Data protection
I. General Information
(1) Below, we provide information in accordance with Art. 13 GDPR regarding the collection of personal data when using our website. Personal data includes all data that can be related to you personally, such as name, address, email addresses, and user behavior.
(2) Controller according to Art. 4 (7) EU General Data Protection Regulation (GDPR) is:
Proventis Partners Holding GmbH
Große Johannisstraße 19
20457 Hamburg
Germany
info@proventis.com
Tel: +49 (0) 40 360 9759 – 0 (see our imprint)
You can reach our data protection officer at:
RA Dr. Volker Wodianka, LL.M. (IT&T)
Wodianka privacy legal GmbH
Dockenhudener Straße 12a
22587 Hamburg
Germany
volker.wodianka@privacy-legal.de
(3) When you contact us by email or through a contact form, the data you provide (your email address, possibly your name and telephone number) will be stored by us to answer your questions. The legal basis for processing the data is our legitimate interest in answering your inquiry in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) lit. b GDPR. We delete the data collected in this context after storage is no longer necessary, or restrict processing if there are legal retention requirements.
(4) If we use commissioned service providers for certain functions of our offer or would like to use your data for advertising purposes, we will inform you about the respective processes below. We also specify the defined criteria for the storage period.
II. Your Rights
(1) You have the following rights regarding your personal data:
- Right to information,
- Right to rectification or erasure,
- Right to restriction of processing,
- Right to object to processing,
- Withdrawal of consent,
- Right to data portability.
(2) You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data by us.
(3) If we base the processing of your personal data on a balance of interests, you can object to the processing. This is the case if the processing is not necessary, in particular, to fulfill a contract with you, which will be explained by us in the following description of the functions. If you exercise such an objection, please explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and either discontinue or adjust the data processing, or show you our compelling legitimate grounds for continuing processing.
III. Deletion of personal data
(1) The data processed by us will be deleted in accordance with legal requirements as soon as the purpose of processing your data has ceased to apply or if they are no longer required for the purpose. Your data will also be deleted if the processing was based on your consent and you have revoked it.
(2) It may be necessary to store your data for other legally permissible purposes, such as to fulfill a legal obligation, to assert legal claims, or for tax reasons. In these cases, your personal data will only be processed for these purposes.
IV. Access to the Website
When using the website for purely informational purposes, i.e., if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you want to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure its stability and security (legal basis is Art. 6 (1) lit. f) GDPR):
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software.
(2) We use TLS encryption to protect your data. You can recognize this by the prefix https:// in the address line of your browser.
V. Use of Cookies
n addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive assigned to the browser you are using and through which certain information flows to the location that sets the cookie (here by us). They serve to make the overall internet offering more user-friendly and effective.
(2) We distinguish between two categories of cookies: (a) essential cookies, without which the functionality of our website would be limited, and (b) optional cookies for the purposes of website analysis and marketing. The use of optional cookies is based on your consent (Art. 6 (1) lit. a GDPR). If you have given your consent, you can revoke it at any time via the cookie banner on our website.
VI. Cookiefirst Consent Manager
(1) We use the Consent Management Platform (CMP) of Digital Data Solutions B.V., Plantage Middenlaan 42A, 1018DH Amsterdam, Netherlands (Cookiefirst). Via the tool, you have the opportunity to conveniently manage your consents to the setting of technically unnecessary cookies and to make changes – such as revoking consents granted or objecting – via the tool.
(2) Furthermore, you can obtain the information required by Art. 13 GDPR on the processing of your personal data by the Cookiefirst CMP and by technically unnecessary cookies from the tool.
(3) You can access the settings of our CMP by clicking on the fingerprint icon in the lower left half of the website.
VII. Categories of recipients of personal data
(1) To process our business transactions, we use external domestic and foreign service providers (e.g., for IT, logistics, telecommunications, sales, and marketing), who may also become aware of your personal data. We have concluded data processing agreements with these providers in accordance with Art. 28 GDPR, which ensure that data processing is carried out in a permissible manner.
(2) If personal data is transferred by us to our subsidiaries or by our subsidiaries to us (e.g., for advertising purposes), this also occurs due to existing data processing relationships.
VIII. Requirements for the transfer of personal data to third countries
(1) For exceptional cases in which personal data is transferred to countries outside the European Economic Area (EEA), i.e., to third countries, this is done under the conditions of Art. 44 ff. GDPR. We will inform you about the specific details of the transfer at the relevant points below.
(2) The European Commission certifies adequacy decisions for some third countries, which attest to a level of data protection comparable to the EEA standard. In other third countries to which personal data may be transferred, there may be, however, no consistently high level of data protection due to missing legal regulations. If this is the case, we ensure that data protection is sufficiently guaranteed. This can be achieved through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 (2) lit. c GDPR, or through other measures pursuant to Art. 46 GDPR.
IX. Use of Google Analytics
(1) If you have given your consent, Google Analytics 4, a web analysis service provided by Google LLC, is used on this website. The responsible entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
(2) Google Analytics 4 uses cookies to analyze your use of our websites. The information collected through these cookies about your use of this website is usually transferred to and stored on a Google server in the USA.
(3) This website uses Google Analytics 4 with the “anonymizeIp” extension. This ensures that IP addresses are processed in a truncated form. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
(4) In addition to the personal data mentioned under section IV of this statement, the following data are also collected:
• Initial visit to the website
• Start of the session
• Visited web pages
• Your “click path,” interaction with the website
• Scrolls (whenever a user scrolls to the end of the page (90%))
• Clicks on external links
• Internal search queries
• Interaction with videos
• File downloads
• Viewed/clicked advertisements
(5) Recipients of the data may include:
• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as a data processor under Article 28 GDPR)
• Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
• Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
(6) We use Google Analytics 4 to analyze the usage of our website and to regularly improve it. Through the gathered statistics, we can enhance our offering and make it more interesting for you as a user. The legal basis for the use of Google Analytics is your consent pursuant to Article 6(1)(a) GDPR, which you can withdraw at any time.
(7) The European Commission adopted its adequacy decision for the USA on July 10, 2023. Google LLC is certified under the Data Privacy Framework, thus ensuring an adequate level of data protection.
(8) Further information on the data protection regulations of Google Analytics can be found here.
X. Integration of Google Maps
(1) On this website, we use the services of Google Maps. Google Maps is operated by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. This allows us to display interactive maps directly on the website and enables you to conveniently use the map function. For more information on data processing by Google, please refer to Google’s privacy policy. There, you can also change your personal privacy settings in the privacy center.
(2) By visiting the website, Google receives information that you have accessed the corresponding subpage of our website. In addition, the data mentioned under section IV of this statement are transmitted. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly associated with your account. If you do not wish for this association with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for purposes of advertising, market research, and/or tailoring its website to meet your needs. Such evaluation is carried out especially (even for users who are not logged in) to provide personalized advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, and to exercise this right, you must contact Google. The legal basis for the use of Google Maps is Article 6(1)(a) GDPR.
XI. Newsletter
(1) With your consent, you can subscribe to our newsletter, through which we inform you about our current interesting offers. The advertised goods and services are named in the consent declaration.
(2) For subscribing to our newsletter, we use the double opt-in procedure. This means that after your registration, we will send you an email to the specified email address, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be blocked and automatically deleted after one month. Furthermore, we store your IP addresses and the times of registration and confirmation. The purpose of the procedure is to prove your registration and, if necessary, to clarify any misuse of your personal data.
(3) After your confirmation, we will store your data for the purpose of sending the newsletter. The legal basis is your consent, pursuant to Article 6(1)(a) GDPR.
(4) You can revoke your consent to receive the newsletter and unsubscribe at any time. You can declare your revocation by clicking on the link provided in each newsletter email.
(5) The newsletters are sent using “MailChimp,” a newsletter distribution platform provided by the US provider Intuit Inc., 2700 Coast Ave Mountain View, CA 94043, USA. We have concluded a data processing agreement with this provider. In addition, Intuit Inc. is certified under the EU-US Data Privacy Framework, ensuring an adequate level of data protection. For more information on Mailchimp’s privacy policy, please see here.
(6) Additionally, you can also give your consent for us to analyze your user behavior when sending the newsletter. For this analysis, the emails sent contain so-called web beacons or tracking pixels, which are one-pixel image files stored on our website. With the data obtained, we create a user profile to tailor the newsletter to your individual interests. We track when you read our newsletters, which links you click on, and derive your personal interests from them. We then link this data with actions you take on our website. You can revoke your consent at any time.
XII. Social media presences
1) We maintain online presences within social networks to inform active users about our services and to communicate directly with them through the platforms if they are interested. Currently, we are present on the following networks: LinkedIn www.linkedin.com/company/proventispartners Xing www.xing.com/companies/proventispartners
(2) All our social media channels can only be accessed by visitors to the website via an external link. We do not use plugins or other interfaces on our website that the respective networks offer for embedding their offerings on websites. We have no influence on the data collection and its further use by the social networks. Therefore, we have no knowledge of the extent to which, where, and for how long the data is stored, to what extent the networks comply with existing deletion obligations, what evaluations and links with the data are made, and to whom the data is passed on. We explicitly point out that the data of users (e.g., personal information, IP address) are stored by the operators of the networks in accordance with their data usage policies and are used for business purposes. We process the data of users in social media presences insofar as they contact us through comments or direct messages and communicate. The legal basis for this processing of user data is Article 6(1)(b) and (f) GDPR. (3) The responsible entities are LinkedIn Corporation, 1000 W Maude Ave Sunnyvale CA 94085, and New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany (Xing). For further information, please refer to the pages of LinkedIn Corporation at https://www.linkedin.com/legal/privacy-policy and Xing at https://privacy.xing.com/de/datenschutzerklaerung.
XIII. APPLICATION DOCUMENTS
(1) You can send us application documents via email.
(2) Your data required for contacting you and conducting the application process will be stored for the purpose of carrying out an application procedure in compliance with legal regulations. The legal basis is Article 6 (1) (b) GDPR and § 26 (1) in conjunction with (8) BDSG (implementation of pre-contractual measures).
(3) The following data may be processed by us in the application process:
- Basic data (title, first name, last name, optionally date of birth)
- Contact details (address, telephone or mobile number, private email address)
- Application data (e.g., profile picture, as well as other documents such as CV, cover letter, complete application, certificates).
(4) In the event of employment, the data will be transferred to the personnel file. Information on the storage period can be found in the information on the processing of personal data of our employees.
(5) If an application for a specific job advertisement is unsuccessful, your data will be stored for evidential purposes for at least 6 months after the conclusion of the application process, in order to assert, exercise, or defend legal claims if necessary.
(6) With your consent, we will gladly include your application in our applicant pool until revoked. We store unsolicited applications for finding a suitable position for you until revoked.
(7) Providing the data is not legally or contractually required. You are not obliged to provide the data. However, if the data is not provided, it will not be possible to carry out an application process and, if applicable, an employment.