Privacy Policy

# Privacy Policy

## 1. Data Protection at a Glance

### General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. Detailed information on the subject of data protection can be found in the Privacy Policy set out below this text.

### Data Collection on This Website

#### Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. The operator’s contact details can be found in the section “Information on the Controller” in this Privacy Policy.

#### How do we collect your data?

Some of your data is collected when you provide it to us. This may, for example, be data that you enter into a contact form.

Other data is collected automatically or after you have given your consent when you visit the website through our IT systems. This primarily includes technical data (e.g. internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

#### What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contractual offers, orders or other enquiries relating to services.

#### What rights do you have regarding your data?

You have the right at any time to receive information, free of charge, about the origin, recipients and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you may revoke this consent at any time with effect for the future. Furthermore, under certain circumstances, you have the right to request restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You may contact us at any time regarding this or any other questions concerning data protection.

### Analytics Tools and Third-Party Tools

When you visit this website, your browsing behaviour may be statistically evaluated. This is primarily carried out using so-called analytics programs.

Detailed information on these analytics programs can be found in the following Privacy Policy.

## 2. Hosting

We host the content of our website with the following provider:

### WIX

The provider is Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel (hereinafter referred to as “WIX”).

WIX is a tool for creating and hosting websites. When you visit our website, WIX is used to analyse user behaviour, visitor sources, the region from which website visitors originate and visitor numbers. WIX stores cookies in your browser that are necessary for displaying the website and ensuring its security (necessary cookies).

The data collected via WIX may be stored on various servers worldwide. WIX servers are located, among other places, in the USA.

For details, please refer to the WIX Privacy Policy: de.wix.com/about/privacy.

According to WIX, data transfers to the USA and other third countries are based on the Standard Contractual Clauses of the European Commission or comparable safeguards pursuant to Art. 46 GDPR. Details can be found here: de.wix.com/about/privacy-dpa-users.

The use of WIX is based on Art. 6(1)(f) GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. Where the relevant consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: [www.dataprivacyframework.gov/participant/5626](http://www.dataprivacyframework.gov/participant/5626).

### Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

## 3. General Information and Mandatory Information

### Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this Privacy Policy.

When you use this website, various types of personal data are collected. Personal data is data that can be used to personally identify you. This Privacy Policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

### Information on the Controller

The controller responsible for data processing on this website is:

ECS Europe GmbH i. Gr.

Erkrather Str. 401

40231 Düsseldorf

Germany

Telephone: 0172 / 2999444

Email: [sascha.zandinejad@ecs-europe.de](mailto:sascha.zandinejad@ecs-europe.de)

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data (e.g. names, email addresses or similar information).

### Storage Period

Unless a more specific storage period 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 submit a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these grounds cease to apply.

### General Information on the Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data pursuant to Art. 9(1) GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is additionally based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your terminal device (e.g. via device fingerprinting), data processing is additionally based on Section 25(1) TDDDG. Consent may be revoked at any time.

If your data is required for the performance of a contract or in order to take steps prior to entering into a contract, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, where your data is required to comply with a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information regarding the relevant legal basis applicable in each individual case is provided in the following sections of this Privacy Policy.

### Data Protection Officer

We have appointed a Data Protection Officer.

External Data Protection Officer

Marc Pastuska

Erkrather Str. 401

40231 Düsseldorf

Germany

[www.mp-datenschutz.de/kontakt](http://www.mp-datenschutz.de/kontakt)

Telephone: 0173 2017325

Email: [kontakt@mp-datenschutz.de](mailto:kontakt@mp-datenschutz.de)

### Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, it is also necessary to transfer personal data to these external parties. We disclose personal data to external parties only if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR, or if another legal basis permits the disclosure of data.

When using processors, we disclose our customers’ personal data only on the basis of a valid data processing agreement. In the case of joint processing, an agreement on joint processing is concluded.

### Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You may revoke consent that you have already given at any time. The lawfulness of data processing carried out prior to revocation remains unaffected by the revocation.

### Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL THEREAFTER NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

### Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

### Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract provided to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be carried out where technically feasible.

### Access, Rectification and Deletion

Within the framework of the applicable statutory provisions, you have the right at any time to obtain information, free of charge, about your stored personal data, its origin and recipients, and the purpose of the data processing, as well as, where applicable, the right to rectification or deletion of this data. You may contact us at any time regarding this or any other questions concerning personal data.

### Right to Restriction of Processing

You have the right to request restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing applies in the following cases:

If you dispute the accuracy of your personal data stored by us, we generally require time to verify this. For the duration of the verification process, you have the right to request restriction of the processing of your personal data.

If the processing of your personal data was or is unlawful, you may request restriction of data processing instead of deletion.

If we no longer require your personal data, but you require it for the exercise, defence or establishment of legal claims, you have the right to request restriction of processing instead of deletion.

If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. Until it has been determined whose interests prevail, you have the right to request restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data may – apart from being stored – only be processed with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

### SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the website operator, this website uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the lock symbol in your browser bar.

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

### Objection to Promotional Emails

We hereby object to the use of contact details published as part of the legal notice obligation for the purpose of sending unsolicited advertising and informational materials. The operators of the website expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example through spam emails.

## 4. Data Collection on This Website

### Cookies

Our websites use so-called “cookies”. Cookies are small data packages and do not cause any damage to your terminal device. They are stored on your terminal device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your terminal device until you delete them yourself or they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable certain services provided by third-party companies to be integrated into websites (e.g. cookies for processing payment services).

Cookies perform various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out electronic communications, to provide certain functions requested by you (e.g. for the shopping cart function), or to optimise the website (e.g. cookies used to measure the website audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies in order to provide its services in a technically error-free and optimised manner.

Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent may be revoked at any time.

You can configure your browser so that you are informed when cookies are set and allow cookies only in individual cases, exclude the acceptance of cookies in certain cases or generally, and activate automatic deletion of cookies when closing the browser. Disabling cookies may restrict the functionality of this website.

If additional cookies and services are used on this website, details can be found in this Privacy Policy.

### Consent with Usercentrics

This website uses Usercentrics consent technology to obtain your consent to the storage of certain cookies on your terminal device or to the use of certain technologies and to document this consent in compliance with data protection regulations. The provider of this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany, website: usercentrics.com/de/ (hereinafter referred to as “Usercentrics”).

When you enter our website, the following personal data is transferred to Usercentrics:

Your consent(s) and/or the revocation of your consent(s)

Your IP address

Information about your browser

Information about your terminal device

Time of your visit to the website

Geolocation

In addition, Usercentrics stores a cookie in your browser in order to associate the consent you have given or its revocation with you. The data collected in this way is stored until you request that we delete it, delete the Usercentrics cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.

Usercentrics is used to obtain the consent required by law for the use of certain technologies. The legal basis for this is Art. 6(1)(c) GDPR.

### Data Processing Agreement

### Contact Form

If you submit enquiries to us via the contact form, the information you provide in the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing your enquiry and in the event of follow-up questions. We do not disclose this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary in order to take steps prior to entering into a contract. In all other cases, processing is based on our legitimate interest in effectively handling enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), where such consent has been requested; consent may be revoked at any time.

The data you enter in the contact form will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

### Enquiries by Email, Telephone or Fax

If you contact us by email, telephone or fax, your enquiry, including all personal data arising from it (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not disclose this data without your consent.

The data you send to us through contact enquiries will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

## 5. Analytics Tools and Advertising

### Google Analytics

This website uses functions of the Google Analytics web analytics service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, time spent on the website, operating systems used and the origin of the user. This data is assigned to the respective user’s terminal device. It is not assigned to a user ID.

Furthermore, Google Analytics enables us, among other things, to record your mouse and scrolling movements and clicks. Google Analytics also uses various modelling approaches to supplement the collected data sets and employs machine-learning technologies for data analysis.

Google Analytics uses technologies that enable the recognition of users for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). Information collected by Google regarding the use of this website is generally transferred to a Google server in the USA and stored there.

The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent may be revoked at any time.

Data transfers to the USA are based on the Standard Contractual Clauses of the European Commission. Details can be found here: business.safety.google/adscontrollerterms/sccs/.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: [www.dataprivacyframework.gov/participant/5780](http://www.dataprivacyframework.gov/participant/5780).

### IP Anonymisation

Google Analytics IP anonymisation is activated. This means that your IP address is shortened by Google within Member States of the European Union or in other states that are party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity and provide the website operator with other services relating to website and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

### Browser Plugin

You can prevent Google from collecting and processing your data by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout?hl=de.

More information about how Google Analytics handles user data can be found in Google’s Privacy Policy: support.google.com/analytics/answer/6004245?hl=de.

### Data Processing Agreement

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

## 6. Plugins and Tools

### Google Maps

This website uses the Google Maps mapping service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. This service enables us to integrate map content into our website.

In order to use the functions of Google Maps, it is necessary to store your IP address. This information is generally transferred to a Google server in the USA and stored there. The provider of this website has no influence over this data transfer.

If Google Maps is activated, Google may use Google Fonts for the purpose of ensuring consistent font display. When you access Google Maps, your browser loads the required web fonts into its browser cache in order to display text and fonts correctly.

Google Maps is used in the interest of providing an attractive presentation of our online offerings and making it easy to locate the places specified by us on the website. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR.

Where the relevant consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Data transfers to the USA are based on the Standard Contractual Clauses of the European Commission. Details can be found here: privacy.google.com/businesses/gdprcontrollerterms/ and privacy.google.com/businesses/gdprcontrollerterms/sccs/.

More information on how user data is handled can be found in Google’s Privacy Policy: policies.google.com/privacy?hl=de.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: [www.dataprivacyframework.gov/participant/5780](http://www.dataprivacyframework.gov/participant/5780).

### Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is intended to determine whether data entered on this website (e.g. in a contact form) is being entered by a human or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of website visitors based on various characteristics. This analysis begins automatically as soon as a website visitor enters the website.

For the analysis, reCAPTCHA evaluates various information (e.g. IP address, the length of time the website visitor spends on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitors are not informed that an analysis is taking place.

In this context, Google acts solely as a data processor within the meaning of Art. 28 GDPR and will not use the data collected in this way for its own purposes. The tool is used on the basis of a Data Processing Agreement (DPA) with Google.

The data is stored and analysed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its online services against abusive automated scraping and SPAM.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information is available from the provider at the following link: [www.dataprivacyframework.gov/participant/5780](http://www.dataprivacyframework.gov/participant/5780).

## 7. Our Own Services

### Handling of Applicant Data

We offer you the opportunity to apply for a position with us (e.g. by email, post or via an online application form). Below, we provide information about the scope, purpose and use of the personal data collected from you as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions, and that your data will be treated as strictly confidential.

### Scope and Purpose of Data Collection

If you submit an application to us, we process the personal data associated with your application (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) insofar as this is necessary for deciding whether to establish an employment relationship.

The legal basis for this is Section 26 BDSG under German law (initiation of an employment relationship), Art. 6(1)(b) GDPR (general steps prior to entering into a contract) and – where you have given your consent – Art. 6(1)(a) GDPR. Consent may be revoked at any time.

Within our company, your personal data will be disclosed exclusively to persons involved in processing your application.

If your application is successful, the data you have submitted will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6(1)(b) GDPR for the purpose of carrying out the employment relationship.

As part of the application process, we may also conduct an internet search concerning you. This primarily includes Google searches, LinkedIn and XING. The legal basis for this type of processing is our legitimate interest pursuant to Art. 6(1)(f) GDPR in obtaining an overall impression of publicly available information about you.

### Data Retention Period

If we are unable to offer you a position, if you decline a job offer or if you withdraw your application, we reserve the right to retain the data you have submitted for up to six months from the end of the application process (rejection or withdrawal of the application), on the basis of our legitimate interests (Art. 6(1)(f) GDPR).

The data will subsequently be deleted and physical application documents will be destroyed. The retention serves in particular as evidence in the event of a legal dispute.

If it is apparent that the data will still be required after the expiry of the six-month period (e.g. due to a threatened or pending legal dispute), deletion will only take place once the purpose for the extended retention no longer applies.

A longer retention period may also apply if you have given the relevant consent (Art. 6(1)(a) GDPR) or if statutory retention obligations prevent deletion.