising IDs and external connections on our websites to improve the user experience on the one hand and to optimize our advertising and existing processes on the other. Cookies are small text files that are stored by your browser on your computer or system and that contain information to identify you more quickly during a visit. Almost all modern websites use cookies, advertising IDs and/or external connections.

Cookies usually have a so-called cookie ID. This ID is unique for each cookie and helps to distinguish your browser from others. This allows us to tailor our service to your needs and provide you with personalized user experience. Cookies also make it easier for you to use websites. For example, you do not have to log in to an online store or website every time a cookie remembers your data. You can deactivate the use of cookies in your browser at any time or delete stored cookies. We would like to point out that you may not be able to use all the functions on our websites without the stored cookies.

Advertising IDs are tied to your hardware. This ID is unique for each device and helps to distinguish your devices from others. This allows us to tailor our service to your needs and provide you with personalized user experience.

External connections are established to load and store external content and external cookies, and aim to optimize the user experience, advertising and our processes. The legal basis for the storage and reading of our cookies, advertising IDs and the establishment of external connections are the aforementioned legitimate interests (Art. 6 (1) (f) GDPR), unless separate Consent has been obtained from you in accordance with Art. 6 (1) (a) GDPR and/or Art. 49 (1) (1) (a) GDPR.

The following applies to all cookies, advertising IDs and external connections integrated in a cookie banner:

By clicking on the Consent button in our cookie banner, you voluntarily consent to the setting or activation of the respective cookies and external connections, as well as to the transmission of advertising IDs and operating system advertising IDs, such as AdIDs (Android), IDFAs (Apple) or the Windows advertising ID, (Consent pursuant to Art. 6 (1) (a) GDPR), the functions of which are explained in more detail in this Privacy Policy or in the documents or external links linked below and are therefore known to you. By clicking the Consent button, you also voluntarily give your explicit Consent in accordance with Art. 49 (1) (1) (a) GDPR to personalized advertising, Advertising ID transfers and for other data transfers to third countries for and by the companies and purposes mentioned in this Privacy Policy, in particular for such transfers to third countries for which there is or is not an adequacy decision of the EU/EEA and to companies or other entities that are not subject to an existing adequacy decision due to self-certification or other accession criteria, and in or for which there are significant risks and no appropriate safeguards for the protection of your Personal Data (e.g. due to Section 702 FISA, Executive Order EO12333 and the CloudAct in the USA). When giving your voluntary and explicit Consent, you were aware that there may not be an adequate level of data protection in third countries and that your data subject rights may not be enforceable. You can withdraw your Consent under data protection law at any time with effect for the future, e.g. by changing your cookie settings or deleting your cookies. The withdrawal of Consent does not affect the lawfulness of Processing based on Consent before its withdrawal. With a single action (pressing the Consent button), you give several Consents. These are Consents under EU/EEA data protection law as well as those under CCPA/CPRA, ePrivacy and telemedia law, and other international legislation, which are necessary, among other things, for storing and reading out information and are required as a legal basis for any planned further Processing of the data read out. Your Consent includes, in particular, explicit Consent to all downstream data Processing by third-party providers, which may also take place in unsafe third countries, in particular for personalized and targeted advertising, by all companies named in our Privacy Policy, as well as their sub-Processors and Controllers who receive or get transmitted data from these third-party providers or us within a data Processing chain. You are aware that you can refuse your Consent by clicking on the other button or, if necessary, make individual settings. By doing so, you also confirm that you have read and acknowledged this Privacy Policy.

For all cookies and external links included in our cookie banner, in addition to the legal bases listed in other areas of this Privacy Policy, the Consent pursuant to Art. 6 (1) (a) GDPR and/or the explicit Consent pursuant to Art. 49 (1) (1) (a) GDPR also apply as legal bases.

18. Subscription to our newsletter and your Consent

We inform our customers and business partners about offers and news at regular intervals by means of a newsletter. You are therefore given the opportunity to subscribe to our newsletter on our website. The Personal Data transmitted to us when you subscribe to the newsletter can be understood from the input mask used. You can only receive our newsletter if (1) you have a valid email address and (2) you have registered to receive the newsletter.

For legal reasons, a confirmation email is sent to the email address entered by a Data Subject for the first time for the newsletter using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the Data Subject has authorized the receipt of the newsletter. The legal basis for sending this double opt-in confirmation email is Art. 6 (1) (c) GDPR, as there is a legal obligation to send a newsletter only to confirmed recipients.

When registering for the newsletter, we also store the IP address assigned by the internet service provider (ISP) of the internet connection used by the Data Subject at the time of registration, as well as the date and time of registration. The storage of this data is necessary to be able to trace the (possible) misuse of a Data Subject's email address at a later point in time and therefore serves as legal protection for the Controller. The legal basis for Processing is also Art. 6 (1) (c) GDPR.

We obtain your Consent for the transmission and storage of your email address for the subscription to our newsletter in accordance with Art. 6 (1) (a) GDPR and Art. 49 (1) (1) (a) GDPR as follows:

By entering and transmitting your Personal Data, you voluntarily consent to the Processing of the Personal Data you have entered for the purpose of sending our newsletter. By entering and transmitting your data to us, you also voluntarily give your explicit Consent in accordance with Art. 49 (1) (1) (a) GDPR to data transfers to third countries to and by the companies named in this Privacy Policy and for the purposes mentioned, in particular for such transfers to third countries for which there is or is not an adequacy decision by the EU/EEA and to companies or other bodies that are not subject to an existing adequacy decision on the basis of self-certification or other accession criteria and in which or for which there are significant risks and no suitable guarantees for the protection of your Personal Data (e.g. due to Section 702 FISA, Executive Order EO12333 and the CloudAct in the USA). When you gave your voluntary and explicit Consent, you were aware that there may not be an adequate level of data protection in third countries and that your data subject rights may not be enforceable. You can withdraw your Consent under data protection law at any time with effect for the future. The withdrawal of Consent does not affect the lawfulness of Processing based on Consent before its withdrawal. With a single action (entry and transmission), you give several Consents. These are Consents under EU/EEA data protection law as well as those under the CCPA/CPRA, ePrivacy and telemedia law, and other international legislation, which are required, among other things, as a legal basis for any planned further Processing of your Personal Data. With your action, you also confirm that you have read and taken note of this Privacy Policy.

Your Consent to the Processing of Personal Data that you have given us for the storage of the email address for sending the newsletter can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking Consent. It is also possible to inform us of your wish to unsubscribe by other means (e.g. by telephone).

The Personal Data collected when registering for the newsletter will be used exclusively to send our newsletter. Furthermore, subscribers to the newsletter may be informed by email if this is necessary for the operation of the newsletter service or a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The Personal Data collected as part of the newsletter service will not be passed on to Third Parties.

By subscribing to our newsletter, you conclude a contract with us for the delivery of the newsletter, which is why the Processing in connection with the dispatch is based on Art. 6 (1) (b) GDPR as the legal basis. The contract can be terminated at any time.

19. Data protection provisions about the application and use of Webflow

Webflow is an innovative design and development platform that enables users to visually design professional websites without having to write code. Webflow offers a wide range of web design features, including responsive layouts, CMS, e-commerce and hosting services to meet the needs of designers, developers and businesses of all sizes.

When using Webflow services, Personal Data such as names, email addresses, payment information and professional information are processed. In addition, usage data such as information about websites created, interaction data and access statistics may be collected. This data is required to provide the services, manage user accounts, improve support and offer personalized experiences.

The company operating the service and therefore the recipient of the Personal Data is: Webflow, Inc., 398 11th St., Floor 2, San Francisco, CA 94103, USA.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of data processing lies in the use of the web design and development platform. Processing is based on the performance of a contract pursuant to Art. 6 (1) (b) GDPR, to which the Data Subject is a party, and on legitimate interests pursuant to Art. 6 (1) (f) GDPR, such as the use of an efficient platform, the optimization of the user experience and the use of effective customer support.

The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company operating the service may have concluded one of the EU standard contractual clauses with us. You can request a copy of the suitable or appropriate guarantees from us.

The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the company operating the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

Further information and the applicable data protection provisions of Webflow may be retrieved under https://webflow.com.

20. Data protection provisions about the application and use of Cloudflare

Cloudflare offers a wide range of services to improve the security, performance and reliability of websites and web applications. Core features include DDoS protection, web application firewall, content delivery network services, secure DNS services and more. By using Cloudflare, we can protect our online presence from cyber-attacks, improve the loading speed of our website and ensure the overall availability of our services.

When using Cloudflare services, data such as IP addresses, system configurations and network traffic information is processed. This information is necessary to ward off threats, optimize data traffic and provide insights into website usage.

The company operating the service and therefore the recipient of the Personal Data is: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of processing is the use of services to secure and optimize websites and web applications. Processing is based on Art. 6 (1) (f) GDPR, whereby our legitimate interest lies in ensuring the security, performance and reliability of our online presence.

The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. Cloudflare, Inc. may have concluded one of the EU standard contractual clauses with us. You can request a copy of the suitable or appropriate safeguards from us.

The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the company operating the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

Further information and the applicable data protection provisions of Cloudflare, Inc. can be found at https://www.cloudflare.com.

21. Data protection provisions about the application and use of jsDelivr

jsDelivr is a public, free content delivery network that enables developers to efficiently host and deliver web libraries, jQuery plugins, CSS frameworks, fonts and other JavaScript resources. By using jsDelivr, web developers can improve the load times of their websites by ensuring that these resources are loaded from servers that are geographically closer to the end users.

When using jsDelivr, data such as users' IP addresses, type of resources requested, time of access and browser information are processed. This data is mainly collected for the provision of the service, performance optimization and security purposes. jsDelivr uses data protection and security measures to protect the data collected, with particular attention paid to compliance with the General Data Protection Regulation and other data protection laws.

The company operating the service and thus the recipient of the Personal Data is: Prospect One Sp.z.o.o., ul. Krolweska 65A/1, 30-081, Krakow, Poland.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of processing is the efficient provision of web content via the CDN. The Processing is carried out on the basis of legitimate interests in accordance with Art. 6 (1) (f) GDPR, namely optimizing the loading times of websites, improving the user experience and ensuring the security of the service.

The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the company operating the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

Further information and the applicable data protection provisions of jsDelivr may be retrieved under https://www.jsdelivr.com.

22. Data protection provisions about the application and use of jQuery

jQuery is a widely used JavaScript library used by web developers to simplify and speed up HTML document management, event handling, animation and Ajax interactions. The use of jQuery on our website serves to create a smoother and more interactive user experience. When visiting our website, jQuery can be used to collect certain data, such as information about user behavior and interactions on the site.

The Processing takes place indirectly and is primarily aimed at improving website performance and user-friendliness. jQuery itself, as a client-side library, stores or processes Personal Data on its own servers. jQuery is executed in the user's browser and can be used for dynamic content updates by also transmitting data to external servers.

The operating company of jQuery is the OpenJS Foundation, 1 Letterman Dr, Ste D4700, San Francisco, California, USA.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of using jQuery is to improve the user experience on our website through an efficient interaction experience. Processing is based on Art. 6 (1) (f) GDPR, whereby our legitimate interest lies in the provision and use of a functional, user-friendly and visually appealing website.

The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company operating the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate guarantees from us.

The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the company operating the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

jQuery's Privacy Policy is available at https://jquery.com/.

23. Data protection provisions about the application and use of Amazon CloudFront

Amazon CloudFront is a global content delivery network. CloudFront accelerates the delivery of static and dynamic web content, such as .html, .css, .js files and multimedia content, to users by distributing content across a global network of data centers. This improves website and application load speeds, reduces latency and increases security through integration with other Amazon Web Services such as Amazon S3, Elastic Load Balancing and Amazon EC2.

When using Amazon CloudFront, data such as IP addresses, device information, request URLs and timestamps can be processed to efficiently serve user requests and ensure security.

The company that operates the service and thus the recipient of personal data is: Amazon.com, Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, USA. For data subjects in the EU and EEA, Amazon EU S.à.r.l., 38 avenue John F. Kennedy, L-1855 Luxembourg, acts as contact and representative within the meaning of Art. 27 GDPR. The representative under national law in the United Kingdom is: Amazon UK Services Ltd., 1 Principal Place, Worship Street, London, EC2A 2FA, United Kingdom. The representative under Art. 14 of the Federal Act on Data Protection (FADP) in Switzerland is: Amazon Web Services Switzerland GmbH, Mythenquai 10, 8002 Zürich, Switzerland.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of using Amazon CloudFront is the efficient delivery of web content and the improvement of the performance of websites and applications and IT security. Processing is based on Art. 6 (1) (f) GDPR, whereby our legitimate interest lies in the provision and use of a fast, reliable and secure online experience for users.

The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. Amazon Web Services may be a certified member of one or more of the Data Privacy Frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.

The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the company operating the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

Further information and the applicable data protection provisions of Amazon CloudFront can be found at https://aws.amazon.com.

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