Data protection is of a particularly high priority for the DAT UG (hereinafter referred to as "DAT"). The use of the website of DAT is possible without any indication of personal data; however, if a data subject wants to use special services via our website or our web/mobile applications, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to DAT. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, DAT has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website or our applications. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data in regards to services on our website to us via alternative means, e.g. by telephone.
The data protection declaration of DAT is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
Any data subject may, at any time, contact us with all questions and suggestions concerning data protection.
The website of DAT collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet page, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, DAT does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, DAT analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
The data subject has the possibility to register on the website of the controller with the indication of personal data to download specific content, request for details about the offering of DAT or to initiate a quick electronic contact to DAT.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to contact DAT to change the personal data specified during the registration, or to have them completely deleted from the data stock of the controller.
On the website of DAT, users are given the opportunity to subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
DAT informs its customers and business partners regularly by means of a newsletter about updates. The newsletter may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter shipping. A confirmation email will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
The personal data collected as part of a registration for the newsletter will be used to send our newsletter or to inform about changes or issues related to our newsletter service. In addition, subscribers to the newsletter may be contacted via email by our team in case of a legitimate interest of DAT – e.g. a recipient shows behaviour of strong interest for our initiative.
The newsletter of DAT contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of newsletter content. Based on the embedded tracking pixel, DAT may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. DAT automatically regards a withdrawal from the receipt of the newsletter as a revocation.
DAT offers users the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of DAT. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blog posts. Blog posts may usually be commented by third parties.
The comments made in the blog of DAT may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.
DAT collects and stores information about companies and employees of these companies who have entered as partner into our initiative in order to take part in workshops and other forms of activities organised by DAT.
DAT uses CRM systems. The personal information in these systems is limited to the business contact information such as first name, last name, e-mail address, function, title and telephone numbers. The employees of the contractual partners may voluntarily provide DAT with information on other, possibly private, contact details (for example, business and private mobile phone numbers). These are also stored by DAT.
At any time, DAT will provide information to each data subject on request about which personal data about the data subject is stored. In addition, DAT corrects or deletes personal data at the request or notice of the person concerned, insofar as this does not conflict with any contractual or statutory retention requirements.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by DAT, he or she may, at any time, contact any DAT employee – in particular the data protection officer or the corresponding account manager. The contact person shall promptly ensure that the erasure request is complied with immediately.
Where DAT has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of DAT will arrange the necessary measures in individual cases.
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 DAT, he or she may at any time contact any employee of DAT – in particular the corresponding account manager or the data protection officer – who will arrange the restriction of the processing.
In order to assert the right to data portability, the data subject may at any time contact any employee of DAT – in particular the corresponding account manager or the data protection officer.
DAT shall no longer process the personal data in the event of the objection, 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 defence of legal claims.
If DAT processes 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 applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to DAT to the processing for direct marketing purposes, DAT 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 DAT 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.
In order to exercise the right to object, the data subject may contact any employee of DAT – in particular the corresponding account manager or the data protection officer. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
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, the DAT GmbH 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 the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the DAT GmbH.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of DAT – in particular the corresponding account manager or the data protection officer.
DAT has integrated components of Facebook on its website and its blog. Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
With each request of an individual page of the website or the blog of DAT, into which a Facebook component (Facebook plug-ins or pixel) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins and Pixel may be accessed under https://developers.facebook.com/docs/plugins/ and https://developers.facebook.com/docs/facebook-pixel. During the course of this technical procedure, Facebook is made aware of what specific page of our website was visited by the data subject.
On this website and the blog, DAT has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
For the web analytics through Google Analytics DAT uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
On this website and the blog, DAT has integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.
DAT has integrated components of the LinkedIn Corporation on this website and the blog. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
On this website and the blog, DAT has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called 'tweets,' e.g. short messages, which are limited to a number characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.
On this website and the blog, DAT has integrated components of XING. XING is an Internet-based social network that enables users to connect with existing business contacts and to create new business contacts. The individual users can create a personal profile of themselves at XING. Companies may, e.g. create company profiles or publish jobs on XING.