Privacy policy

1. An overview of data protection

General information
The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter of data protection, please consult
our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available
under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this
Privacy Policy.

How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information
you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during
your website visit. This data comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data
may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived
personal data at any time without having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain circumstances. Furthermore, you have
the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection
related issues.

Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website.
Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration
below.

2. Hosting

We are hosting the content of our website at the following provider:

Hetzner
The provider is the Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter
referred to as Hetzner).
For details, please view the data privacy policy of Hetzner:
https://www.hetzner.com/de/rechtliches/datenschutz.
We use Hetzner on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable
depiction of our website possible. If appropriate consent has been obtained, the processing is carried out
exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of
cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning

of the TDDDG. This consent can be revoked at any time.

Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence,
we handle your personal data as confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises
data that can be used to personally identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains how, and for which purpose the
information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)
may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
CDS-Service-Gruppe (R+F Beteiligungs GmbH, CDS Service GmbH, CDS IT-Systeme GmbH sowie CDS
Business Services GmbH)
Edisonstraße 11 / 19,
32791 Lage,
Phone: +49 5232 9554-0
E-mail:
The controller is the natural person or legal entity that single-handedly or jointly with others makes
decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).

Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain
with us until the purpose for which it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally
permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or
Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of
explicit consent to the transfer of personal data to third countries, the data processing is also based on Art.
49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end

device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The
consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the
implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.
Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art.
6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest
according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in
the following paragraphs of this privacy policy.

Designation of a data protection officer
We have appointed a data protection officer.
Peter Seidel
Marienstr. 27
70178 Stuttgart
Phone: +49 711 89217-902
E-mail:

Information on the data transfer to third-party countries that are not secure under data
protection law and the transfer to US companies that are not DPF-certified
We use, among other technologies, tools from companies located in third-party countries that are not safe
under data protection law, as well as US tools whose providers are not certified under the EU-US Data
Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and
processed in these countries. We would like you to note that no level of data protection comparable to that
in the EU can be guaranteed in third countries that are insecure in terms of data protection law.
We would like to point out that the US, as a secure third-party country, generally has a level of data
protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is
certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances.
Information on transfers to third-party countries, including the data recipients, can be found in this Privacy
Policy.

Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also
requires the transfer of personal data to these external parties. We only disclose personal data to external
parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g.,
disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f)
GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose
personal data of our customers on the basis of a valid contract on data processing. In the case of joint
processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also
revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness
of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct
advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE

THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON
GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED
ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS
BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE
WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO
PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,
THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE
PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION
PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,
YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR
THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE
EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL
DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES
(OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
agency, in particular in the member state where they usually maintain their domicile, place of work or at the
place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other
administrative or court proceedings available as legal recourses.

Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of
a contract handed over to you or to a third party in a common, machine-readable format. If you should
demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about
your archived personal data, their source and recipients as well as the purpose of the processing of your data
at any time. You may also have a right to have your data rectified or eradicated. If you have questions about
this subject matter or any other questions about personal data, please do not hesitate to contact us at any
time.

Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is
concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in
the following cases:

In the event that you should dispute the correctness of your data archived by us, we will usually need
some time to verify this claim. During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to
demand the restriction of the processing of your data instead of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal
entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for important public interest reasons cited by
the European Union or a member state of the EU.

SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or
inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the address line of the browser
switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

4. Recording of data on this website

Contact form
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any
contact information provided therein will be stored by us in order to handle your inquiry and in the event
that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a
contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based
on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or
on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the
data, revoke your consent to the archiving of data or if the purpose for which the information is being
archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without
prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,
request) will be stored and processed by us for the purpose of processing your request. We do not pass these
data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a
contract or is required for the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.
6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be
revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

5. Analysis tools and advertising

Matomo

This website uses the open-source web analysis service Matomo.
Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This
enables us to find out, for instance, when which page views occurred and from which region they came. In
addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can
measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).
The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in
the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If appropriate
consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and §
25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s
end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any
time.

Hosting
We host Matomo with the following third-party provider:
Hetzner Online GmbH
Industriestr. 25
91710 Gunzenhausen

Objection

6. Newsletter

Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as
well as information that allows us to verify that you are the owner of the e-mail address provided and that
you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the
handling of the newsletter, we use newsletter service providers, which are described below.

Mailjet
This website uses Mailjet for sending newsletters. The provider is Mailgun Technologies Inc., 112 E Pecan Sr.
#1135, San Antonio, Texas 78205, USA.
Mailjet is a service with which, among other things, the dispatch of newsletters can be organized and
analyzed. The data entered by you for the purpose of receiving the newsletter will be stored on the servers
of Mailjet.

Data analysis by Mailjet
With the aid of Mailjet we are able to analyze our newsletter campaigns. For example, we can see if a
newsletter message has been opened and which links have been clicked. In this way, we can determine which
links have been clicked particularly often.
We can also see whether certain previously defined actions were performed after opening/clicking
(conversion rate). For example, we can tell if you have made a purchase after clicking on the newsletter.

Mailjet also allows us to classify newsletter recipients into different categories (“clusters”). For example, the
newsletter recipients can be subdivided according to age, gender, or place of residence. In this way, the
newsletters can be better adapted to the respective target groups. If you do not want Mailjet to analyze you,
you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every
newsletter message. Furthermore, you can unsubscribe from the newsletter directly on the website.
For detailed information on the functions of Mailjet, please refer to the following link:
https://www.mailjet.de/funktion/.
Mailjet’s privacy policy can be found at:
https://www.mailjet.de/sicherheit-datenschutz/.

Legal Basis
Data processing is based on your agreement (Art. 6(1)(a) GDPR). You can revoke this agreement at any time.
The legality of the data processing operations that have already taken place remains unaffected by the
revocation.
Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be
found here:
https://www.mailjet.de/av-vertrag/.

Storage period
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you
unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter
distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain
unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the
newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data
from the blacklist is used only for this purpose and not merged with other data. This serves both your
interest and our interest in complying with the legal requirements when sending newsletters (legitimate
interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to
the storage if your interests outweigh our legitimate interest.

Newsletter mailing to existing customers
If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently
be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct
advertising for our own similar goods or services will be sent via the newsletter. You can unsubscribe from
this newsletter at any time. There is a corresponding link in every newsletter for this purpose. In this case,
the legal basis for sending the newsletter is Art. 6 (1)(f) GDPR in conjunction with Section 7 (3) UWG.
After you unsubscribe from the newsletter distribution list, we may store your email address in a blacklist to
prevent future mailings to you. The data from the blacklist will only be used for this purpose and will not be
merged with other data. This serves both your interest and our interest in complying with the legal
requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1)(f) GDPR).
Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

7. Plug-ins and Tools

Vimeo Without Tracking (Do-Not-Track)
This website uses plugins of the Vimeo video portal. The provider is Vimeo Inc., 555 West 18th Street, New
York, New York 10011, USA.
Whenever you visit one of our pages featuring Vimeo videos, a connection with the servers of Vimeo is
established. In conjunction with this, the Vimeo server receives information about which of our sites you
have visited. Vimeo also receives your IP address. However, we have set up Vimeo in such a way that Vimeo
cannot track your user activities and does not place any cookies.
We use Vimeo to make our online presentation attractive for you. This is a legitimate interest on our part
pursuant to Art. 6(1)(f) GDPR. If a respective declaration of consent was requested (e.g. concerning the
storage of cookies), processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR; the given consent
may be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here:
https://vimeo.com/privacy.
For more information on the handling of user data, please consult Vimeo’s data privacy policy at:
https://vimeo.com/privacy
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5711.

8. Custom Services

Handling applicant data
We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services
on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of
the personal data collected from you in conjunction with the application process. We assure you that the
collection, processing, and use of your data will occur in compliance with the applicable data privacy rights
and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data
If you submit a job application to us, we will process any affiliated personal data (e.g., contact and
communications data, application documents, notes taken during job interviews, etc.), if they are required to
make a decision concerning the establishment or an employment relationship. The legal grounds for the
aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art.
6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a)
GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be
shared with individuals who are involved in the processing of your job application.
If your job application should result in your recruitment, the data you have submitted will be archived on the

grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship
in our data processing system.

Data Archiving Period
If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the
right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up
to 6 months from the end of the application procedure (rejection or withdrawal of the application).
Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage
serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required
after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only
take place when the purpose for further storage no longer applies.
Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory
data retention requirements preclude the deletion.

Admission to the applicant pool
If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all
documents and information from the application will be transferred to the applicant pool in order to contact
you in case of suitable vacancies.
Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The
submission agreement is voluntary and has no relation to the ongoing application procedure. The affected
person can revoke his agreement at any time. In this case, the data from the applicant pool will be
irrevocably deleted, provided there are no legal reasons for storage.
The data from the applicant pool will be irrevocably deleted no later than two years after consent has been
granted.