Privacy Policy
We are very pleased about your interest in our company. Data protection is of particular importance to the management of Enpageo GmbH. Use of the Enpageo GmbH websites is generally possible without providing any personal data. However, if an affected person wishes to use special services of our company through our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the affected person.
The processing of personal data, such as the name, address, email address or telephone number of an affected person, always takes place in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to Enpageo GmbH. Through this privacy policy, our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, affected persons are informed of the rights to which they are entitled through this privacy policy.
Enpageo GmbH, as the party responsible for processing, has implemented numerous technical and organizational measures to ensure the most complete protection possible of the personal data processed via this website. Nevertheless, internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every affected person is free to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
The privacy policy of Enpageo GmbH is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for both the public and our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
In this privacy policy, we use, among others, the following terms:
a) personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter affected 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.
b) affected person
Affected person means any identified or identifiable natural person whose personal data is processed by the party responsible for processing.
c) Processing
Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, 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 means the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling means 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 analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f) Pseudonymization
Pseudonymization means the processing of personal data in such a way that the personal data can no longer be attributed to a specific affected person without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or party responsible for processing
Controller or party responsible for processing means 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
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient means a natural or legal person, public authority, agency or other 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
Third party means a natural or legal person, public authority, agency or body other than the affected person, the controller, the processor and persons who, under the direct authority of the controller or the processor, are authorized to process personal data.
k) Consent
Consent means any freely given, specific, informed and unambiguous indication of the affected person's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
2. Name and address of the party responsible for processing
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 other provisions of a data protection nature is:
Enpageo GmbH Lenbachstr. 16 D-10245 Berlin Germany Email: info@enpageo.de Website: www.enpageo.de
3. Collection of general data and information
The Enpageo GmbH website collects a series of general data and information with every call-up of the website by an affected person or an automated system. This general data and information is stored in the server's log files. The following may be collected: (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 referrer), (4) the sub-websites accessed via an accessing system on our website, (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 the purpose of averting danger in the event of attacks on our information technology systems.
When using this general data and information, Enpageo GmbH does not draw any conclusions about the affected person. 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 advertising, (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 prosecution in case of a cyberattack. This anonymously collected data and information is therefore statistically evaluated by Enpageo GmbH and further evaluated with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by an affected person.
To improve our website, we use Matomo, a privacy-compliant open-source software for analyzing usage behavior. Among other things, information about pages visited, time spent and devices used is collected anonymously. Evaluation takes place exclusively on our own servers, without disclosure to third parties.
You have the option of preventing actions you take here from being analyzed and linked. This will protect your privacy but will also prevent the owner from learning from your actions and improving usability for you and other users.
4. Registration on our website
The affected person has the option of registering on the website of the party responsible for processing by providing personal data. Which personal data is transmitted to the party responsible for processing is determined by the respective input mask used for registration. The personal data entered by the affected person is collected and stored exclusively for internal use by the party responsible for processing and for its own purposes. The party responsible for processing may arrange for the data to be passed on to one or more processors, for example a parcel delivery service, which likewise uses the personal data exclusively for internal use attributable to the party responsible for processing.
By registering on the website of the party responsible for processing, the IP address assigned by the affected person's Internet Service Provider (ISP), as well as the date and time of registration, are also stored. This data is stored against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the party responsible for processing. This data is generally not passed on to third parties unless there is a statutory obligation to pass it on or the disclosure serves the purpose of criminal prosecution.
The registration of the affected person, with voluntary provision of personal data, serves the party responsible for processing to offer the affected person content or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided at registration at any time or to have it completely deleted from the data stock of the party responsible for processing.
The party responsible for processing shall, at any time, upon request, provide each affected person with information about which personal data about the affected person is stored. Furthermore, the party responsible for processing shall correct or delete personal data at the request or indication of the affected person, provided this does not conflict with statutory retention obligations. All employees of the party responsible for processing are available to the affected person as contacts in this regard.
5. Contact option via the website
The Enpageo GmbH website contains information which enables, due to legal requirements, a quick electronic contact to our company as well as direct communication with us, which also includes a general address for so-called electronic mail (email address). If an affected person contacts the party responsible for processing by email or via a contact form, the personal data transmitted by the affected person is automatically stored. Such personal data transmitted on a voluntary basis by an affected person to the party responsible for processing is stored for the purposes of processing or contacting the affected person. There is no disclosure of this personal data to third parties.
6. Routine erasure and blocking of personal data
The party responsible for processing processes and stores the personal data of the affected person only for the period necessary to achieve the purpose of storage or as provided for by the European legislator or other legislators in laws or regulations to which the party responsible for processing is subject.
If the purpose of storage ceases to apply or a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with statutory provisions.
7. Rights of the affected person
a) Right of confirmation
Every affected person has the right, granted by the European legislator, to obtain from the party responsible for processing confirmation as to whether personal data concerning them is being processed. If an affected person wishes to exercise this right of confirmation, they may at any time contact an employee of the party responsible for processing.
b) Right of access
Every person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the party responsible for processing, at any time and free of charge, information about the personal data stored about them and a copy of this information. Furthermore, the European legislator has granted the affected person access to the following information:
• the purposes of the processing • the categories of personal data concerned • 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 rectification or erasure of personal data concerning them, or restriction of processing by the controller, or to object to such processing • the existence of the right to lodge a complaint with a supervisory authority • where the personal data are not collected from the affected person: any available information as to their source • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the affected person
Furthermore, the affected person has the right to obtain information as to whether personal data have been transferred to a third country or to an international organization. Where this is the case, the affected person also has the right to obtain information about the appropriate safeguards relating to the transfer.
If an affected person wishes to exercise this right of access, they may at any time contact an employee of the party responsible for processing.
c) Right to rectification
Every person affected by the processing of personal data has the right, granted by the European legislator, to obtain the immediate rectification of inaccurate personal data concerning them. Furthermore, the affected person has the right to have incomplete personal data completed, including by means of a supplementary statement, taking into account the purposes of the processing.
If an affected person wishes to exercise this right to rectification, they may at any time contact an employee of the party responsible for processing.
d) Right to erasure (right to be forgotten)
Every person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and insofar as processing is not necessary:
• The personal data were collected or otherwise processed for purposes for which they are no longer necessary. • The affected person withdraws consent on which the processing was based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing. • The affected person objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the affected person objects to the processing pursuant to Art. 21(2) GDPR. • The personal data have been unlawfully processed. • Erasure of the personal data is required for compliance with a legal obligation under Union or Member State law to which the controller is subject. • The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.
If one of the above reasons applies and an affected person wishes to arrange for the erasure of personal data stored by Enpageo GmbH, they may at any time contact an employee of the party responsible for processing. The employee of Enpageo GmbH will arrange for the erasure request to be complied with immediately.
Where the personal data have been made public by Enpageo GmbH and our company as controller is obliged pursuant to Art. 17(1) GDPR to erase the personal data, Enpageo GmbH will take reasonable steps, including technical measures, taking account of available technology and the cost of implementation, to inform other controllers processing the published personal data that the affected person has requested erasure by such other controllers of any links to, or copies or replications of, that personal data, insofar as processing is not required. The employee of Enpageo GmbH will arrange the necessary steps in individual cases.
e) Right to restriction of processing
Every person affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller restriction of processing where one of the following applies:
• The accuracy of the personal data is contested by the affected person, for a period enabling the controller to verify the accuracy of the personal data. • The processing is unlawful and the affected person 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 processing, but they are required by the affected person for the establishment, exercise or defense of legal claims. • The affected person has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the affected person.
If one of the above conditions applies and an affected person wishes to request restriction of personal data stored by Enpageo GmbH, they may at any time contact an employee of the party responsible for processing. The employee of Enpageo GmbH will arrange for the restriction of processing.
f) Right to data portability
Every person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was provided, provided the 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, provided the processing is not 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 affected person has the right to have personal data transmitted directly from one controller to another, where technically feasible and where doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the affected person may at any time contact an employee of Enpageo GmbH.
g) Right to object
Every person affected by the processing of personal data has the right, granted by the European legislator, to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
Enpageo GmbH will no longer process the personal data in the event of an objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the affected person, or the processing serves the establishment, exercise or defense of legal claims.
Where Enpageo GmbH processes personal data for direct marketing purposes, the affected person has the right to object at any time to processing of personal data for the purpose of such marketing. This also applies to profiling to the extent it is related to such direct marketing. If the affected person objects to Enpageo GmbH's processing for direct marketing purposes, Enpageo GmbH will no longer process the personal data for these purposes.
In addition, the affected person has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them which is carried out by Enpageo GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the affected person may contact any employee of Enpageo GmbH directly. The affected person is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Every person affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided the decision (1) is not necessary for entering into, or the performance of, a contract between the affected person and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which lays down suitable measures to safeguard the affected person's rights and freedoms and legitimate interests, or (3) is based on the affected person's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the affected person and the controller, or (2) is based on the affected person's explicit consent, Enpageo GmbH shall implement suitable measures to safeguard the affected person's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
If the affected person wishes to assert rights relating to automated decisions, they may at any time contact an employee of the party responsible for processing.
i) Right to withdraw data protection consent
Every person affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.
If the affected person wishes to exercise their right to withdraw consent, they may at any time contact an employee of the party responsible for processing.
10. Data protection in applications and the application process
The party responsible for processing collects and processes the personal data of applicants for the purpose of processing the application procedure. Processing may also take place electronically. This is particularly the case if an applicant submits corresponding application documents electronically, for example by email or via a web form on the website, to the party responsible for processing. If the party responsible for processing concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with statutory provisions. If no employment contract is concluded with the applicant by the party responsible for processing, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the party responsible for processing preclude erasure. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
11. Data protection provisions regarding the use of LinkedIn
The party responsible for processing has integrated components of LinkedIn Corporation on this website. LinkedIn is an internet-based social network that enables users to connect with existing business contacts and to establish new business contacts. More than 400 million registered persons use LinkedIn in more than 200 countries. This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. For data protection matters outside the USA, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
With each individual call-up of our website that is equipped with a LinkedIn component (LinkedIn plug-in), this component causes the browser used by the affected person to download a corresponding representation of the LinkedIn component. Further information about LinkedIn plug-ins can be accessed at developer.linkedin.com/plugins. During this technical process, LinkedIn becomes aware of which specific sub-page of our website was visited by the affected person.
If the affected person is simultaneously logged in to LinkedIn, LinkedIn recognizes, with each call-up of our website by the affected person and for the entire duration of the respective stay on our website, which specific sub-page of our website the affected person visits. This information is collected by the LinkedIn component and assigned by LinkedIn to the affected person's respective LinkedIn account. If the affected person clicks a LinkedIn button integrated on our website, LinkedIn assigns this information to the affected person's personal LinkedIn user account and stores this personal data.
LinkedIn always receives, via the LinkedIn component, information that the affected person has visited our website, provided that the affected person is simultaneously logged in to LinkedIn at the time of calling up our website; this takes place regardless of whether the affected person clicks on the LinkedIn component or not. If such transmission of this information to LinkedIn is not desired by the affected person, they can prevent this transmission by logging out of their LinkedIn account before calling up our website.
LinkedIn offers, at www.linkedin.com/psettings/guest-controls, the option to unsubscribe from email messages, SMS messages and targeted advertisements as well as to manage advertising settings. LinkedIn also uses partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame, which may set cookies. Such cookies can be rejected at www.linkedin.com/legal/cookie-policy. The applicable data protection provisions of LinkedIn are available at www.linkedin.com/legal/privacy-policy. LinkedIn's cookie policy is available at www.linkedin.com/legal/cookie-policy.
12. Legal basis for the processing
Art. 6(1)(a) GDPR serves our company 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 affected person is a party, as is the case, for example, with processing operations necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the affected person or of another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, 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 above legal bases, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests, fundamental rights and freedoms of the affected person. Such processing operations are particularly permissible because they were specifically mentioned by the European legislator. It took the view that a legitimate interest could be assumed if the affected person is a customer of the controller (recital 47, sentence 2 GDPR).
13. Legitimate interests in the processing pursued by the controller or a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.
14. Duration for which the personal data will be stored
The criterion for the duration of storage of personal data is the respective statutory retention period. After the period expires, the corresponding data is routinely deleted, provided it is no longer required for the fulfillment or initiation of a contract.
15. Statutory or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the affected person to provide the personal data; possible consequences of failure to provide
We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). It may sometimes be necessary for a contract to be concluded that an affected person provides us with personal data, which must subsequently be processed by us. The affected person is, for example, obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the affected person could not be concluded. Before providing personal data, the affected person must contact one of our employees. Our employee will inform the affected person, on a case-by-case basis, whether the provision of 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 consequences the failure to provide the personal data would have.
16. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.