We are very delighted that you have shown interest in our company. Data protection is of particularly high priority for the management of Zenfulfillment GmbH. The use of the Internet pages of Zenfulfillment GmbH is generally possible without any indication of personal data. However, if a data subject wants to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to Zenfulfillment GmbH. By means of this privacy policy, our company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this privacy policy, of the rights to which they are entitled.
As the controller, Zenfulfillment GmbH has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
1. Definitions
The privacy policy of Zenfulfillment GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this privacy policy, we use, inter alia, the following terms:
a. Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b. Data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c. Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d. Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.
e. Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f. Pseudonymisation Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g. Controller or controller responsible for the processing
Controller or controller responsible for the processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h. Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i. Recipient
Recipient means a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j. Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
k. Consent
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union and other provisions related to data protection is:
Zenfulfillment GmbH
Tempelhofer Damm 227
12099 Berlin
Germany
Phone: +4930 398 218 57
Email: kontakt@zenfulfillment.com
Website:www.zenfulfillment.com
3. Name and address of the data protection officer
The data protection officer of the controller is:
Zenfulfillment GmbH
Tempelhofer Damm 227
12099 Berlin
Germany
Email: datenschutz@zenfulfillment.com
Website:www.zenfulfillment.com
Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.
4. Cookies
The websites of Zenfulfillment GmbH use cookies. Cookies are text files that are placed and stored on a computer system via an internet browser. Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID. Through the use of cookies, Zenfulfillment GmbH can provide the users of this website with more user-friendly services that would not be possible without the setting of cookies. By means of a cookie, the information and offers on our website can be optimized with the user in mind. As mentioned above, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website, because this is taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie. The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
5. Collection of general data and information
The website of Zenfulfillment GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using this general data and information, Zenfulfillment GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Zenfulfillment GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
6. Registration on our website
The data subject has the possibility to register on the website of the controller by providing personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transferred to one or more processors, for example a parcel service provider, who will likewise use the personal data exclusively for an internal purpose attributable to the controller. By registering on the website of the controller, the IP address assigned by the data subject's internet service provider (ISP), as well as the date and time of the registration, are also stored. These data are stored because this is the only way to prevent the misuse of our services and, where necessary, to make it possible to investigate criminal offences committed. In this respect, the storage of these data is necessary to safeguard the controller. As a matter of principle, these data are not passed on to third parties unless there is a legal obligation to do so or the transfer serves the purpose of criminal prosecution. The registration of the data subject, with the voluntary provision of personal data, enables the controller to offer the data subject content or services that, by their very nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have them completely deleted from the controller's database. The controller shall, at any time and upon request, provide each data subject with information on what personal data are stored about the data subject. In addition, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as there are no statutory retention obligations to the contrary. All employees of the controller are available to the data subject as contact persons in this context.
7. Subscription to our newsletter
On the website of Zenfulfillment GmbH, users are given the opportunity to subscribe to our company's newsletter. The input mask used for this purpose determines what personal data is transmitted to the controller when the newsletter is ordered. Zenfulfillment GmbH informs its customers and business partners regularly by means of a newsletter about company offers. The newsletter of our company may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. For legal reasons, a confirmation e-mail is sent in the double opt-in procedure to the e-mail address registered by a data subject for the first time for newsletter shipping. This confirmation e-mail is used to verify whether the owner of the e-mail address as the data subject has authorized the receipt of the newsletter. During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the legal protection of the controller. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a related registration, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be withdrawn at any time. For the purpose of withdrawing consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
8. Newsletter tracking
The newsletters of Zenfulfillment GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in e-mails sent in HTML format to enable log file recording and log file analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Zenfulfillment GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by the data subject. Such personal data collected via the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are at any time entitled to withdraw the respective separate declaration of consent issued by means of the double opt-in procedure. After a withdrawal, this personal data will be deleted by the controller. Zenfulfillment GmbH automatically regards an unsubscription from the receipt of the newsletter as a withdrawal.
9. Contact possibility via the website
The website of Zenfulfillment GmbH contains information, based on legal requirements, that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. This personal data is not transferred to third parties.
10. Routine erasure and blocking of personal data
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
11. Rights of the data subject
a) Right to confirmation
Each data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may contact an employee of the controller at any time.
b) Right of access
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored about them and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
- the purposes of the processing
- the categories of personal data concerned
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
- where possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria used to determine that period
- the existence of the right to request from the controller rectification or erasure of personal data concerning them, or restriction of processing, or to object to such processing
- the existence of the right to lodge a complaint with a supervisory authority
- where the personal data are not collected from the data subject: any available information as to their source
- the existence of automated decision-making, including profiling, referred to in Art. 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
Furthermore, the data subject has the right to obtain information as to whether personal data have been transferred to a third country or to an international organization. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they may contact an employee of the controller at any time.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Zenfulfillment GmbH, he or she may, at any time, contact any employee of the controller. An employee of Zenfulfillment GmbH shall promptly ensure that the erasure request is complied with without undue delay. Where Zenfulfillment GmbH has made personal data public and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, Zenfulfillment GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure by such controllers of any links to, or copies or replications of, those personal data, as far as processing is not required. An employee of Zenfulfillment GmbH will arrange the necessary measures in individual cases.
e) Right to restriction of processing
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead. The controller no longer needs the personal data
for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR, pending verification of whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met and a data subject wishes to request the restriction of personal data stored by Zenfulfillment GmbH, they may contact an employee of the controller at any time. The employee of Zenfulfillment GmbH will arrange the restriction of the processing.
f) Right to data portability
Each data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject may contact an employee of Zenfulfillment GmbH at any time.
g) Right to object
Each data subject affected by the processing of personal data has the right granted by the European legislator to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions. In the event of an objection, Zenfulfillment GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims. If Zenfulfillment GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Zenfulfillment GmbH processing their data for direct marketing purposes, Zenfulfillment GmbH will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them which is carried out by Zenfulfillment GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest. To exercise the right to object, the data subject may directly contact any employee of Zenfulfillment GmbH or another employee. The data subject is also free, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is based on the data subject's explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject's explicit consent, Zenfulfillment GmbH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision. If the data subject wishes to exercise rights relating to automated decisions, they may contact an employee of the controller at any time.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of the controller.
12. Data protection for applications and the application procedure
The controller collects and processes the personal data of applicants for the purpose of handling the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents to the controller by electronic means, for example by e-mail or by means of a web form on the website. If the controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the rejection decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
13. Data protection provisions about the application and use of Facebook
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to, among other things, create private profiles, upload photos, and connect through friend requests. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a person lives outside of the USA or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Facebook component (Facebook plug-in) was integrated, the web browser on the information technology system of the data subject is automatically prompted by the respective Facebook component to download a display of the corresponding Facebook component from Facebook. An overview of all the Facebook plug-ins may be accessed under https://developers.facebook.com/docs/plugins/?locale=de_DE. During the course of this technical procedure, Facebook is made aware of which specific sub-page of our website was visited by the data subject. If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject, and for the entire duration of their stay on our website, which specific sub-page of our website was visited by the data subject. This information is collected through the Facebook component and associated by Facebook with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data. Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made. The data protection guideline published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
14. Data protection provisions on the use and application of Google Analytics (with anonymization function)
The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and evaluation of data about the behavior of visitors to websites. A web analytics service collects, among other things, data about the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analytics is mainly used to optimize a website and for the cost-benefit analysis of internet advertising. The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. For web analytics via Google Analytics, the controller uses the extension "_gat._anonymizeIp". By means of this extension, the IP address of the data subject's internet connection is shortened and anonymized by Google if our websites are accessed from a Member State of the European Union or from another state party to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyze visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our websites, and to provide other services related to the use of our website. Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. Setting the cookie enables Google to analyze the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is accessed, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements. The cookie is used to store personal information, such as the time of access, the location from which access was made and the frequency of the data subject's visits to our website. Each time our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties. As already explained above, the data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs. Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google.
For this purpose, the data subject must download and install a browser add-on under the link: https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics through JavaScript that no data and information about visits to Internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-on to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-on. Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is further explained under the following link: https://www.google.com/intl/de_de/analytics/.
15. Data protection provisions about the application and use of Google Remarketing
On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords that allows a company to display advertising to Internet users who have previously resided on the company's website. The integration of Google Remarketing therefore allows a company to create user-based advertising and thus show relevant advertisements to interested Internet users. The operating company of the Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on the individual needs and interests of Internet users. Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if they subsequently call up websites that are also members of the Google advertising network. With each call-up of an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject automatically identifies itself with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, inter alia, for the insertion of interest-relevant advertising. The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass this personal data collected through the technical procedure to third parties. The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. The data subject also has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link www.google.de/settings/ads from each of the browsers used by the data subject and set the desired settings. Further information and the applicable data protection provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/.
16. Data protection provisions about the application and use of Google Ads
This website uses Google Ads. Ads is an online advertising program of Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, IE ("Google"). As part of Google Ads, we use so-called enhanced conversion tracking. This requires consent, which you may object to. Enhanced conversions are a feature that supplements existing conversion tags. This allows conversion data collected on the website itself to be sent to Google in encrypted form.
When a conversion takes place on a website, user data such as a name, an e-mail address or a postal address is collected in most cases. This data can be captured and hashed in your conversion tracking tags. For this purpose, the data is encrypted using the one-way hash algorithm SHA256. The hash values of your user data are then passed to Google and used to improve your
conversion measurement. If the cookie banner is accepted in Consent Mode, the tracking tags work as usual and record the
associated conversions and click information. If cookies are declined, Consent Mode only sends a ping. These so-called pings work without cookies. They may contain information such as the timestamp and the referring URL. No personally identifiable information is stored. In addition, Consent Mode can use the pings to compare opt-in and opt-out rates. This information is then used to model conversions of users who have declined the cookie banner. So, if you click on an ad placed by Google, a cookie for enhanced conversion tracking is set. Cookies are small text files that the web browser stores on the user's computer. These cookies expire after 30 days and are not used to personally identify users. Each Google Ads customer receives a different cookie. The cookies cannot be tracked across the websites of Ads customers. The information obtained using the conversion cookie is used to generate conversion statistics for Ads customers who have opted for conversion tracking. Customers learn, for example, the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in tracking, you can object to this use
by simply deactivating the Google conversion tracking cookie in the user settings of your web browser. You will then not be included in the conversion tracking statistics. More information on Google Ads and Google enhanced conversion tracking can be found in Google's privacy policy: https://policies.google.com/privacy?hl=de.
17. Data protection provisions on the use and application of Twitter
The controller has integrated components of Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and distribute so-called tweets, i.e. short messages limited to 280 characters. These short messages are accessible to everyone, including persons who are not registered with Twitter. The tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter makes it possible to address a broad audience via hashtags, links or retweets. The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Each time one of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, is accessed, the internet browser on the information technology system of the data subject is automatically prompted by the respective Twitter component to download a display of the corresponding Twitter component from Twitter. Further information on the Twitter buttons is available athttps://about.twitter.com/de/resources/buttons. As part of this technical procedure, Twitter learns which specific subpage of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to redistribute the content of this website, to make this website known in the digital world and to increase our visitor numbers. If the data subject is logged in to Twitter at the same time, Twitter recognises with each visit to our website by the data subject, and for the entire duration of the respective stay on our website, which specific subpage of our website the data subject is visiting. This information is collected by the Twitter component and assigned by Twitter to the respective Twitter account of the data subject. If the data subject clicks one of the Twitter buttons integrated on our website, the data and information thereby transmitted are assigned to the personal Twitter user account of the data subject and stored and processed by Twitter. Twitter receives information via the Twitter component that the data subject has visited our website whenever the data subject is logged in to Twitter at the same time as accessing our website; this occurs regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not wish such information to be transmitted to Twitter, he or she can prevent the transmission by logging out of his or her Twitter account before accessing our website. The applicable data protection provisions of Twitter are available at https://twitter.com/privacy?lang=de.
18. Legal basis for the processing
Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and his or her name, age, health insurance data or other vital information would have to be disclosed to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. The legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, sentence 2 GDPR).
19. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and shareholders.
20. Period for which the personal data will be stored
The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely erased, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
21. Provision of personal data as statutory or contractual requirement; requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee clarifies to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of non-provision of the personal data would be.
22. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
23. Record of processing activities
Name of the controller: Zenfulfillment GmbH
Address: Tempelhofer Damm 227, 12099 Berlin, Germany
Persons authorized to represent the company: Daniel Werner, Johannes Humpert
Data protection officer contact: datenschutz@zenfulfillment.com
23.1
Name of the processing activity:
Website
Purposes of the processing:
Operation of a website for the external presentation of the company and for making contact, incl. contact form
Description of the categories of personal data
- Name
- Company name
- E-mail address
- Master data
- Usage data
- Content data
- Description of the categories of data subjects:
- Prospective customers
- Visitors
Categories of recipients to whom the personal data have been or will be disclosed: hosting provider
If applicable, other internal departments for processing inquiries. If applicable, transfers of personal data to a third country or an international organization: integration of Google Web Fonts. In this context, servers of Google in the USA are called up. Google is the "controller" for this processing. The adequate level of data protection results from Google's participation in the Privacy Shield. Envisaged time limits for erasure of the different categories of data: usage data are deleted or anonymized after 7 days at the latest.
Content data (e.g. data submitted via a contact form) are stored for a period of 1 year. After the year has expired, the need for further storage is reviewed, and a renewed review is scheduled at the end of each calendar year.
If content data are to be classified as business letters, the retention obligations under commercial law apply. General description of the technical and organizational measures pursuant to Art. 32(1) GDPR: see data security concept.
23.2
Name of the processing activity
Sales / distribution
Purposes of the processing
Sale and distribution of goods or services
Description of the categories of personal data:
First name
Last name
Title
Company name
Address (business)
Address (private)
Billing address
Email address
Phone number
Customer number
Customer type
Contact details
Contact history
Appointment data
Bank details
VAT identification number
Data on purchased goods or services
Contract data
Sales data
Description of the categories of data subjects:
Customers
Categories of recipients to whom the personal data have been or will be disclosed: Cooperation partners
Logistics companies. Transfers of personal data to a third country or an international organization, if applicable: None. Envisaged time limits for erasure of the different categories of data: Personal data relating to sales / distribution are assumed to be relevant for accounting purposes. They are therefore generally stored for 10 years, with the period beginning in accordance with Section 147(4) of the German Fiscal Code (AO). General description of the technical and organizational measures pursuant to Art. 32(1) GDPR: See data security concept.
23.3
Name of the processing activity
CRM
Purposes of the processing: Management of relationships with customers and prospects ("Customer Relationship Management (CRM)"). Description of the categories of personal data: First name, last name, title, company name, address (business), website address, email address, phone number, fax number, marital status, customer number, customer type, contact details, contact history, appointment data, data on interests, data on purchased goods or services, contract data, communication data, photos, occupational information. Description of the categories of data subjects: Employees, customers, prospects. Categories of recipients to whom the personal data have been or will be disclosed: CRM service provider
Employees of the company
Processors. Transfers of personal data to a third country or an international organization, if applicable: For the CRM system, a software system of a service provider in a third country (here: USA) is used. A data processing agreement has been concluded with the service provider. An adequate level of data protection is ensured by the service provider's membership in the "Privacy Shield". Envisaged time limits for erasure of the different categories of data: For personal data in the CRM system, a review is carried out after two years, at the end of the respective calendar year, to determine whether further storage is necessary. If it is not necessary, the data will be erased.
This does not apply to data classified as business letters within the meaning of the German Commercial Code (HGB) or as accounting-relevant data. In these cases, the respective statutory retention obligations apply. General description of the technical and organizational measures pursuant to Art. 32(1) GDPR: See data security concept
23.4
Name of the processing activity
Appointment management
Purposes of the processingPlanning and management of appointments Description of the categories of personal dataFirst name Last name Company name Address (business) Address (private) Email address Phone number Position Contact details Appointment data Description of the categories of data subjectsEmployees Customers Prospective customers Service providers Third parties Categories of recipients to whom the personal data have been or will be disclosedOther participants in appointments Transfers of personal data to a third country or an international organisation, if applicableNone Envisaged time limits for erasure of the different categories of dataFor personal data relating to appointment management, a review is carried out after four years, at the end of the respective calendar year, to determine whether further storage is necessary. If storage is no longer necessary, the data are deleted.
This does not apply to data that qualify as business letters within the meaning of the German Commercial Code (HGB) or as accounting-relevant data. In these cases, the statutory retention obligations are observed. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.5
Name of the processing activity
Time recording
Purposes of the processingRecording of working hours, attendance, absence and holiday periods Description of the categories of personal dataFirst name Last name Email address Working hours Holiday periods Sick days Description of the categories of data subjectsEmployees Temporary agency workers Categories of recipients to whom the personal data have been or will be disclosedWorks council
Tax advisor
Auditor Transfers of personal data to a third country or an international organisation, if applicableNone Envisaged time limits for erasure of the different categories of dataOvertime: 2 years
Tax-relevant time recording data are stored for at least 10 years in accordance with the requirements of the German Fiscal Code (Abgabenordnung).
All other data are stored for a period of two years. At the end of the calendar year, a review is carried out to determine whether further storage is necessary. If this is not the case, the data are deleted. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.6
Name of the processing activity:
Email
Purposes of the processingElectronic communication Description of the categories of personal dataName Email address Usage data Traffic data Description of the categories of data subjectsEmployees Customers Prospective customers Service providers Third parties Applicants Categories of recipients to whom the personal data have been or will be disclosedService providers
Other persons within the company
third parties, if applicable Transfers of personal data to a third country or an international organisation, if applicableNot planned.
Nevertheless, when emails are sent via the internet, it can never be ruled out that they are routed through a third country. Envisaged time limits for erasure of the different categories of dataEmails are retained for at least 6 years in order to comply with the commercial-law retention obligations for business letters. After 6 years, a review is carried out at the end of the respective calendar year to determine whether further storage is necessary. If storage is no longer necessary, the data are deleted.
This does not apply to data that qualify as accounting-relevant data. In these cases, the respective tax-law retention obligations apply. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.7
Name of the processing activity
IT
Purposes of the processingProvision, maintenance and support of IT systems Description of the categories of personal dataFirst name Last name Title Email address Phone number Position Contact history Usage data Traffic data Telecommunications data Communication data Description of the categories of data subjectsEmployees Customers Service providers Third parties Categories of recipients to whom the personal data have been or will be disclosedEmployees with personnel responsibility
Works council Transfers of personal data to a third country or an international organisation, if applicableNone. Envisaged time limits for erasure of the different categories of dataThere are many different retention periods for personal data processed in the IT area. These depend on the respective application or IT system and vary. IT systems used to process personal data generally have a logging function that makes it possible to trace "who" "entered, changed or deleted" "which data" and "when". As a rule, this log is stored for a further 4 years from the deletion of the respective data record. At the end of each calendar year, a review is carried out to determine whether data can be deleted. In addition, for data generally arising in the IT area (processing of orders, requests, etc.), a review is carried out after four years, at the end of the respective calendar year, to determine whether further storage is necessary. If storage is no longer necessary, the data are deleted.
This does not apply to data that qualify as business letters within the meaning of the German Commercial Code (HGB) or as accounting-relevant data. In these cases, the respective statutory retention obligations apply. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.8
Name of the processing activity
Administration
Purposes of the processingGeneral administration of the company (organization, office organization, reception, etc.) Description of the categories of personal dataFirst name Last name Title Company name Address (business) E-mail address Telephone number Position Contact details Contact history Contract data Description of the categories of data subjectsEmployees Customers Prospects Service providers Third parties Visitors Categories of recipients to whom the personal data have been or will be disclosedInternal departments
Service providers
Third parties, if applicable Transfers of personal data to a third country or an international organization, if applicableNone Envisaged time limits for erasure of the different categories of dataFor personal data of general administration, a review is carried out after four years, at the end of the respective calendar year, to determine whether further storage is necessary. If there is no such necessity, the data will be erased.
This does not apply to data that qualifies as business correspondence within the meaning of the German Commercial Code (HGB) or as accounting-relevant data. In this case, the respective statutory retention obligations apply. General description of the technical and organizational measures pursuant to Article 32(1) GDPR See data security concept.
23.9
Name of the processing activity
Financial accounting
Purposes of the processingDetermination and management of all income and expenditure, in particular for the purpose of calculating and paying taxes and levies. Description of the categories of personal dataFirst name Last name Company name Billing address E-mail address Telephone number Customer number Customer type Bank details VAT identification number Data on purchased goods or services Contract data Sales data Description of the categories of data subjectsEmployees Customers Debtors Creditors Categories of recipients to whom the personal data have been or will be disclosedTax authorities
Tax advisors
Auditors Transfers of personal data to a third country or an international organization, if applicableNone Envisaged time limits for erasure of the different categories of dataFinancial accounting data is stored for at least 10 years in accordance with the German Fiscal Code (AO). Section 147(4) AO applies to the start of this period. General description of the technical and organizational measures pursuant to Article 32(1) GDPR
See data security concept.
23.10
Name of the processing activity
Payroll accounting
Purposes of the processingCalculation of wages & salaries, payroll processing and payment of wages & salaries Description of the categories of personal dataFirst name Last name Title Address (private) Telephone number Date of birth Marital status Information on dependents (e.g. children) Bank details Contract data Social security data Working hours Wage and salary data Information on tax classes Religious affiliation Information on wage garnishments Description of the categories of data subjectsEmployees Categories of recipients to whom the personal data have been or will be disclosedWorks council
Tax advisors
Auditors
Social security agencies and health insurance funds
Tax authorities
Insurers for company pension schemes
Heads of department or persons with personnel responsibility
Company management Transfers of personal data to a third country or an international organization, if applicableNone. Envisaged time limits for erasure of the different categories of dataTwo years for overtime records
Tax-relevant data is stored for at least 10 years in accordance with the German Fiscal Code. Section 147(4) AO applies to the start of this period.
All other data is stored for a period of two years; at the end of the calendar year, a review is carried out to determine whether further storage is necessary. If there is a need, the necessity is reviewed again annually at the end of each calendar year. General description of the technical and organizational measures pursuant to Article 32(1) GDPR See data security concept.
23.11
Name of the processing activity
Personnel / HR
Purposes of the processingProcessing of personnel data
Personnel development Description of the categories of personal dataFirst name Last name Title Address (private) Email address Phone number Date of birth Marital status Information on dependants (e.g. children) Health data Data on interests Bank details Contract data Photos Social security data Working hours Wage and salary data Information on tax classes Religious affiliation Information on occupation Information on career history Information on wage garnishments Holiday periods Data on occupational reintegration management (BEM) School-leaving qualification Vocational qualification University studies Sick days Data on criminal convictions or entries in the Federal Central Criminal Register (Bundeszentralregister) Data on professional training Description of the categories of data subjectsEmployees Categories of recipients to whom the personal data have been or will be disclosedWorks council
Social security agencies and health insurance funds
Tax authorities
Insurers for company pension schemes
Heads of department or persons with personnel responsibility
Company management Transfers of personal data to a third country or an international organisation, if applicableNone Envisaged time limits for erasure of the different categories of dataWarnings: 36 months
Otherwise, a review is carried out 10 years after the end of the employment relationship to determine whether the data can be deleted. Data will not be deleted if the employee wishes to claim or is claiming a company pension. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.12
Name of the processing activity
Applicant management
Purposes of the processingThe purpose of applicant management is recruitment. This includes finding suitable applicants and selecting the applicants with the best skills for the respective position. Description of the categories of personal dataFirst name Last name Title CV School-leaving qualification Vocational qualification University studies Description of the categories of data subjectsApplicants Categories of recipients to whom the personal data have been or will be disclosedWorks council
Internal departments responsible for hiring the respective person. Transfers of personal data to a third country or an international organisation, if applicableNot planned. Envisaged time limits for erasure of the different categories of dataAs a rule, applicant data are deleted 6 months after the respective position has been filled.
This does not apply to the data of applicants who have given their consent to the further storage of their data in the applicant pool.
For these data, a review is carried out after two years to determine whether further storage is required. Otherwise, the data are deleted. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.13
Name of the processing activity
Controlling
Purposes of the processingPlanning, management and control of all areas of the company Description of the categories of personal dataFirst name Last name Company name Address (business) Billing address Email address Phone number Fax number Position Industry Customer number Customer type Contact details Contact history Contract data Master data Usage data Sales data Description of the categories of data subjectsEmployees Customers Service providers Third parties Categories of recipients to whom the personal data have been or will be disclosedAuditor
Tax advisor
Works council
Company management Transfers of personal data to a third country or an international organisation, if applicableNone Envisaged time limits for erasure of the different categories of dataData processed for controlling purposes are generally stored for a period of 10 years.
After this period, a review is carried out at the end of the respective calendar year to determine whether further storage is necessary. If storage is no longer necessary, the data are deleted. General description of the technical and organisational measures pursuant to Article 32(1) GDPR See data security concept.
23.14
Name of the processing activity
Marketing
Purposes of the processingMarketing/advertising for goods or services and for the company as a whole. Description of the categories of personal dataFirst name Last name Title Company name Address (business) Website address E-mail address Telephone number Fax number Position Industry Customer number Customer type Contact history Appointment data Data on interests Data on purchased goods or services Contract data Photos Videos Description of the categories of data subjectsEmployees Customers Prospects Third parties
Categories of recipients to whom the personal data have been or will be disclosedService providers used for advertising/marketing
Cooperation partners
Other third parties, if applicable Transfers of personal data to a third country or an international organization, if applicableNone Envisaged time limits for erasure of the different categories of dataFor personal data processed for advertising purposes, reviews are generally carried out at the end of each calendar year to determine whether further processing of the data is still required.
Depending on the result, the data is either stored further or erased. General description of the technical and organizational measures pursuant to Article 32(1) GDPR See data security concept.
