Thursday, June 30th, 2022

Data protection statement and disclaimer

Responsible for the processed data:

DIGITAL CIRCLES AG · CLOUD SOLUTIONS
Etzelblickstr. 1
8834 Schindellegi
Switzerland

Phone: +44 (0) 207 887 6527
E-Mail: info@digital-circles.com
 

Our data protection officer:

Dr. Sebastian Kraska
IITR Datenschutz GmbH
Marienplatz 2
80331 München

Telefon: +49 89 18917360
E-Mail: email@iitr.com

 

DISCLAIMER

 

1. Website content

The author takes no responsibility for the timeliness, accuracy, completeness or quality of the information provided. The author is in no event liable for damages of any kind incurred or suffered as a result of the use or non-use of the information presented on this website or the use of defective or incomplete information unless the author has been acting deliberately or in a wantonly negligent manner. The contents of this website are subject to confirmation and not binding. The author expressly reserves the right to alter, amend or remove pages, whole and in part, without prior notice or to discontinue publication for a period of time or even completely.

 

2. References and links

In cases of direct and indirect references to third-party Internet pages or other documents on the Internet (hyperlinks) the author is not responsible for, the author can only be made liable if the author was aware of the content of the website or if it would have been reasonable and technically feasible to prevent the use of websites with illegal content. The author hereby explicitly states that, at the time of setting the link, there was no evidence of illegal content on the respective website. The author has no influence on the current or future design, the content or the copyright of the linked website. Therefore, the author dissociates him-/herself explicitly from all changes concerning the contents of linked pages that were made after the link was set. This statement is valid for all links and references within the website created by the author as well as for links and references from third parties in guestbooks, discussion forums, lists of links and mailing lists. The provider of the linked page is exclusively responsible for illegal, defective or incomplete contents and especially for damages resulting from the use or non-use of the information presented on the linked page. The author referring to the page through a link is not liable for any of the above.

 

3. Copyright and acknowledgement of sources

The author aims to observe the copyright of any graphic, audio document, video sequence or text in all publications, to use his/her own graphics, audio documents, video sequences or texts or to make use of license free graphics, audio documents, video sequences or texts. All trade marks and brands mentioned on the website, including those protected by third parties, are without limitation subject to the provisions under the respective labelling law and the rights of the copyright holder. The sole mentioning of a trade mark on this website should not lead to the assumption that it is not protected by the rights of a third party! The author of the website has the exclusive copyright to all published objects created by him-/herself. The reproduction or use of any such graphics, audio documents, video sequences or texts in other electronic or printed publications is prohibited without the author's express consent.

 

4. Objection against advertising mails

Third parties are prohibited to send unsolicited information to mailing addresses, phone or fax numbers or e-mail addresses published on the imprint page or similar pages. We reserve the right to take legal action against anyone violating this prohibition by sending so-called spam.

 

PRIVACY POLICY

 

1. Data Protection Overview

When you visit this website, your personal data is processed. Personal data are all data with which you can be personally identified. The following notes explain which data we collect and for what purpose. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

1.1 Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. His contact details can be found at the beginning of this website.

1.2 How do we collect your data?

On the one hand, your data is collected when you voluntarily provide us with it. This may, for example, be data that you provide to us in the context of an application.

On the other hand, data is automatically collected by our IT systems when you visit this website. These are mainly technical data, e.g. Internet browser, type and version of operating system, time of access and IP address.

1.3 What do we use your data for?

Part of the data is collected in order to ensure the error-free provision of the website and the security of our website.

Another part of the data can be used to analyse your usage behaviour and for statistical evaluation of your interests.

1.4 What rights do you have in connection with your data?

You have the right to receive information free of charge at any time about the purpose, the categories of personal data processed, the recipient, the duration of storage and the origin of the data. You also have the right to demand the correction, deletion or restriction of the processing. For this, as well as for further questions regarding data protection, you can contact us at any time at the address given in the imprint. Furthermore, you have the right to complain to the responsible supervisory authority.

 

2. General Information and Compulsory Information

2.1 Privacy

The operator of this website takes the protection of your personal data very seriously. We treat your personal data with the utmost confidentiality and in accordance with the statutory data protection regulations and this privacy policy.

2.2 General data processing information

Personal data is only collected if you communicate it to us yourself. Apart from that, no personal data is collected. Any processing of your personal data that goes beyond the scope of the statutory permission is only possible on the basis of your express consent.

Legitimate grounds for processing personal data are to perform our contractual obligations towards our customers and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to maintain and develop our business.

Categories of recipients are public authorities in the event of priority legislation, external service providers or other contractors and other external bodies in so far as the data subject has given his consent or a transmission is permitted due to a prevailing interest.

2.4 Transfer of personal data to third countries.

If we transfer data to third countries, i.e. countries outside the European Union, the transfer will only take place in compliance with the legal requirements.

If the transfer of the data to a third country does not serve to fulfil our contract with you, if we do not have your consent, if the transfer is not necessary for the assertion, exercise or defence of legal claims and if no other exception according to Art. 49 GDPR applies, we will only transfer your data to a third country if an adequacy decision according to Art. 45 GDPR or suitable guarantees according to Art. 46 GDPR are available.

2.5 Duration of data storage

Unless a more specific duration of data storage has been stated within this privacy policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a legitimate 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., retention periods under tax or commercial law); in the latter case, the data will be deleted after these reasons no longer apply.

2.6 SSL or TLS Encryption

In compliance with the data protection regulations under Art. 32 GDPR, this site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser's address line when it changes from "http://" to "https://" and the lock icon is displayed in your browser's address bar.

If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.

2.7 E-Mail Communication

Security gaps can occur in e-mail communication, if the connection is not encrypted. An e-mail sent to a recipient can be intercepted and read by experienced Internet users. E-Mails are received by our office devices which processes the messages. If you send an e-mail to us (e. g. by completing the encrypted contact form), we assume that the staff is authorised to reply by e-mail. If you do not wish to receive an e-mail, we kindly ask you to consider alternative ways of communication, for example regular mail.

 

3. Data Collection on our Website in Detail

3.1 Cookies

Our website uses so-called “cookies”. Cookies do not damage your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, more effective and safer. Cookies are small text files that are stored on your computer and saved by your browser.

On the one hand we use so-called “session cookies”. They are automatically deleted at the end of your visit. Other cookies remain stored on your end device until you delete them yourself. These cookies enable us to recognize your browser the next time you visit us. You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies the functionality of this website may be limited.

Cookies that are required for the electronic communication process, are stored on the basis of Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimised provision of his services. Insofar as other cookies (e.g., cookies for the analysis of your surfing behaviour) are stored, these are integrated separately in this data protection declaration.

3.2 Server Log Files

The provider of the website automatically collects and stores information in so-called sever log files, which your browser automatically sends to us when you visit the website. The following data is recorded:

  • Browser type and browser version
  • Operating system used
  • Referred URL
  • Host name of the accessing computer
  • Date and time of the server request
  • IP address

These files are not merged with other data sources.

The basis for data processing is Art. 6 Para. 1 lit. b, f GDPR, which permits the processing of data for the fulfilment of a contract or a pre-contractual measure, as well as for the protection of legitimate interests. The legitimate interest here lies in the technically faultless and optimized provision of our services to you.

For reasons of technical security, in particular to prevent attacks on our web server, we store these data for a short period of time. It is impossible to discern the identity of individual persons based on this data. After seven days at the latest, the data is anonymized by shortening the IP address at the domain level, so that it is no longer possible to establish any reference to the individual user. The anonymized data will also be processed for statistical purposes. We don’t compare any data to data in other databases or forward them to third parties, even in excerpts.

3.3 Contact Forms

If you send us inquiries using the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the request and in case of follow-up questions. We do not pass on this data without your consent.

This data is processed on the basis of Article 6 Para. 1 lit. b GDPR, provided that your request is related to the performance of a contract or 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 inquiries sent to us (Art. 6 Para. 1 lit. f GDPR) or on your consent (Art. 6 Para. 1 lit. a GDPR) if this was queried.

The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions - in particular retention periods - remain unaffected.

3.4 Enquiries by E-Mail, Telephone, Fax

If you contact us directly by e-mail, telephone or fax, your inquiry including all personal data (name, contact data, inquiry itself) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.

The processing is based on the basis of Art. 6 Paragraph 1 lit. b GDPR in so far as your enquiry is connected with the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on your consent pursuant to Art. 6 Paragraph 1 lit. a GDPR and/or on our legitimate interest pursuant to Art. 6 Paragraph 1 lit. f. GDPR, as we have a legitimate interest in the effective processing of the inquiries addressed to us. You can revoke this consent at any time. An informal notification by e-mail to us is sufficient for this purpose. Your revocation does not affect the lawfulness of the processing that has taken place on the basis of the consent until the revocation.

The data you have sent us by contact request will remain with us until you request us to delete it, revoke your consent to store it or for the purpose for which it was stored ceases to apply, e.g. due to the completed processing of your request. Mandatory legal provisions – in particular retention periods – remain unaffected.

 

4. Information about other data processing procedures

4.1 Applications

If you apply to us (e.g. in electronic form), we will store the data you provide (e.g. e-mail address, name, address, telephone number). Your application documents will only be made available to authorized employees who are directly involved in the application process.

The purpose of the data processing is the necessary decision on the establishment of an employment relationship (Art. 88 paragraph 1 GDPR in conjunction with § 26 BDSG).

Your data will be stored by us until the application procedure is completed. If your application is rejected, your application documents will be stored with us for a further 6 months due to the possibility of legal action in accordance with the General Equal Treatment Act (§ 15 Paragraph 4 AGG) and then deleted or anonymised. In the event of anonymisation, the data is then only available to us as so-called metadata without direct personal reference for statistical analysis (e.g. proportion of women or men, number of applications in a specific period of time, etc.).

If an employment relationship with us arises following your application, we will store the personal data collected during the application process at least for the duration of the employment relationship.

4.2 Employee and Contractor Data

If you are employed or contracted with Digital Circles AG, personal data required for contract execution will be processed and stored. If necessary, additional data on the basis of your express consent will be processed and stored.

The purpose of the data processing is the execution of the contract and is based on the basis of Art. 6 Paragraph 1 lit. b GDPR. As part of contractual execution, processors could also be used outside the European Union.

The duration of data storage depends on the statutory storage requirements. Categories of recipients are public authorities in the event of priority legislation, external service providers or other contractors and other external bodies in so far as the data subject has given his consent or a transmission is permitted due to a prevailing interest.

4.3 Customer Data / Prospective Parties’ Data

Customer and prospective parties’ data are communicated for contract execution. We process personal data to be able to deliver services to our customers and users and to run, maintain and develop Digital Circles AGs business. If necessary, additional data for processing on basis of your express consent will be processed and stored. Digital Circles AG, also processes, if necessary, the personal data of the contracting party’s employees. In this connection, our interest is on the initiation, conclusion and execution of such contractual relationships.

The purpose of the data processing is the execution of the contract and is based on the basis of Art. 6 Paragraph 1 lit. b GDPR. We use personal data in order to conduct its contractual obligations. As part of contractual execution, processors could also be used outside the European Union.

The duration of data storage depends on the statutory storage requirements. Categories of recipients are public authorities in the event of priority legislation, external service providers or other contractors and other external bodies in so far as the data subject has given his consent or a transmission is permitted due to a prevailing interest.

4.4 Registration as a User

If you wish to register as a user on our website, the personal data you provide (e-mail address) will be processed and stored. The processing is carried out for the purpose of opening a user account.

The legal basis for the processing is your express consent in accordance with Art. 6 Para. 1 lit a GDPR.

We do not pass on this data without your consent. You can revoke this consent at any time. All you need to do is send us an informal e-mail. Your revocation does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.

4.5 Video Conference/webinar software

If you use video conferencing software/webinar software data is processed and stored (e.g. first name, last name, email address, optional: audio transmission data; optional: video transmission data; optional: use of chat function), as well as the data your system is technically required to process in order to establish a connection with the provider of the conference software.

The purpose of processing is conduction video conferences/webinar. Categories of recipients could include external service providers or other contractors (e.g., for data processing and hosting) and other external bodies insofar as the data subject has given his or her consent or transmission is permitted due to a prevailing interest.

Video conferences can only be recorded if participants have provided documented consent in advance. The technical data will be deleted if they are no longer required. The duration of data storage depends on the statutory storage requirements.

 

5. Analysis Tools and Advertising

5.1 Matomo (formerly known as Piwik)

Your visit to our website is registered through Matomo® Analytics, formerly known as Piwik, a cookie used for web analysis. The information generated by the cookie is used exclusively for statistical purposes and the improvement of the internet presence and server. No personal data is stored or passed on to third parties. The IP address is anonymized before storage.

The use of this analysis tool is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the anonymized analysis of user behavior in order to optimize both its website and its advertising. Insofar as a corresponding consent has been requested (e.g. consent to store cookies), the processing is carried out exclusively on the basis of Art. 6 (1) lit. a DSGVO.

The consent can be revoked at any time.

IP anonymization

When analyzing with Matomo, we use IP anonymization. Your IP address is shortened before the analysis, so that it can no longer be clearly assigned to you.

Hosting

We host Matomo exclusively on our own servers, so that all analysis data remains with us and is not passed on. 

Information generated

In detail, this information is as follows: Two bytes of the IP address of the user's calling system Title of the visited page, search term (through which visitors come to the page), search engines, page URL, number of pages visited, visitor's location (country), provider, browser, operating system, screen resolution, browser plugins, visit times, visit duration, entry pages, exit pages, downloads, referring websites.

Important notice

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

5.2 Third-party cookies

This website does not embed any third-party-components. If a third-party-component or -website is mentioned, it will always be opened in an extra window/tab and the user will be informed about opening another website before.

 

6. Data subject's rights

6.1 Revocation of consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke any consent already given at any time. For this purpose, an informal notification by e-mail to us is sufficient. Your revocation does not affect the lawfulness of the processing that has taken place on the basis of the consent until the revocation.

6.2 Right to data portability

You also have the right to have data, which we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a structured, common and machine-readable format. If you request the direct transfer of the data to another responsible party, this will only take place to the extent that this is technically feasible.

6.3 Information, correction, deletion, restriction, objection

You have the right to obtain, at any time and free of charge, information on your personal data processed and stored by us, the purposes of the data processing, the categories of personal data processed, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right of rectification, cancellation, restriction of processing or opposition, the existence of a right of appeal, the origin of your data, if not collected by us, as well as the existence of automated decision making including profiling and, where applicable, meaningful information on the details thereof. You can contact us at any time at the address given in the imprint for this purpose and for further questions on data protection.

6.4 How to use the rights

These rights may be invoked by sending an e-mail, including the following information: name and contact detail. We may request the provision of additional information necessary to confirm the identity of the data subject. Please contact us by mail at datenschutz@digital-circles.com

6.5 Right of complaint to the competent supervisory authority

If you believe that the processing of your personal data concerning you is in breach of data protection regulations, you have the right to complain to the competent supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our office.

The responsible body for data processing on this website is:

State Commissioner for Data Protection and Freedom of Information in Bavaria

 

7. Applicability and Changes

Due to the further development of our website and offers on it or due to changed legal or official requirements, it may become necessary to change this privacy policy. The current privacy policy can be accessed by you at any time on our website.


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