windream GmbH – Data Privacy Policy According to the EU GDPR

Sect. 1 General

We will process your personal data (e.g. title, name, address, e-mail address, phone number) solely in accordance with the provisions of the German data protection law and the data protection law of the European Union (EU). The following provisions will inform you, besides the information about the processing purposes, recipients, legal bases and storage periods, also about your rights and the controller for your data processing. This privacy policy applies only to our websites. If you are directed to other sites via links on our pages, please familiarise yourself with the respective use of your data there.

Sect. 2 Contact us

(1) Purpose of data processing

Your personal data you provide us by e-mail, contact form etc., will be processed to answer your inquiries. You are not obliged to provide us with your personal data but we would not be able to answer your inquiries sent by e-mail without your e-mail address.

(2) Legal basis

a) If your explicit consent is given for the processing of your data, the legal ground for this processing is set out in Art. 6 (1) (a) of the GDPR.

b) If your personal data is processed for the purpose of contract performance, the legal ground for this processing is set out in Art. 6 (1) (b) of the GDPR.

c) The legal ground for all other cases (especially when using a contact form) is set out in Art. 6 (1) (f) of the GDPR.

You have the right to object at any time to the processing of data which was performed according to Article 6 (1)(f) of GDPR and which does not serve direct marketing for reasons arising from your particular situation.

In the case of direct marketing, however, you may object to the processing at any time without stating any reasons.

(3) Legitimate interest

Our legitimate interest in data processing is to communicate with you in a timely manner and to answer your queries cost-effectively. If you provide us with your address, we reserve the right to use it for direct postal marketing. You can protect your interest in data protection by transferring of data efficiently (e.g. using a pseudonym).

(4) Recipient categories

Provider of hosting, service provider for direct marketing

(5) Duration of storage

Your data will be deleted if it can be inferred from the circumstances that your queries or questions have been completely clarified.

However, if a contract is concluded, the data required by commercial and tax law will be retained by us for the periods as required by law, i.g. generally for ten years (cf. § 257 HGB, § 147 AO).

(6) Right of revocation

You have the right to revoke your consent for processing at any time in compliance with your consent.

Sect. 3 Further Informationen

Use of the Google services: Google reCaptcha, YouTube, Google Fonts, Google Ads

The parent company Google LLC is located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
The USA is considered by the European Court of Justice to be a country with a level of data protection that is inadequate by EU standards. In particular, there is a risk that your data may be processed by U.S. authorities for control and monitoring purposes, possibly without the possibility of legal recourse

Use of Google reCaptcha for newsletter registration

We use the Google service reCaptcha to determine whether a person or computer is making a particular entry in our contact or newsletter form. Google uses the following information to determine whether you are a human being or a computer: IP address of the end device used, the website you visit with us and on which the captcha is integrated, the date and duration of the visit, the identification data of the type of browser and operating system used, Google account if you are logged in at Google, mouse movements on the reCaptcha areas as well as tasks in which you have to identify images. The legal basis for the described data processing is Art. 6 para. 1 lit. f of the Basic Data Protection Regulation. There is a legitimate interest on our part in this data processing to ensure the security of our website and to protect us from automated entries (attacks).

Embedded YouTube videos

YouTube videos are embedded on our website. The provider of the corresponding plugins and the corresponding website at www.youtube.com is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA (hereinafter referred to as "YouTube"). YouTube is a service of Google.

For this purpose we use the extended data protection mode offered by YouTube, which prevents the automatic setting of cookies. Please note that the videos will only be shown to you if you agree to the setting of cookies via the banner of our website.

When you click on a YouTube video for viewing, a connection to YouTube servers is established. YouTube will be informed from which website you click on the video. If you are logged in to your YouTube account, YouTube can personally track your browsing habits. You can prevent this by first logging out of your YouTube account.

When a YouTube video is launched, the provider uses cookies to collect information about your user behaviour. YouTube may also display third-party plugins that allow you to link or share videos. windream has no influence on these services and the associated data collection by YouTube.

Further information on data protection at "YouTube" can be found in the privacy policy of this service, available at: www.google.de/intl/de/policies/privacy/

Google Fonts

We integrate the fonts Fira Sans of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: fonts.google.com; privacy policy: policies.google.com/privacy.

Google Ads

Our website uses Google Ads conversion tracking. This is an analysis service of Google, Inc, Amphitheatre, Parkway, Mountain View, California 94043, USA. The service places a cookie on your PC when you visit our website via a Google ad. We do not use the cookie to identify you personally, it is only used to identify whether a user has come to our website via a paid advertisement. We can thus determine which advertisement was used to visit our website and whether you subsequently accessed our website again. We use the information obtained from this analysis to better tailor our advertising to your needs, and you can find more detailed information together with Google's privacy policy at: policies.google.com/privacy

Online meetings, conference calls and webcasts via "Zoom"

We would like to inform you in the following about the processing of personal data in connection with the use of "Zoom". We use the "Zoom" tool to conduct telephone conferences, online meetings, video conferences and/or webcasts (hereinafter: "online meetings"). "Zoom" is a service of Zoom Video Communications, Inc. which is based in the USA.

The person responsible for data processing which is directly related to the execution of "Online Meetings" is windream GmbH.

Note: If you access the "Zoom" website, the provider of "Zoom" is responsible for data processing. However, it is only necessary to call up the "Zoom" website in order to download the software for the use of "Zoom".

You can also use "Zoom" if you enter the respective meeting ID and, if necessary, other access data for the meeting directly in the "Zoom" app.

If you do not want to or cannot use the "Zoom" app, the basic functions can also be used via a browser version, which you can also find on the "Zoom" website.

Different types of data are processed when using "Zoom". The scope of the data also depends on the information you provide before or during participation in an "online meeting".

The following personal data are subject to processing:

User information: first name, last name, telephone, address, city, country/region, postal code, e-mail address, profile picture (optional)
Meeting metadata: Topic, description (optional), participant IP addresses, equipment/hardware information

On record: MP4 file of all video, audio and presentation recordings, M4A file of all audio recordings, text file of online meeting chat.

When dialing in by phone: Information on incoming and outgoing phone number, country name, start and end time. If necessary, further connection data such as the IP address of the device can be saved.

Text, audio and video data: You may be able to use the chat, question or survey functions in an "online meeting". To this extent, the text entries you make are processed in order to display and, if necessary, log them in the "online meeting". In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device will be processed for the duration of the meeting. You can turn off or mute the camera or microphone yourself at any time using the "Zoom" applications.

In order to participate in an "online meeting" or to enter the "meeting room", you must at least provide information about your name.

We use "Zoom" to conduct "online meetings". If we want to record "online meetings", we will inform you transparently in advance and - if necessary - ask for your consent. The fact of the recording will also be displayed in the "Zoom" app.

If it is necessary for the purpose of recording the results of an online meeting, we will log the chat content. However, this will usually not be the case.

In the case of using the Zoom Webinar function, we may also process questions asked by participants for the purposes of recording and follow-up webcasts.

If you are registered as a user at "Zoom", reports on "online meetings" (meeting metadata, telephone dial-in data, questions and answers when using the Zoom Webinar function, survey function when using the Zoom Webinar function can be stored for up to one month at "Zoom".

Automated decision-making within the meaning of Art. 22 DSGVO is not used.

Personal data processed in connection with participation in "online meetings" will not be passed on to third parties unless they are specifically intended for disclosure. Please note that content from "online meetings", as well as in personal meetings, often serves precisely to communicate information with customers, interested parties or third parties and is therefore intended for disclosure.

Other recipients: The provider of "Zoom" necessarily obtains knowledge of the above-mentioned data, insofar as this is provided for in our contract processing agreement with "Zoom".

"Zoom" is a service provided by a provider from the USA. A processing of personal data thus also takes place in a third country. The USA is considered by the European Court of Justice to be a country with a level of data protection that is inadequate by EU standards. In particular, there is a risk that your data may be processed by U.S. authorities for control and monitoring purposes, possibly without the possibility of legal recourse.

 

Sect. 4 Web Analysis with Google Analytics

(1) Purpose of data processing

This website uses Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland ("Google"). Google Analytics uses so-called “cookies”, small text files, which are placed on your computer to analyze how you use the website. The information generated by the cookie about your use of this website will be transmitted and saved on server in the United States by Google. If the anonymizeIP function is activated on this website, Google will shorten your IP address in advance within the member states of the European Union or in other states which are parties to the Agreement on the European Economic Area. Only in exceptional cases Google will transmit the full IP address on server in the United States and will shorten there. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activities and providing other services related to website and internet usage for the website operators.

(2) Legal basis

The legal basis for such processing is set out in Article 6 (1) (a) of the GDPR.

(3) Recipient categories

Google and its partners.

(4) Transfer to a third country

Google Ireland Limited is a company affiliated with Google LLC. Google LLC is located in the USA (1600 Amphitheatre Parkway, Mountain View, CA 94043).
The USA is considered by the European Court of Justice to be a country with an inadequate level of data protection according to EU standards. In particular, there is a risk that your data may be processed by U.S. authorities, for control and monitoring purposes, possibly without the possibility of legal recourse.

(5) Duration of Storage

26 months

(6) Right of objection

You can prevent the installation of the cookies in your browser settings. If you choose to change your settings you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: optout

You may also generate blocking by setting an opt-out cookie. If you want to prevent the future collection of your data when you visit this website, please click here: Disable Google Analytics

Sect. 5 Newsletter

(1) Purpose of data processing

We send our newsletters with the provider CleverReach GmbH & Co. KG from Germany. When subscribing to the newsletter, your e-mail address will be used for advertising purposes, i.e. within the scope of the newsletter we will inform you in particular about products from our range. For statistical purposes, we can evaluate which links are clicked in the newsletter. In doing so, it is not recognizable for us which specific person has clicked. You have expressly given us your consent separately or, if applicable, in the course of the ordering process.

(2) Legal basis

The legal basis for such processing is set out in Article 6 (1) (a) of the GDPR.

(3) Recipient categories

Newsletter delivery providers and internal departments

(4) Duration of storage

Your e-mail address will be stored for the newsletter mailing only for the duration of the desired registration. After you have unsubscribed from the newsletter, we blacklist your email address so that you no longer receive unwanted advertising from us.

(5) Right of revocation

You may revoke your consent at any time with effect for the future. If you no longer wish to receive the newsletter, you may unsubscribe as follows:By a log-out link in the newsletter E-mail to newsletter@windream.com

5.1. HubSpot

On this website, we use the HubSpot service for various purposes. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Telephone: +353 1 5187500.

Hubspot is an integrated software solution that we use to cover various aspects of our online marketing. These include, but are not limited to:

Email marketing, social media publishing & reporting, reporting, contact management (e.g. user segmentation & CRM), landing pages and contact forms.

Our sign-up service allows visitors to our website to learn more about our company, download content, and provide their contact information and other demographic information. This information, as well as the content of our website, is stored on servers of our software partner HubSpot. They can be used by us to contact visitors to our website and to determine which of our company's services are of interest to them. All information we collect is subject to this Privacy Policy. We use all information collected exclusively to optimize our marketing measures.

More information about HubSpot's privacy policy legal.hubspot.com/privacy-policy

More information from HubSpot regarding EU data protection regulations legal.hubspot.com/security

You can find more information about the cookies used by HubSpot here knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser und hier knowledge.hubspot.com/privacy-and-consent/hubspot-cookie-security-and-privacy

As part of the optimization of our marketing measures, the following data may be collected and processed via Hubspot:

Geographical position
Browser type
Navigation information
Referrer URL
Performance data
Information about how often the application is used
Mobile Apps Data
HubSpot subscription service credentials
Files that are displayed in the field
Domain Names
Pages viewed
Aggregate Usage
Version of the operating system
Internet Service Providers (ISPs)
IP address
Device identifier
Duration of the visit
Where the application was downloaded from
Operating system
Events that occur within the application
Access Hours
Clickstream data
Device model and version
In addition, we also use Hubspot to provide contact forms. 

The legal basis for the processing of the data is your consent in accordance with Art. 6 (1) (a) GDPR. If you do not want HubSpot to collect and process the data shown, you can refuse your consent in the cookie banner or revoke it at any time with effect for the future. 

The personal data will be kept for as long as they are necessary to fulfill the purpose of processing. The data will be deleted as soon as they are no longer required to achieve the purpose.

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: www.dataprivacyframework.gov/s/participant-search/participant-detail

Forms
We use the HubSpot service to provide the following online forms. For this purpose, we forward your data to HubSpot, which processes the data exclusively on our behalf. See HubSpot's privacy policy.

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: www.dataprivacyframework.gov/s/participant-search/participant-detail

Sect. 6 Your rights as a data subject

If your personal data is being processed, you are the ‘data subject’ in terms of GDPR and you have the following rights towards us, the controller:

1. Right to information

You may request us to provide information about your personal data processed by us under Article 15 of the GDPR.

2. Right to rectification

If your personal data provided to us is not up to date or not accurate you have the right to ask for modifications to your personal data under Article 16 of the GDPR. You also have the right to request us to complete an incomplete data.  

3.  Right to erasure

You have the right to have your personal data erased and ask for deletion of your data under Article 17 of the GDPR.

4. Right to restriction of processing

You have the right to restrict the processing your personal data under Article 18 of the GDPR.

5. Right to data portability

You have the right referred to in Article 20 of the GDPR to receive your personal data provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

6. Right to revoke the consent given under data protection law

You have the right referred to in paragraph 3 of Article 7 to withdraw your given consent based on the data protection provisions at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.

7. Right to lodge a complaint with a supervisory authority

If you consider that the processing of personal data relating to you infringes the GDPR, you have the right referring to in Article 77 of the GDPR to complain to the supervisory authority against the processing of your personal data (in particular in the Member State of your habitual residence, place of work or place of the alleged infringement ).

Please also note your right of objection under Article 21 GDPR:

a) In general: reasoned objection required

If the processing of personal data concerning you takes place in order

- to perform our overriding legitimate interest (legal basis: Article 6 (1f) GDPR)

or

- to safeguard the public interest (legal basis: Article 6 (1e) GDPR),

you are entitled to object to the processing at any time for reasons arising from your particular situation; this also applies to profiling based on the provisions of the GDPR.

In the event of objection, we will no longer process the personal data concerning you unless we can prove compelling grounds for processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims;

b) Special case of direct marketing: simple objection is sufficient

If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing and without stating reasons; this includes profiling to the extent that it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

Responsible for data processing:
windream GmbH
Wasserstraße 219
44799 Bochum
Phone: 023497340
info@windream.com

Contact details of our data protection officer:
HEC Harald Eul Consulting GmbH
Datenschutz + Datensicherheit
Auf der Höhe 34
50321 Brühl
datenschutz@windream.com

In accordance with Articles 13 and 14 of the General Data Protection Regulation (GDPR), windream GmbH informs you in detail about the processing of your personal data during the application procedure.

Responsible party within the meaning of the GDPR
windream GmbH
Wasserstraße 219
44799 Bochum
Telephone: 023497340
info@windream.com

Group of companies
windream GmbH is part of the dataglobal Group, which consists of the following companies:
- dataglobal Group GmbH, Heilbronn
- dataglobal GmbH, Heilbronn
- eleven cyber security GmbH, Berlin
- windream GmbH, Bochum

Collection and processing of personal data
The collection and processing of your data is necessary in accordance with Art. 6 (1) b) GDPR for the performance of contractual services or for the implementation of pre-contractual measures. We process your data for the following specific purposes:
- Processing your application
- in the event of the establishment of an employment relationship, also for the implementation of the employment relationship.
The collection and processing is based on legitimate interests pursuant to Art. 6 (1) f) GDPR:
- Establishment of an employment relationship within the dataglobal group of companies.
In this context, your data will only be processed by a restricted group of persons who are necessary for the application process within the dataglobal Group.
 

Data we receive from third parties
If we receive your data from personnel service providers, the processing is carried out according to Art. 6 f) DSGVO in conjunction with. Art. 9 para. 2 e) GDPR. Processing for any other purpose does not take place.
 

Categories of data collected
We process such data that you provide to us in your application forms. These are, among others:

- Name
- Your address
- contact details
- certificates

Special categories of personal data (e.g. health data) are processed if we are legally obliged to do so according to Art. 9 (2) f) GDPR.

Duration of processing

Once the desired training position or job has been awarded, your applicant data will remain stored until the purpose for which it was collected no longer applies.
Immediately after the award of the training position or job, the data of applicants who have not entered into an employment relationship will be blocked for any use other than the clarification of applicant claims. In the event of a legitimate interest, e.g. in the case of a duty to provide evidence in legal proceedings, the data may also be processed after the award of the training position or job.
 

Passing on your data
Your applicant data will not be passed on to third parties, in particular to countries outside the European Union or to an international organization, unless you have given your prior consent. Companies that are part of the dataglobal Group of companies do not count as third parties.

Your rights as a data subject
According to the GDPR, you have the right to:
- Information about the processing of your data
- Correction or deletion of your data
- Restriction of processing (only storage possible)
- Objection to the processing
- Data portability
- Revocation of your given consent with effect for the future
- Complaint to the data protection supervisory authority. The supervisory authority of the state of North Rhine-Westphalia is responsible for this.
If your personal data was collected on the basis of legitimate interests of the controller (Art. 6 para. 1 p. 1 lit. f GDPR), you have the right to object to the processing. To exercise your right, simply send an email to datenschutz@windream.com

If you have any questions, please contact our data protection officer in confidence:
HEC Harald Eul Consulting GmbH, Rolf Schnitzler, datenschutz@windream.com.

windream GmbH informs you in detail about the processing of your personal data according to Article 13 and 14 of the General Data Protection Regulation (GDPR).

Responsible party within the meaning of the GDPR
windream GmbH
Wasserstraße 219
44799 Bochum
Telephone: 023497340
info@windream.com

Processing of personal data
The collection and processing of your data is necessary for the fulfillment of contractual services or for the implementation of pre-contractual measures. We process your data for the following specific purposes:
According to Article 6 (1) b) of the GDPR on the basis of the contract concluded with you:
- Fulfillment of the contractual service
- payment processing
- Provision of contractually ordered software and services
- support requests
According to Article 6 (1) a) of the GDPR on the basis of the consent given by you:
- Sending you interesting information about products and promotions

Categories of collected data
- Name, first name
- function
- Contact data e.g. e-mail, telephone number

Data we receive from third parties
If we receive your data from third parties, such as the BVMW or other business associations, the processing is carried out in accordance with Art. 6 f) GDPR in conjunction with. Art. 9 para. 2 e) DSGVO. Processing for any other purpose does not take place.

Duration of processing
We process your data only for as long as is necessary to fulfill the contractual services and maintain the customer relationship. We comply with the statutory retention and storage periods in accordance with the provisions of the HGB and the AO (maximum 6 and 10 years).
Unless you object, we will use your data to maintain and intensify our business relationship for our mutual benefit. Should you wish your data to be deleted, we will take appropriate measures without delay, provided that legal requirements are not affected and do not conflict with our actions.

Passing on your data
Your contact data will be passed on to subcontractors in order to fulfill the contractually agreed services.

Your rights as a data subject
- According to the GDPR, you have the right to:
- Information about the processing of your data
- Correction or deletion of your data
- Restriction of processing (only storage possible)
- Objection to the processing
- Data portability
- Revocation of your given consent with effect for the future
- Complaint to the supervisory authority. The supervisory authority of the state of North Rhine-Westphalia is responsible for this.
If your personal data was collected on the basis of legitimate interests of the controller (Art. 6 (1) f) GDPR), you have the right to object to the processing. To exercise your right, simply send an e-mail to datenschutz@windream.com. 

If you have any questions, please contact our data protection officer in confidence:
HEC Harald Eul Consulting GmbH, Rolf Schnitzler, datenschutz@windream.com.

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