Privacy Policy

September 2024

We (i.e., the company providing you with this privacy policy or referred to in the legal notice as the operator of this site) take the protection of your personal data seriously. This privacy policy outlines how we collect, use, disclose, transfer, and store your personal data (“process”). The personal data collected depends on the context of your interactions with us, the products, services, and features you use, your location and the law applicable at the time.

1. Processing of Personal Data Related to Your Use of Our Websites, Applications, and Online Services

Data Categories and Purpose of Processing

When using our external and internal websites, applications, or online services (individually referred to as an “Online Offer”), we process the following categories of personal data:

- Your contact information, such as first and last name, business address, business phone number, business mobile number, and business email address,

- Organizational information, including position and company name,

- Additional personal data you provide in contact and other forms on an Online Offer,

- Information you provide in case of a support request, survey, comment, or forum entry,

- Information collected automatically during the use of an Online Offer, such as your device and user ID, operating system details, pages and services you visited during your visit, and the date and time of a user request.

We process your personal data for the following purposes:

- To enable you to use the services and functions of the Online Offers, including creating and managing your online account, conducting updates, security, and troubleshooting measures,

- To provide customer support and improve and develop our Online Offers,

- To invoice your use of an Online Offer, determine your identity, and enable user authentication,

- To process your request or instruction,

- To handle your order and provide related information and offers to you,

- To contact you with information and offers related to our products and services and send you further marketing information or contact you as part of customer satisfaction surveys, as described in section 3,

- To enforce our terms of use, assert or defend legal claims, and to prevent and counteract fraudulent and similar actions, including attacks on our IT infrastructure.

Online Offers Provided by Your Company

In some cases, our online offers are provided to you by the company you are employed with. If you use an Online Offer provided by your company, the processing of personal data entered by you or your company into the content of the Online Offer is performed on behalf of and according to the instructions of your company as part of a data processing agreement between your company and us. In this case, your company is responsible for data protection. If you have questions about personal data we process on behalf of your company, please contact your company.

2. Processing of Personal Data Related to Your Use of Our Marketplaces

Data Categories and Purpose of Processing

During the use of our marketplaces (each a “Marketplace”), we process the following categories of personal data:

- Your contact information, such as first and last name, business address, business phone number, business mobile number, and business email address,

- Organizational information, including position and company name,

- Payment data, such as information required for payment transactions or fraud prevention, including credit card information and card security codes,

- Additional personal data you provide in contact and other forms on a Marketplace,

- Information provided during a support request, survey, comment, or forum entry;

- Legally required information for compliance and export control screenings, such as date of birth, nationality, residence, ID numbers, information on relevant court proceedings and other legal disputes, and

- Information collected automatically during the use of a Marketplace, such as your device and user ID, operating system details, pages and services you visited during your visit, and date and time of a user request.

We process your personal data for the following purposes:

- Communication with you about our services and products, e.g., to handle your requests or provide technical information about products,

- Planning, executing, and managing the (contractual) business relationship, e.g., handling orders for products and services, collecting payments, accounting and billing, and performing deliveries, maintenance, or repairs,

- Contacting you with information and offers related to our products and services and conducting additional marketing activities and customer satisfaction surveys as described in section 4,

- Maintaining and protecting the security of our products and services and our websites, preventing and detecting security risks, fraudulent activities, or other criminal or harmful activities,

- Complying with legal obligations (e.g., tax and commercial retention duties), existing obligations to perform compliance screenings (to prevent financial crime or money laundering), as well as our policies and industry standards, and

- Settling legal disputes, enforcing existing contracts, and asserting, exercising, and defending legal claims.

3. Processing of Personal Data from Business Partners

Data Categories and Purpose of Processing

In collaborations with business partners, we process personal data of end consumers and contacts at customer, prospect, distributor, supplier, and partner companies (each a “Business Partner”):

- Contact information, such as first and last names, business address, business phone number, business mobile phone number, and business email address,

- Organizational information, including position and company name,

- Payment data, such as information required for payment transactions or fraud prevention, including credit card information and card security numbers,

- Additional information necessary for processing a project or contractual relationship with us or voluntarily provided by business partners, e.g., within orders, requests, or project details,

- Personal data obtained from publicly available sources (including corporate or professional social networks and websites), information databases, or credit agencies, and

We process personal data for the following purposes:

- Communication with business partners regarding products, services, and projects, e.g., handling business partners’ requests or providing technical information about products,

- Planning, executing, and managing the (contractual) business relationship between the Business Partner and us, e.g., handling orders for products and services, collecting payments, accounting and billing, and performing deliveries, maintenance, or repairs,

- Creating a personal profile with business-related information about interactions between you and us with the aim of providing you and the company you work for relevant information and suitable offers regarding services and products and improving our personal communication with you,

- Conducting market analyses, sweepstakes, competitions, or similar actions and events,

- Contacting you with information and offers related to our products and services and conducting additional marketing activities and customer satisfaction surveys as described in section 4,

- Maintaining and protecting the security of our products and services and our websites, preventing and detecting security risks, fraudulent activities, or other criminal or harmful activities,

- Settling legal disputes, enforcing existing contracts, and asserting, exercising, and defending legal claims.

4. Processing of Personal Data for Customer Satisfaction Surveys and Direct Marketing

Under applicable laws, we may use your contact details for direct marketing purposes (e.g., trade fair invitations, newsletters with information and offers about our products and services) and to conduct customer satisfaction surveys, including via email. You have the right to object to the use of your contact data for these purposes at any time by sending an email to info@adtouro.de or by using the opposition option provided in the message you received.

5. Processing of Personal Data in Connection with Your Application

If you apply for an open position with us, we process your personal data as described in the privacy policy of the adtouro recruiting portal or the application platform you are using.

6. Transfer and Disclosure of Personal Data

We only transfer your personal data as described below:

Companies and Partners

For the purpose and to the extent required for conducting our business relationship with you, we transfer your personal data to our companies and other third parties (e.g., partners and representatives).

For example, we distribute certain products and services only through local business relationships, and in this case, we transfer your personal data to our respective local companies or other partners who manage the business relationship with you.

Transactions on Our Marketplaces

Through our marketplaces, we also provide products, services, and offers from our companies and other parties. We transfer personal data of our customers in connection with these transactions to the respective company and/or other parties.

Service Providers

We commission companies and other enterprises to perform tasks on our behalf, such as manufacturers, service providers, IT services, or payment processing. These companies and other enterprises process personal data exclusively for the purpose of the commissioned products and services.

Other Parties

We transfer personal data in connection with complying with legal obligations or establishing, exercising, or defending rights or claims to other parties (e.g., for court and arbitration proceedings, to regulatory, law enforcement, and government authorities, to lawyers and advisers).

Recipients of your personal data may reside outside the country in which you live.

Personal data published by you via online offers (e.g., in chatrooms or forums) may be accessible globally to other registered users of the respective online offer.

7. Retention Periods

Unless a specific retention period is indicated at the time of collection (e.g., in the context of a consent declaration), your personal data will be deleted as soon as it is no longer required to fulfill the purpose of storage, unless legal retention obligations (e.g., commercial and tax retention obligations) prevent deletion.

8. Your Rights

Under applicable data protection law, you may have the right to:

- request confirmation of whether we are processing personal data about you and obtain access to the personal data we process,

- request the correction of inaccurate personal data,

- request the deletion of personal data we process,

- request the restriction of processing personal data,

- request the transfer of personal data that you have actively provided to us,

- object to the processing of personal data for reasons arising from your particular situation, or

- withdraw a declared consent.

9. Data Security

We take appropriate technical and organizational measures to protect personal data from accidental or unlawful destruction, use, alteration, and unauthorized disclosure or access.

10. Contact Person

Our data protection organization assists with any questions regarding data protection. Complaints can also be addressed to our data protection organization and the rights mentioned in this privacy policy can be exercised.

Our data protection organization can be contacted at datenschutz@adtouro.de.

Our data protection organization is always striving to address and remedy your inquiries and complaints.

In addition to contacting the data protection organization, you also have the option to contact the competent data protection supervisory authority at any time.

11. Processing of Personal Data within the Scope of the EU General Data Protection Regulation

This section applies if your personal data is processed by one of our companies based in the European Economic Area.

Data Processing Controller

Online Offers

The entity named in the legal notice of the Online Offer is the controller for the processing activities described in this privacy policy under the General Data Protection Regulation.

Marketplaces

The company identified as the operator of the marketplace is the data processing controller.

Personal Data of Business Partners in our Customer Relationship Systems

Contact information of business partners is shared, if applicable, in the context of your business relationship with us with other companies.

We and these companies are jointly responsible for the protection of your personal data (Article 26 General Data Protection Regulation). To ensure that you can easily and reliably exercise your data protection rights within this joint responsibility, we have agreed with these companies that you can exercise your rights described in Section 6 not only with the respective company but also centrally with SCAILE Technologies GmbH. Contact us at datenschutz@adtouro.de.

Legal Basis of Processing

The General Data Protection Regulation obligates adtouro to inform you about the legal basis of data processing.

Unless expressly indicated otherwise at the time of collection, the legal basis for data processing is:

- the performance and completion of a contract with you (Article 6 (1) (b) of the General Data Protection Regulation) (“Contract Performance”)

- compliance with legal obligations to which we are subject (Article 6 (1) (c) of the General Data Protection Regulation) (“Fulfillment of Legal Obligations”), or

- safeguarding our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation) (“Legitimate Interest in Processing”).

Our legitimate interest lies in processing your personal data for the purpose:

(i) of offering and operating the Online Offers and

(ii) in initiating, executing, and managing our business relationship.

If our legitimate interest in processing is listed as the legal basis for processing your personal data, we believe that your interests, fundamental rights, and freedoms are sufficiently considered, as:

(i) we regularly review the processing activities and underlying processes described in this privacy policy,

(ii) we consider the protection of your personal data in our processes, including the Binding Corporate Rules for the protection of personal data (adtouro Binding Corporate Rules),

(iii) we ensure the transparency of our processing activities and

(iv) you are entitled to the aforementioned rights in relation to our processing activities.

If you would like further information about the described balancing of interests, please contact our data protection organization at datenschutz@adtouro.de.

If you have expressly consented to the processing of your personal data in a specific case, this consent is the legal basis for the processing (Article 6 (1) (a) of the General Data Protection Regulation) (“Consent”).

Processing of Personal Data Related to Your Use of Our Online Offers - Purpose and Legal Basis

- Enabling the use of the services and functions of the Online Offers, including creating and managing your online account, conducting updates, security, and troubleshooting measures to provide customer support and improve and develop our Online Offers

- Performance of Contract (Article 6 (1) (b) of the General Data Protection Regulation)