Privacy policy according to Art. 13, 21 GDPR as well as § 25 German Telemedia-Telecommunications-Data Privacy Act (TTDSG) for the contents and functions of the website https://wta-unisol.com (hereinafter „Services“)
Date: May 2024
The protection of your personal data and your privacy is extremely important to us. Therefore, we would like to offer you comprehensive transparency regarding the processing of your personal data (GDPR) as well as regarding the storage of information on your end device or regarding the access to information (TTDSG). Because only if the processing of personal data and information is comprehensible for you as a data subject, you are sufficiently informed about the scope, purposes and benefits of the processing.
Controller within the meaning of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and other data protection regulations is the
WTA UNISOL GmbH
Fritz-Bothmann-Strasse 1
99867 Gotha
Tel +49 (0) 3621 73 77 920
Fax +49 (0) 3621 73 77 921
Mail info@wta-unisol.com
Hereinafter „Controller“ or „us“.
Our Data Protection Officer is
Carsten Bachert
(+49) 159-0192
2.1 Personal Data
Personal data is individual information about personal or factual circumstances of an identified or identifiable natural person.
Individual details about personal or factual circumstances are, for example:
2.2 This is the way we process personal data
We process personal data within the legally permissible limits. This means that data processing operations are based on a legal basis. These are standardized in Art. 6 para. 1 GDPR. Most data processing is based on a legitimate interest on our part (Art. 6 para. 1 lit. f GDPR), on processing operations necessary for the performance of the contract (Art. 6 para. 1 (lit. b GDPR) or on the basis of consent given by you (Art. 6 para. 1 lit. a GDPR). In the latter case, you will be informed separately (e.g. via a cookie banner) about the consent process.
Personal data is processed by us only for clear purposes (Art. 5 para. 1 lit. b GDPR). As soon as the purpose of the processing ceases to apply, your personal data will be deleted or protected by technical as well as organizational measures (e.g. by pseudonymization).
The same applies to the expiry of a prescribed storage period, subject to cases in which further storage is necessary for the conclusion or fulfillment of a contract. In addition, there may be a legal obligation to store data for a longer period or to pass it on to third parties (esp. to law enforcement agencies). In other cases, the storage period and type of data collected as well as the type of data processing depends on which functions you use in the individual case. We will be happy to provide you with information about this in individual cases, in accordance with Art. 15 GDPR.
2.3 We process these categories
Data categories are in particular the following data:
2.4 These are the security measures we meet
In accordance with legal requirements and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to your rights and freedoms, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
In particular, the measures include ensuring that your data is stored and processed confidentially, with integrity and available at all times. Furthermore, the security measures we implement include controls on access to your data as well as access, input, disclosure, ensuring availability and their separation from data of other natural persons. Furthermore, we have established procedures to ensure the exercise of data subject rights (see under Section 5), the deletion of data and responses in the event of a risk to your data. Furthermore, we already consider the protection of personal data during the development of our software as well as through procedures that comply with the principle of data protection through technology design and through data protection-friendly default settings.
2.5 This is how we transfer personal data
In the course of our processing activities of your personal data, it may happen that this data is transferred or disclosed to other bodies, companies, legally independent organizational units or persons. These third parties may include, for example, payment institutions in the context of payment transactions, Service providers entrusted with IT tasks or providers of Services and content that we have integrated into our website. If we transfer or disclose your personal data to third parties, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
2.6 This is how a third country transfer takes place
If this privacy policy indicates that we transfer your personal data to a third country, i.e. a country outside the EU or outside the EEA, the following applies.
If we process your data in a third country or if the processing takes place in a third country as part of the use of third-party Services, this will only take place in accordance with the legal requirements.
Furthermore, a third country transfer usually only takes place with your express consent. Whether or not such consent is given, we ensure that we have contractual or legal authorization to transfer and process your data in the third country in question. Furthermore, we only allow your data to be processed by Service providers in third countries that, in our view, have a recognized level of data protection. This means that a corresponding adequacy decision exists between the EU and the country in which we transfer your personal data, for example. An “adequacy decision” is a decision adopted by the European Commission under Article 45 of the GDPR that determines that a third country (i.e., a country that is not bound by the GDPR) or an international organization provides an adequate level of protection for personal data. Alternatively, e.g. if there is no adequacy decision, a third country transfer will only take place if, for example, contractual obligations exist between us and the Service provider in the third country through so-called standard contractual clauses of the EU Commission and further technical security precautions have been taken that ensure an adequately equivalent level of protection to that in the EU or the Service provider in the third country can provide data protection certifications and your data is only processed in accordance with internal data protection regulations (Articles 44 to 49 GDPR. Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
As part of the so-called “Data Privacy Framework” (“DPF”), the EU Commission has recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10.07.2023. A list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of this privacy policy, we will inform you which services we use are certified under the Data Privacy Framework.
2.7 Information about the cookies used (Cookies are here synonymous with other tracking mechanisms such as tokens, beacons, etc.).
Cookies are small text files that contain data from visited websites or domains and are stored on your device (computer, tablet or smartphone). If you access a service, the cookie stored on your device sends information to the party that placed the cookie.
2.7.1 First-party cookies and third-party cookies.
Our Services may set third-party cookies and allow third parties to place cookies on your device. The difference between a first party cookie and a third party cookie is the control over the placement of the cookie. First party cookies are cookies that are specific to the Services that created them. Their use allows us to provide an efficient Service and to evaluate your user behavior in our Services. Third-party cookies are placed on your device by third parties (i.e., not by us). Although we may allow third parties to access our Services to place cookies on your devices, we do not control the information provided by the cookies nor do we have access to this data. This information is processed entirely by the third parties in accordance with their respective privacy policies and, where applicable, any processing contracts entered into between us and the third parties under Article 28 GDPR or shared responsibility contracts under Article 26 GDPR.
We distinguish between
These cookies are essential to provide you with Services available through our Services and to enable you to use certain features of our Services. Without these cookies, we cannot provide you certain Services on our Services.
These cookies are used to collect information to analyze the traffic to our Services and how visitors are using our Services. For example, these cookies may track things such as how long you spend on the Services or the pages you visit which helps us to understand how we can improve our Services site for you. The information collected through these tracking and performance cookies do not identify any individual visitor.
These cookies are used to show advertising that is likely to be of interest to you based on your browsing habits. These cookies, as served by our content and/or advertising providers, may combine information they collected from our Services with other information they have independently collected relating to your web browser’s activities across their network of websites. If you choose to remove or disable these targeting or advertising cookies, you will still see adverts but they may not be relevant to you.
2.7.2 How we use cookies
We want you to be able to make an informed decision for or against the use of cookies that are not strictly necessary for the technical features of the Services. Therefore, we allow you to choose which cookies you allow in a cookie consent banner when you visit our Services for the first time and permanently thereafter in appropriate settings. Here, strictly necessary cookies are mandatory for visiting our Services and are therefore already permitted via our default settings. Any other cookies are optional. You can allow them by consenting to the setting of these cookies accordingly in the cookie banner. Alternatively, you can reject them. Please note that you may be shown advertisements even if you reject.
2.7.3 Storage period of cookies
Unless we provide you with explicit information about the storage period of cookies (e.g., within the cookie banner), you can assume that the storage period can be up to two years. If cookies were set on the basis of your consent, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”).
2.8 Consent Management
We use Cookiebot as a consent management tool as part of the tracking and analysis activities in our services. Cookiebot is a service provided by Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark, phone: + 45 50 333 777, e-mail: mail@cookiebot.com (“Cookiebot”). Cookiebot collects log file and consent data using JavaScript. This JavaScript makes it possible to inform you about your consent to certain tags in our services and to obtain, manage and document this consent.
We process the following data: (1) Consent data (anonymized logbook data (Consent ID, Processor ID, Controller ID), Consent Status, Timestamp), (2) Device data (including shortened IP addresses (IP v4, IP v6), device information, timestamp), (3) User data (including email, ID, browser information, SettingIDs, changelog). The ConsentID (contains the above-mentioned data) and the Consent status including timestamp are stored in the local memory of your browser and at the same time on the cloud servers used by us. Further processing will only take place if you submit a request for information or revoke your consent. We also store personal data that we process using Cookiebot on our servers. The legal basis for the processing of personal data by means of Cookiebot in accordance with the provisions mentioned here results from our legitimate interest as well as for the fulfillment of legal requirements and thus from Art. 6 para. 1 lit. f and c GDPR. By means of Cookiebot, we want to comply with legal requirements for data protection and tracking and thus set up the functioning of our information technology systems in a legally compliant and user-centered manner.
The use of our Services with all their functions involves the processing of personal data. We explain exactly how this is done here.
3.1 Informational use of our Services
The purely informational use of our Services requires the processing of the following personal data and information: Browser type and browser version, operating system used, address of previously visited websites, address of the terminal device with which you access our Services (IP address), and the time of the call to our Services. All this information is automatically transmitted by your browser if you have not configured it in such a way that transmission of the information is suppressed.
This personal data is processed for the purpose of the functionality and optimization of our Services, as well as to ensure the security of our information technology systems. These purposes are at the same time legitimate interests according to Art. 6 para. 1 lit. f GDPR, the processing is thus carried out with legal grounds.
3.2 Contact form / contacting us by e-mail
We process your personal data that you provide to us when contacting us for the purpose of answering your inquiry, your e-mail or your callback request. Processed data categories are master data, contact data, content data, possibly usage data, connection data and possibly contract data. In individual cases, we forward this data to companies affiliated with us or to third parties that we commission to process orders. The legal basis of the processing depends on the purpose of the contact.
3.3 Application Management
We process your personal data that you provide to us as part of the application process (e.g. via the corresponding contact form in our services) for the purpose of processing your application and carrying out the application process. At your request, we will also consider your application in future application procedures with us or our subsidiaries. The processed data categories are master data, contact data, content data, usage data (not for postal applications), connection data (not for postal applications), contract data. The legal basis for the processing of your data in the context of applicant management is based on Art. 88 para. 1 GDPR i.V.m. § Section 26 para. 1 sentence 1 BDSG (German Federal Data Protection Act). The legal basis for applications to subsidiaries and for storage for future application procedures is Art. 6 para. 1 lit. a GDPR in conjunction with Art. 7 GDPR, § 26 para. 2 BDSG; Art. 6 para. 1 lit. f GDPR.
3.4 Webhosting
3.4.1 Provision of our Services
In order to provide you with our Services, we use the Services of a web hosting provider. This hosting provider is Raidboxes GmbH, Hafenstraße 32, 48153 Münster. Our Services are accessed from the servers of these web hosting providers. For these purposes, we use the web hosting provider’s infrastructure and platform Services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The processed data includes all such data that you enter or that is collected by you in the course of your use and communication in connection with your visit to our Services (e.g. your IP address). Our legal basis for using a web hosting provider to provide our Services results from Art. 6 para. 1 lit. f GDPR (legitimate interest).
3.4.2 Receiving and sending e-mails
The Services of the web host used by us may also include the sending, receiving as well as storing of e-mails. For these purposes, the addresses of the recipients of your e-mails as well as the senders as well as further information concerning the e-mail dispatch (e.g. the providers involved) as well as the contents of the respective e-mails are processed. The aforementioned data is processed, among other things, for the purpose of recognizing SPAM. E-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless end-to-end encryption is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server. Our legal basis for using a web hosting provider to receive and send e-mails results from Art. 6 para. 1 lit. f GDPR (legitimate interest).
3.4.3 Collection of access data and log files
We ourselves (or our web hosting provider) collect data on each access to the server (server log files). The server log files may include the address and name of the Services and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, your operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files may be used on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability. Our legal basis for using a web hosting provider to collect access data and log files results from Art. 6 para. 1 lit. f GDPR (legitimate interest).
3.5 Tracking & Tools
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our services. The Google Tag Manager itself (which implements the tags) does not process any personal data. With regard to the processing of personal data by the integrated services, please refer to our explanations of the individual Google services below. The provider of Google Tag Manager is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.
Google Search Console
We use the Google Search Console, a web analysis service from Google, to continuously optimize the Google ranking of our services.
The Google Search Console enables us to carry out search analyses that provide us with information about how often our services appear in Google search results. This allows us to monitor and manage our services in the search index.
No personal user or tracking data is processed or transmitted to Google when using the Google Search Console.
Google Analytics
We use Google Analytics for the purpose of statistically analyzing your use of our services. Your IP address is collected by us before it is anonymized by Google by shortening it before it is permanently stored on their servers. Processed data is usage data & connection data. The recipient of the data is Google Ireland Ltd, Gordon House, Barrow Street Dublin 4 Ireland (as joint controller, Art. 26 GDPR). If Google transfers this data to a third country (e.g. the USA), this will only be done on a case-by-case basis, on the basis of an order processing contract concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which ensure the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). The legal basis for the use of Google Analytics is your consent (e.g. via an opt-in in the cookie banner), provided that you have given us this consent during your visit to our services and therefore results from Art. 6 para. 1 lit. a GDPR. Cookies are stored on your end device on the basis of your consent and personal data is read out as a result. If you have not given us your consent to the use of Google Analytics (no opt-in in the cookie banner or revocation of your consent), we will not (or no longer) use Google Analytics in the context of your visits to our services.
Google Ad Manager
We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Through the Google Marketing Platform, ads can be displayed in real time based on users’ presumed interests. This allows us to display ads in a more targeted manner in order to present you only with ads that match your potential interests. Processed data is usage data & connection data. The recipient of the data is Google Ireland Ltd, Gordon House, Barrow Street Dublin 4 Ireland (as joint controller, Art. 26 GDPR). If Google transfers this data to a third country (e.g. the USA), this will only be done in individual cases, on the basis of an order processing contract concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which guarantee the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). The legal basis for the use of the Google Ad Manager is your consent (e.g. via an opt-in in the cookie banner), provided that you have given us this consent during your visit to our services and therefore results from Art. 6 para. 1 lit. a GDPR. Cookies are stored on your end device on the basis of your consent and personal data is read out as a result. If you have not given us your consent to use the Google Ad Manager (no opt-in in the cookie banner or revocation of your consent), we will not (or no longer) use the Google Ad Manager during your visits to our services.
3.6 Fanpages on Social Media
We maintain fan pages on the websites of social networks on the Internet and process personal data in this context in order to communicate with the users active there or to offer information about us. We would like to point out that your data may be processed outside the European Union when you visit our fan pages. The operators of the respective social networks are responsible for this. You can find a detailed description of the respective forms of processing and objection options (e.g. opt-out) in the privacy policies of the operators of the respective social networks.
We operate a LinkedIn fan page for our company on LinkedIn. When you visit and use the LinkedIn fan page, LinkedIn can evaluate your usage behavior and provide us with information obtained from this. This information is used for the purposes of economic optimization and needs-based design of our website/services. The categories of data processed are master data, contact data, content data, usage data and connection data. The recipient of the data is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, as joint controller pursuant to Art. 26 GDPR. The legal basis for the processing of the data in accordance with the provisions mentioned here results from our legitimate interest and thus from Art. 6 para. 1 lit. f GDPR.
LinkedIn is responsible for implementing your rights as a data subject. LinkedIn informs you about your rights as a data subject at: https://de.linkedin.com/legal/privacy-policy. You can also assert your rights against us; we will then forward your request to LinkedIn immediately.
3.7 Newsletter with CleverReach
We use the services of CleverReach to send newsletters. CleverReach is a service with which, among other things, the sending of newsletters can be organized and analyzed. The provider is CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany. The data you enter for the purpose of receiving the newsletter (e.g. e-mail address) is stored on CleverReach’s servers. Our newsletters sent with CleverReach enable us to analyze the behavior of newsletter recipients. Among other things, we can analyze how many recipients have opened the newsletter message and how often which link in the newsletter was clicked on. All links in the email are so-called tracking links, with which your clicks can be counted. If you do not want CleverReach to analyze your data, you must unsubscribe from the newsletter. We provide a link for this purpose in every newsletter message. You can also revoke your consent at any time with effect for the future by sending an email to the address given in our legal notice. The data you provide us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted from both our servers and the CleverReach servers after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the member area) remain unaffected by this. The data entered in the newsletter registration form is processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the e-mail address and its use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
If we use external Service providers to process your data, they will be carefully selected and commissioned by us. If the Services provided by these Service providers are commissioned processing within the meaning of Art. 28 GDPR, the Service providers are bound by our instructions and are regularly monitored. In this context, our order processing contracts comply with the strict requirements of Art. 28 GDPR as well as the specifications of the German data protection authorities.
If your personal data is processed, you are a data subject within the meaning of the GDPR and you are entitled to the following rights as a user against the controller:
5.1 Right to information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.
If such processing exists, you may request information from the controller about the following:
5.2 Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
5.3 Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
5.4 Right to erasure
5.4.1 You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase this data without undue delay, if one of the following reasons applies:
5.4.2 If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
5.4.3 The right to erasure shall not apply to the extent that the processing is necessary
5.5 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right vis-à-vis the controller to be informed about these recipients.
5.6 Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
the processing is based on consent pursuant to Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) lit. b GDPR and
the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
5.7 Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 (1) lit. e or f GDPR; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as 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.
You have the possibility, in connection with the use of information society Services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.
5.8 Right to revoke your declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
The processing is lawful until your revocation – the revocation thus only affects the processing after receipt of your revocation. You can declare the revocation informally by mail or e-mail. The processing of your personal data will then no longer take place, subject to permission by another legal basis. If this is not the case, your data must be deleted immediately after the revocation in accordance with Art. 17 (2) GDPR. Your right to revoke your consent subject to the above conditions is guaranteed.
Your revocation should be addressed to:
WTA UNISOL GmbH
Fritz-Bothmann-Strasse 1
99867 Gotha
Tel +49 (0) 3621 73 77 920
Fax +49 (0) 3621 73 77 921
Mail info@wta-unisol.com
5.10 Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
Automated decisions in individual cases including profiling do not take place.
If your personal data have been disclosed to other recipients (third parties) with legal grounds, we will notify them of any rectification, erasure or restriction of the processing of your personal data (Art. 16, Art. 17 (1) and Art. 18 GDPR). The notification obligation does not apply if it involves disproportionate effort or is impossible. We will also inform you about the recipients upon request.
WTA UNISOL GmbH
Fritz-Bothmann-Strasse 1
99867 Gotha
Fax +49 (0) 3621 73 77 921
Mail info@wta-unisol.com
Copyright © 2024 WTA UNISOL GmbH
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