Privacy Policy

This privacy policy explains to you the nature, scope and purpose of the processing of personal data within the XignIn app and the associated website, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offer"). With regard to the terms used, such as "processing" or "person responsible", we refer you to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

1. Terms used

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.
"Processing" means any operation or set of operations which is performed on sets of personal data, whether or not by automated means, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, qualification, erasure or destruction.
"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 ensuring that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.
The "controller" is 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. "Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

2. Relevant legal bases

In accordance with Art. 13 GDPR we inform you about the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing in order to fulfil our services and carry out contractual measures as well as answer enquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing in order to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR and the legal basis for processing in order to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR. In case that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

3. Security measures

In accordance with Art. 32 GDPR, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons. Such measures shall include ensuring the confidentiality, integrity and availability of data by controlling physical access to, access to, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects' rights, deletion of data and reaction to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

4. Cooperation with contract processors and third parties

Insofar as we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR is necessary for the performance of the contract), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). If we commission third parties with the processing of data on the basis of a so-called "data processing agreement", this is done on the basis of Art. 28 GDPR.

5. Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Art. 44 ff. of the German Data Protection Act are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

6. Rights of data subjects

You have the right to request confirmation as to whether data relating to you will be processed and, if applicable, to obtain access to such data and other information, such as the purposes for which it was processed, the categories of personal data, the recipients, the duration of the retention period and the origin of the data not collected from the data subject. Furthermore, you have the right to a copy of the data in accordance with Art. 15 GDPR. In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you. Pursuant to Art. 17 GDPR, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand a restriction on the processing of the data pursuant to Art. 18 GDPR. You have the right to demand that the data relating to you which you have provided to us be received in accordance with Art. 20 GDPR and that it be transferred to other responsible parties. Pursuant to Art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.

7. Right of revocation

You have the right to revoke consents granted pursuant to Art. 7 para. 3 GDPR with effect for the future. The revocation does not affect the lawfulness of the processing which took place on the basis of the consent up to the revocation.

8. Right of objection

You may object at any time to the future processing of the data concerning you in accordance with Art. 21 GDPR. In particular, you may object to the processing of your data for the purposes of direct marketing.

9. Cookies and right to object to direct advertising

“Cookies" are small files that are stored on the user's computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user's visit to an online service. Temporary cookies, or "session cookies" or "session cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as "permanent" or "persistent" and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users who are used for range measurement or marketing purposes can also be stored in such a cookie. Third party cookies" are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter's cookies, they are referred to as "first party cookies"). We may use temporary and permanent cookies and explain this in our privacy policy. If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of your browser. The exclusion of cookies can lead to functional restrictions of this online offer. A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . In addition, cookies can be saved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

10. Deletion of data

The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons. According to legal requirements in Germany, data is stored for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting records, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).

11. Business-related processing

Additionally, we process

– Contract data (for example, contract object, duration, customer category).

– Payment data (e.g., bank details, payment history)

by our customers, interested parties and business partners for the purpose of providing contractual services, customer care, marketing, advertising and market research.

12. Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the scope of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data regarding contractual services and contractual communication corresponds to the data specified in these processing activities. We disclose or transmit data to the financial administration, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers. Furthermore, based on our business interests, we store information on suppliers, organisers and other business partners, e.g. for the purpose of establishing contact at a later date and maintaining business relations. This data, which is mainly company-related, is stored permanently.

13. Establishing contact

When contacting us through various channels, the user's details are processed for the processing of the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) GDPR. The user's details may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation. We delete the requests if they are no longer necessary, whereby the necessity is reviewed every 2 years; furthermore, the statutory archiving obligations apply.

14. Hosting and e-mail dispatch

The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service. Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f GDPR in connection with Art. 28 GDPR (conclusion of an order processing contract).

15. Online presence in social media

We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. Unless otherwise stated in our data protection declaration, we process the data of users who communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

16. Integration of services and contents of third parties

Within the scope of our online offer, we act based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR) content or service offers from third parties in order to integrate their content and services, such as videos or fonts. This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring web pages, visit times and other information about the use of our online services, as well as may be linked to such information from other sources.

17. Use of Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Ireland Limited. It is used in "Universal Analytics" mode. This makes it possible to assign data, sessions and interactions across several devices to a pseudonymous user ID and thus to analyse the activities of a user across all devices. Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. However, if IP-Anonymisation is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. We would like to point out that on this website Google Analytics has been extended to include IP-Anonymisation in order to guarantee anonymous collection of IP addresses (so-called IP masking). The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You can find more information on terms of use and data protection at: https://www.google.com/analytics/terms/de. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and Google from processing this data by downloading and installing the "Browser add-on to deactivate Google Analytics". Opt-out cookies prevent the future collection of your data when you visit this website. To prevent Universal Analytics from collecting cookies across multiple devices, you must opt-out on all systems you use.

18. Facebook Pixel, Facebook Custom Audiences and Facebook-Conversion

Within our online offer, the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used. With the help of the Facebook pixel, Facebook is on the one hand able to determine visitors to our online offering as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to Facebook users who have shown an interest in our online offering or who have certain features (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called "custom audiences"). Using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. Using Facebook pixels, we can further track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were referred to our website after clicking on a Facebook ad (known as "conversion"). Facebook processes the data in accordance with Facebook's data usage guidelines. Accordingly, general information about the presentation of Facebook ads can be found in Facebook's Data Usage Policy. Specific information and details about the Facebook pixel and how it works can be found at: https://de-de.facebook.com/business/gdpr.

19. LinkedIn Insight-Tag

Our website uses the so-called Insight Tag of the social network LinkedIn. This is offered by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA ("LinkedIn"). The LinkedIn Insight tag is a small piece of JavaScript code that we have added to our website. The LinkedIn Insight tag allows us to collect information about visits to our Web site, including URL, referrer URL, IP address, device and browser properties, timestamps, and page views. This data is encrypted, anonymized within seven days, and the anonymized data is deleted within 90 days. LinkedIn does not share any personally identifiable information with us, but only provides aggregated reports about website target audience and display performance. LinkedIn also provides retargeting for website visitors so that we can use this information to target advertisements outside our website without identifying the member. LinkedIn members can control the use of their personal information for promotional purposes in their account settings. Use of the LinkedIn Insight tag is for the purpose of obtaining detailed information about visitors to our website and to serve our advertising and marketing interests. We use the LinkedIn Insight tag to track conversions, retarget our website visitors, and gather additional information about LinkedIn members who view our advertisements. For details on data collection (purpose, scope, further processing, use) and your rights and settings, please refer to LinkedIn's privacy policy. LinkedIn provides this information at https://www.linkedin.com/legal/privacy-policy .

20. Change of our data protection regulations

We reserve the right to adapt this data protection declaration so that it always corresponds to the current legal requirements or to implement changes to our services in the data protection declaration, e.g. when introducing new services. Your renewed visit will then be subject to the new data protection declaration. In case of differing interpretation possibilities between the German and English version of this data protection declaration, the German version shall always be decisive in case of doubt.