Privacy Policy

We welcome you to our website and are pleased about your interest. The protection of your personal data is very important to us. Therefore, we conduct our business in compliance with applicable laws on data privacy protection and data security. We would like to inform you in the following about which data of your visit is used for which purposes.

Controller for processing according to GDPR

The controller responsible within the meaning of the General Data Protection Regulation and other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

circuly GmbH

Obernstraße 50

33602 Bielefeld

https://de.circuly.io/data-privacy

info@circuly.io

+49 172 948 4913

Data protection officer

Nils Möllers

Keyed GmbH

Siemensstraße 12

48341 Altenberge, Westfalen

info@keyed.de

+49 (0) 2505 - 639797

https://keyed.de

What are personal data?

The term personal data is defined in the Bundesdatenschutzgesetz and the GDPR. According to these laws, these are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes, for example, your civil name, your address, your telephone number or your date of birth.

Scope of anonymous data collection and data processing

Unless otherwise stated in the following sections, no personal data is collected, processed or used when using our websites. However, by using analysis and tracking tools, we learn certain technical information based on the data transmitted by your browser (e.g. browser type/version, operating system used, web pages visited on our website incl. length of stay, previously visited website). We evaluate this information for statistical purposes only.

Legal basis for the processing of personal data

  1. Where we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) lit. a) of the EU Genereal Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
  2. Article 6 (1) lit. b) GDPR serves as the legal basis for the processing of personal data required for the performance of a contract to which the data subject is a party. This also applies to processing operations necessary for the performance of pre-contractual measures.
  3. Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 (1) lit. c) GDPR serves as the legal basis.
  4. In cases where vital interests of the data subject or another natural person make it necessary to process personal data, Article 6 (1) lit. d) GDPR serves as the legal basis.
  5. If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Article 6 (1) lit. f) of the GDPR serves as the legal basis for the processing.

Use of cookies

The internet pages of circuly GmbH use cookies. Cookies are data that are stored by the Internet browser on the user's computer system. The cookies can be transmitted to a page when it is called up and thus enable the user to be assigned to it. Cookies help to simplify the use of Internet pages for the user.

It is possible to object to the setting of cookies at any time by changing the setting in the Internet browser accordingly. Set cookies can be deleted. Please note that if cookies are deactivated, it may not be possible to use all functions of our website to their full extent. The user data collected in this way is pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users. When accessing our website, users are informed by an info banner about the use of cookies for analysis purposes and are referred to this data protection declaration. In this context, there is also a note on how the storage of cookies can be prevented in the browser settings. The legal basis for the processing of personal data using technically necessary cookies is Art. 6 Paragraph 1 lit. f) GDPR. The legal basis for the processing of personal data using cookies for analysis purposes is Article 6 (1) lit. a) of the GDPR if the user has given his or her consent. For information on whether and to what extent cookies are used on our website, please refer to our cookie banner and our notes in this data protection declaration.

Cookiebot by Usercentrics

Description and purpose

This website uses the cookie consent technology "cookiebot" by Usercentrics to obtain your consent to the storage of certain cookies on your terminal device and to document and record this consent in accordance with data protection law. As soon as you enter this website, the following personal data is transferred to Usercentrics:

  • Your consent(s) or the revocation of your consent(s).
  • Your IP address
  • Information about your browser (http agent, http referrer),
  • information about your terminal device
  • Time of your visit to the website

The following additional data will be added:

  • Opt-in and opt-out data
  • Referrer URL
  • user agent
  • User settings
  • Consent ID and consent number
  • Information on whether implicit or explicit consent was given
  • Time (date and time) of consent
  • Consent type
  • Template version
  • Banner language

Furthermore, Usercentrics stores a cookie in your browser in order to be able to allocate the consent given or its revocation to you. The data collected in this way will be stored until you request us to delete it, delete the Usercentrics cookie yourself or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.

Legal basis

Usercentrics is used to obtain the legally required consent for the use of cookies. The legal basis for this is therefore Art. 6 para. 1 lit. c) DSGVO.

Recipient

The recipient of the data is Usercentrics GmbH, Rosental 4, 80331 Munich.

Transfer to third countries

There is no transfer of personal data to third countries.

Duration of processing

The retention period is the period during which the collected data is stored for processing. The data must be deleted as soon as it is no longer required for the specified processing purposes. Consent data (consent and withdrawal of consent) is stored for three years. The data will then be deleted immediately.

Contractual or legal obligation to provide the data

The provision of your personal data is neither legally nor contractually required. If you do not provide your personal data, consent management cannot take place on the website accessed.

Further data protection information

https://www.cookiebot.com/de/privacy-policy/

Creation of log files

With each call of the Internet page the circuly GmbH collects data and information by an automated system. These are stored in the log files of the server. The data is also stored in the log files of our system. These data are not stored together with other personal data of the user.
(1) Information about the type of browser and the version used
(2) The user's operating system
(3) The user's Internet service provider
(4) The user's IP address
(5) The date and time of access
(6) Websites from which the user's system accesses our website (referrer)
(7) Websites that are accessed by the user's system via our website

Duration of storage of personal data

Personal data is stored for the duration of the respective legal retention period. After expiry of the period, the data is routinely deleted, unless it is necessary for the initiation or fulfilment of a contract.

Contact opportunities

On the internet pages of circuly GmbH there is a contact form which can be used for electronic contact. Alternatively, it is possible to contact us via the provided e-mail address. If the data subject contacts the data controller via one of these channels, the personal data transmitted by the data subject is automatically stored. The storage is solely for the purpose of processing or contacting the data subject. The data will not be passed on to third parties. The legal basis for the processing of the data is Art. 6 Paragraph 1 lit. a) GDPR if the user has given his or her consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 Paragraph 1 letter f) GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for processing is Art. 6 (1) lit. b) GDPR. The data is deleted as soon as it is no longer necessary for the purpose for which it was collected. For personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be concluded from the circumstances that the matter in question has been finally clarified. The personal data additionally collected during the sending process will be deleted after a period of seven days at the latest.

Newsletter

If the newsletter of our company is subscribed to, the data in the respective input mask will be transmitted to the person responsible for processing. The subscription to our newsletter is carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. When registering for the newsletter, the IP address of the user and the date and time of registration are stored. This serves to prevent abuse of the services or the e-mail address of the person concerned. The data will not be passed on to unauthorized third parties. For the purpose of sending the newsletter, however, necessary data could be transmitted to appropriate service providers. Furthermore, an exception exists if there is a legal obligation to pass on the data. The data is used exclusively for sending the newsletter. The subscription to the newsletter can be cancelled by the person concerned at any time. Likewise, the consent to the storage of personal data can be revoked at any time. For this purpose there is a corresponding link in every newsletter. The legal basis for the processing of the data after registration for the newsletter by the user is Art. 6 Paragraph 1 letter a GDPR if the user has given his consent. The legal basis for the dispatch of the newsletter as a result of the sale of goods or services is Art. 7 para. 3 UWG.

Online Shop

We use your personal information to process your online purchases (your orders and returns are processed through our online services) and to send you notifications of delivery status or notifications of problems with the delivery of your items. We use your personal data to process your payments. We also use your information to process complaints and product warranty claims. Your personal information is used to verify your identity, ensure that you are of legal age to make online purchases, and to match your address with external partners. We would like to offer you several payment methods and will carry out analyses to find out what payment options are available to you, including your payment history and credit checks.

Transfer of data when using online payment service providers

Should you decide to pay with one of the online payment service providers offered by us during the ordering process, your contact data will be transmitted to this service provider in the course of the order process. The lawfulness of the transmission of the data results from Art. 6 para.1 lit. b) GDPR, for the execution of the payment method chosen by you as well as our legitimate interests according to Art. 6 para. 1 lit. f) GDPR to enable a user-friendly and uncomplicated payment processing. The personal data transmitted to the online payment service provider is usually first name, surname, address, IP address, e-mail address, or other data required for order processing, as well as data related to the service, such as type of service, identity of the recipient, invoice amount and taxes in percent, billing information, etc. This transmission is necessary to provide the service with the payment method you have chosen, in particular to confirm your identity, to administer your payment and the customer relationship. Please note, however, that personal data may also be passed on by the online payment service provider to service providers, subcontractors or other associated companies if this is necessary to fulfil the contractual obligations arising from your order or if the personal data are to be processed on behalf of the company. Depending on the selected payment method, e.g. invoice or direct debit, the personal data transmitted to the provider will be transmitted by the provider to credit agencies. This transmission serves the purpose of identity and credit assessment with regard to the order you have placed. Which credit agencies are involved and which data are generally collected, processed, stored and passed on by the respective provider can be found in the respective data protection declarations of the providers:

Stripe, Inc.,185 Berry Street, Suite 550, San Francisco, CA 94107, USA at https://stripe.com/de/privacy#translation g. micropayment GmbH, Scharnweberstrasse 69, D-12587 Berlin at https://www.micropayment.de/about/privacy/

Transfer to third countries

We would like to inform you that your personal data may also be transferred to a server in a third country and thus processed outside the EU.

Duration

The data will be deleted as soon as they are no longer required for the purpose for which they were collected. In addition, the data will be deleted if you revoke your consent or request the deletion of your personal data. Contractual or legal obligation to provide personal data.The provision of personal data is neither required by law nor by contract and is not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide it may mean that you are unable to use this service or cannot use it to its full extent.

Payment Services

Description and purpose

If you decide to pay with one of the online payment service providers offered by us during the ordering process, your contact data will be transmitted to this provider in the course of the order process.

If you choose a payment method from the payment service provider Stripe, the payment will be processed via the payment service provider Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we will pass on the information you provided during the ordering process, together with information about your order (name, address, account number, bank sort code, credit card number if applicable, invoice amount, currency and transaction number) in accordance with Art. 6 (1) lit. b DSGVO. You can find more information on Stripe's data protection at the URL https://stripe.com/de/privacy#translation.
Stripe reserves the right to carry out a credit check on the basis of mathematical-statistical procedures in order to safeguard the legitimate interest in determining the user's ability to pay. The personal data necessary for a credit check and obtained in the course of payment processing may be transmitted by Stripe to selected credit agencies, which Stripe discloses to users upon request. The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, these are based on a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. Stripe uses the result of the credit check in relation to the statistical probability of non-payment for the purpose of deciding on the authorisation to use the selected payment method.
You can object to this processing of your data at any time by sending a message to Stripe or the appointed credit agencies.
However, Stripe may still be entitled to process your personal data if this is necessary for the contractual processing of payments.

The personal data transmitted to the online payment service provider is usually first name, surname, address, IP address, e-mail address, or other data required for order processing, as well as data related to the service, such as type of service, identity of the recipient, invoice amount and taxes in percent, billing information, etc. This transmission is necessary to provide the service with the payment method you have chosen, in particular to confirm your identity, to administer your payment and the customer relationship. Please note, however, that personal data may also be transmitted by the online payment service provider to service providers, subcontractors or other associated companies if this is necessary to fulfil the contractual obligations arising from your order or if the personal data are to be processed on behalf of the service provider. Depending on the selected payment method, e.g. invoice or direct debit, the personal data transmitted to the provider will be transferred by the provider to credit agencies. This transmission serves the purpose of identity and credit checks with regard to the order you have placed. Which credit agencies are involved and which data are generally collected, processed, stored and passed on by the respective provider can be found in the respective data protection declarations of the providers.

Legal basis

The lawfulness of the passing on of data results from Art. 6 para. p. 1 lit. b) GDPR, for the execution of the payment method chosen by you as well as our legitimate interests according to Art. 6 para. p. 1 lit. f) GDPR to enable a user-friendly and uncomplicated payment processing.

Recipient

The recipient is the respective payment service provider, such as American Express Services Europe Ltd., Mastercard SA, Visa Europe Services Inc., PayPal (Europe) S.à.r.l. & Cie. S.C.A., Amazon Payments Europe s.c.a. (secondary to Amazon EU SARL, Amazon Services Europe SARL and Amazon Media EU SARL), Stripe Inc. or micropayment GmbH.

Transfer to Third Countries

Data may be transferred to a third country.

Duration of data storage

The data is deleted as soon as it is no longer required for the purpose for which it was collected. In addition, the data will be deleted if you revoke your consent or request the deletion of your personal data.

Possibility of objection

You have the possibility to revoke your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

Contractual or legal obligation

There is no contractual or legal obligation to provide the data.

Further data protection information via link

https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html https://www.mastercard.de/de-de/datenschutz.html https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html https://www.paypal.com/de/webapps/mpp/ua/privacy-full  https://pay.amazon.com/de/help/201751600  https://stripe.com/de/privacy#translation https://www.micropayment.de/about/privacy/

Registration on our website

Where the data subject takes advantage of the possibility to register on the Internet site of the controller by providing personal data, the data shall be communicated to the controller in the relevant input mask. The data shall be stored by the controller solely for the purposes of internal use. The data will be deleted as soon as they are no longer required for the purpose for which they were collected. When registering, the user's IP address and the date and time of registration are stored. This serves to prevent abuse of the services. The data will not be passed on to third parties. An exception is made if there is a legal obligation to pass on the data. The registration of the data is necessary for the provision of contents or services. Registered persons have the possibility at any time to have the stored data deleted or changed. The person concerned will receive information about their stored personal data at any time.

Routine deletion and blocking of personal data

The controller shall process and store personal data relating to the data subject only for as long as necessary to achieve the purpose of storage. In addition, data may be stored for as long as this is provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. As soon as the storage purpose ceases to apply or a storage period prescribed by the aforementioned regulations expires, the personal data is routinely blocked or deleted.

Rights of the data subject

If your personal data is processed, you are the data subject within the meaning of the GDPR and you are entitled to the following rights in relation to the person responsible:

Right of access by the data subject acc. to Art. 15 GDPR

You can request confirmation from the person responsible as to whether personal data concerning you is being processed by us. If such processing is carried out, you may ask the controller for information on:

  1. the purposes for which the personal data are processed;
  2. the categories of personal data processed;
  3. the recipients or categories of recipients to whom your personal data have been or will be disclosed;
  4. the planned duration of storage of your personal data or, if it is not possible to give specific details, criteria for determining the duration of storage
  5. the existence of a right to rectification or erasure of your personal data, a right to have the processing limited by the controller or a right to object to such processing
  6. the existence of a right of appeal to a supervisory authority;
  7. all available information on the origin of the data when the personal data are not collected from the data subject;
  8. the existence of automated decision making, including profiling, in accordance with Art. 22, para. 1 and 4 GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended effects of such processing on the data subject.

You have the right to request information whether your personal data are transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.

Right to rectification acc. to Art. 16 GDPR

You have the right to obtain from the data controller the rectification and/or integration of any personal data processed concerning you if it is incorrect or incomplete. The data controller shall make the correction without delay.

Right to erasure acc. to Art. 17 GDPR

(1) You may request the controller to delete your personal data immediately and the controller is obliged to delete such data immediately if one of the following reasons applies:

  1. The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. You revoke your consent on which the processing was based in accordance with Article 6 (1) (a) or Article 9 (2) (a) of the GDPR and there is no other legal basis for the processing.
  3. You object to the processing in accordance with Article 21 (1) GDPR and there are no legitimate reasons for the processing which take precedence, or you object to the processing in accordance with Article 21 (2) GDPR.
  4. The personal data concerning you have been processed unlawfully
  5. The deletion of personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  6. The personal data concerning you have been collected in relation to information society services offered, in accordance with Article 8 (1) of the GDPR.

(2) If the controller has made your personal data public and is obliged to delete them in accordance with Article 17 (1) of the GDPR, he shall take reasonable measures, including technical measures, taking into account the available technology and implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to these personal data or copies or replications of these personal data.

(3) The right to erasure shall not apply where the processing is necessary

  1. for the exercise of the right to freedom of expression and information;
  2. to comply with a legal obligation to which the processing is subject under Union or national law to which the controller is subject, or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest relating to public health pursuant to Art. 9, para. 2 lit. h and i as well as Art. 9 para. 3 GDPR;
  4. for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the right referred to in para. 1 is likely to render impossible or seriously prejudice the attainment of the objectives of such processing, or
  5. to assert, exercise or defend legal claims.

Right to restriction of processing acc. to Art. 18 GDPR

Under the following conditions, you may request the restriction of the processing of your personal data:

  1. if you dispute the accuracy of your personal data for a period of time that allows the controller to verify the accuracy of the personal data;
  2. if the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of the personal data;
  3. if the controller no longer needs the personal data for the purposes of the processing, but you need them for the assertion, exercise or defence of legal claims; or
  4. if you have lodged an objection to the processing pursuant to Article 21 (1) of the GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh your reasons.

If the processing of your personal data has been restricted, these data - apart from their storage - may only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of major public interest of the Union or a Member State. If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

Notification obligation regarding rectification or erasure of personal data or restriction of processing acc. to Art. 19 GDPR

If you have exercised the right to rectify, erase or limit the processing, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification, erasure or limitation of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed of these recipients by the controller.

Right to data portability acc. to Art. 20 GDPR

You have the right to receive your personal data, which you have provided to the responsible person, in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another responsible party without hindrance by the responsible party to whom the personal data has been made available, if

  1. the processing is based on consent pursuant to Art. 6 Para. 1 letter a) GDPR or Art. 9 Para. 2 letter a) GDPR or on a contract pursuant to Art. 6 Para. 1 letter b) GDPR and
  2. the processing is carried out using automated procedures. In exercising this right, you also have the right to request that your personal data be transferred directly from one responsible party to another, insofar as this is technically feasible. The freedoms and rights of other persons may not be impaired by this. The right to data transferability shall not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right of objection acc. to Art. 21 GDPR

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. The controller will no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to processing of your personal data for such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes. You have the possibility, in connection with the use of information society services - notwithstanding Directive 2002/58/EC - to exercise your right to object by means of automated procedures using technical specifications.

Right to lodge a complaint with a supervisory authority acc. to Art. 77 GDPR

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of employment or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR. The supervisory authority to which the complaint has been lodged will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 77 of the GDPR.

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  1. is necessary for the conclusion or performance of a contract between you and the controller,
  2. is permitted by legal provisions of the Union or the Member States to which the controller is subject, and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests, or
  3. is done with your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to Article 9 (1) of the GDPR, unless Article 9 (2) a) or g) applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

With regard to the cases mentioned in a. and c., the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include, at a minimum, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to object to the decision.

Hubspot

Description and purpose

On this website we use HubSpot for our online marketing activities. HubSpot is a software company from the USA with a subsidiary in Ireland. Contact us: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500 This is an integrated software solution that we use to cover various aspects of our online marketing. These include, among others: Email marketing (newsletter and automated mailings, e.g. to provide downloads), social media publishing & reporting, reporting (e.g. traffic sources, access, etc. ...), contact management (e.g. user segmentation & CRM), landing pages and contact forms. Our registration service allows visitors to our website to learn more about our company, download content and provide their contact information and other demographic information. This information, as well as the content of our website, is stored on servers of our software partner HubSpot. We may use this information to contact visitors to our Web site and to determine what services of our company are of interest to them. All information collected by us is subject to this Privacy Policy. We use all information collected solely to optimize our marketing efforts. We also use HubSpot's live chat service "Messages" (round chat icon at the bottom right of the screen) to send and receive messages on some sub-pages to improve the user experience on our site. Upon consent and use of this feature, the following information is transmitted to HubSpot's servers: - Content of all chat messages sent and received - Contextual information (e.g., page on which the chat was used) - Optional: user's e-mail address (if provided by the user via chat feature).

Legal basis

The legal basis for the use of Hubspot's (CRM) services is Art. 6 (1) lit. f) GDPR (legitimate interest). Our legitimate interest in using this service is to optimize our customer service and the management of our contact information. For the live chat, the newsletter and other success measurements, the consent according to Art. 6 (1) lit. a) GDPR is the legal basis.

Recipient

The recipient is HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland. There is no data transfer to a third country. As HubSpot has a US parent company, the EU standard data protection clauses have already been concluded with the necessary additional measures.

Transfer to third countries

Data is transferred to third countries.

Duration of data storage

The data is deleted as soon as it is no longer required for the purpose for which it was collected. In addition, the data will be deleted if you revoke your consent or request the deletion of your personal data.

Possibility of objection

You have the possibility to revoke your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

Contractual or legal obligation

There is no contractual or legal obligation to provide the data.

Further data protection information via link

https://legal.hubspot.com/privacy-policy

Webflow

Description and purpose

circuly GmbH uses the service Webflow, of Webflow Inc., 398, 11th Street, 2nd Floor, San Francisco, CA 94103, USA to host the website. Webflow is used to ensure fast and location-independent availability of the website and to offer more security. Therefore, the website and the data are not only located on one server, but in a so-called Content Distribution Network (CDN), which is operated by Fastly Inc. and Amazon Web Services Inc. (AWS- Amazon Cloudfront).

Legal basis

The legal basis for the use ob Webflow ist Art. 6 (1) lit. f) GDPR. Our legitimate interest here is the fast availability of the website, regardless of the starting location of the website visitor, the protection against data loss and the fail- safety of the website.

Recipient

In addition to circuly GmbH, the recipient of the data is Webflow Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA.

Transfer to third countries

A transfer of data to the United States is possible.

Duration of data storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In addition, the storage period is based on the statutory retention periods. In addition, the data will be deleted if you request the deletion of personal data, provided that there are no legal retention periods to the contrary.

Contractual or legal obligation

There is no contractual or legal obligation to provide the data.

Further data protection information via link

https://webflow.com/legal/privacy

Google Analytics and Conversion Tracking

Description and purpose

This website uses the service "Google Analytics", which is provided by Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) to analyse the use of the website by users. The service uses "cookies" - text files which are stored on your end device. The information collected by the cookies is usually sent to a Google server in the USA and stored there. If necessary, Google Analytics is used on this website with the code "gat._anonymizeIp();" extended to ensure anonymous recording of IP addresses (so-called IP-Masking). Please also note the following information on the use of Google Analytics: Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The IP address of users is shortened within the member states of the EU and the European Economic Area. This shortening means that the personal reference of your IP address is no longer necessary. Within the framework of the data protection agreement, which the website operators have concluded with Google LLC, the latter uses the information collected to create an evaluation of website use and website activity and provides services associated with Internet use.

Legal basis

The legal basis is the norm of Art. 6 para. 1 lit. a) and Art. 49 para. 1 lit. a) GDPR, if anonymous data collection using the code "gat._anonymizeIp" does not take place. Otherwise, especially in the case of the use of "gat._anonymizeIp", Art. 6 para. 1 lit. f) GDPR is the legal basis.

Receiver

However, in the event that IP anonymisation is activated on this website, your IP address will be shortened by Google in advance within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. In addition, we use Google Conversion Tracking in connection with Google Analytics. This enables us to record the behavior of our website visitors. For example, it shows us how many PDFs were downloaded from our website or how often the contact form was filled out. It also shows us how many clicks on advertisements from external sources (AdWords, LinkedIn, Xing, Facebook, Pinterest, Instagram etc.) have led to our website. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link (https://tools.google.com/dlpage/gaoptout?hl=de).

Transfer to third countries

Personal data is transferred to the USA under the Art. 46 GDPR and Art. 49 GDPR.

Duration of data storage

The data sent by us and linked to cookies, user IDs (e.g. User ID) or advertising IDs are automatically deleted after 14 months. The deletion of data whose retention period has been reached is automatically carried out once a month.

Cancellation and objection option

You can prevent the storage of cookies by adjusting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser add-on. Opt-out cookies prevent the future collection of your data when visiting this website. To prevent Universal Analytics from collecting data across multiple devices, you must opt-out on all systems in use.

Contractual or legal obligation

The provision of personal data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide it may mean that you cannot or cannot fully use this function of our website.

Further data protection information via link

Further information on terms of use and data protection can be found at: https://policies.google.com/?hl=de&gl=del https://policies.google.com/privacy?hl=de&gl=de

LinkedIn Analytics

Description and Purpose

Our website uses features of the LinkedIn network, including the LinkedIn Analytics feature. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access one of our pages that contains LinkedIn features, a connection to LinkedIn servers is established. LinkedIn is notified that you have visited our sites using your IP address. If you click the LinkedIn "Recommend" button and are logged into your LinkedIn account, LinkedIn is able to track your visit to our site to you and your account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. LinkedIn Analytics uses "cookies", which are stored on your computer and which enable an analysis of your use of the website. LinkedIn uses this information to evaluate your use of the website, to compile reports on website activities for the website operators and to provide further services related to website and internet use.

Legal basis

The legal basis is the norm of Art. 6 para. 1 lit. a) and Art. 49 para. 1 lit. a) GDPR.

Recipient

The recipient is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.

Transfer to third countries

Personal data is transferred to the USA under the Art. 46 GDPR and Art. 49 GDPR.

Duration of data storage

The data is deleted as soon as it is no longer required for the purpose for which it was collected. In addition, the data will be deleted if you revoke your consent or request the deletion of personal data.

Possibility of objection

You have the possibility to revoke your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

Contractual or legal obligation

There is no contractual or legal obligation to provide the data.

Further data protection information via link

https://www.linkedin.com/legal/privacy-policy

Google Adsense

Description and purpose

We have integrated Google AdSense of the company Google LLC (Google) on this website. Google AdSense is an online service that enables the placement of advertising on third party sites. Google AdSense is based on an algorithm which selects the advertisements displayed on third party sites according to the content of the respective third party site. Google AdSense allows an interest-based targeting of the internet user, which is implemented by generating individual user profiles. The purpose of the Google AdSense component is the integration of advertisements on this website. Google AdSense sets a cookie on the information technology system of the person concerned. By each call of one of the single pages of this website, which is operated by us and on which a Google AdSense component was integrated, the internet browser on the information technological system of the person concerned is automatically induced by the respective Google AdSense component to transmit data to Google for the purpose of online advertising and the accounting of commissions. In the course of this technical process, Google receives knowledge of personal data, such as the IP address of the person concerned, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission invoicing. Google AdSense also uses so-called counting pixels. A pixel-code is a miniature graphic that is embedded in websites to enable log file recording and log file analysis, which enables statistical evaluation. The embedded pixel-code enables Google to recognise whether and when a website was opened by a person concerned and which links were clicked on by the person concerned. Counting pixels are used, among other things, to evaluate the flow of visitors to a website. Through Google AdSense, personal data and information, which includes the IP address and is necessary for the collection and billing of the ads displayed, is transferred to Google.

Legal basis

The legal basis is the consent pursuant to Art. 6 para. 1 lit. a) GDPR.

Recipient

The data is usually transferred to a Google server in the USA and stored there.

Transfer to third countries

Personal data is transferred to the USA under the Art. 46 GDPR and Art. 49 GDPR.

Duration of data storage

The data sent by us and linked to cookies, user IDs (e.g. User ID) or advertising IDs are stored for 26 months by default and are automatically deleted after this period.

Possibility of objection

The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies.

Contractual or legal obligation

There is no contractual or legal obligation to provide the data.

Further data protection information via link

https://www.google.com/adsense/new/localized-terms?hl=de

Google Ajax

Description and purpose

We use Ajax to optimize loading speeds. In this context, program libraries of Google servers are called. The CDN (Content delivery network) of Google is used. If you have used jQuery on another page of the Google CDN before, your browser will fall back to the cached copy. If this is not the case, it will require a download, whereby data from your browser is sent to Google LLC. ("Google").

Legal basis

The legal basis for the processing of personal data is the legitimate interest pursuant to Art. 6 para. 1 lit. f) DSGVO.

Recipient

The data is usually transferred to a Google server in the USA and stored there.

Transfer to third countries

Personal data is transferred to the USA under the Art. 46 GDPR and Art. 49 GDPR.

Duration of data storage

The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs are stored for 26 months as standard and are automatically deleted thereafter.

Possibility of objection

You can prevent the storage of cookies by adjusting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent.

Contractual or legal obligation

There is no contractual or legal obligation to provide the data.

Further data protection information via link

https://policies.google.com/privacy?hl=de&gl=del https://developers.google.com/speed/libraries/#jquery

Google Double Click

Description and purpose

This website continues to use the online marketing tool Campaign Manager from Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Campaign Manager uses cookies to deliver ads relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to track which ads are served in which browser and to prevent them from being shown more than once. Campaign Manager may also use cookie IDs to track conversions related to ad requests. For example, when a user sees a Campaign Manager ad and later visits the advertiser's site on the same browser to make a purchase. According to Google, Campaign Manager cookies do not contain any personal information. Because of the marketing tools used, your browser automatically establishes a direct connection with Google's server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of Campaign Manager, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will find out and save your IP address. In addition, the Campaign Manager (DoubleClick Floodlight) cookies enable us to understand whether you perform certain actions on our website after you have called up or clicked on one of our display/video ads on Google or on another platform via Campaign Manager (conversion tracking). Campaign Manager uses this cookie to understand the content that you have interacted with on our sites so that we can later send you targeted advertisements. In addition, you can prevent Google from collecting the data generated by the cookies about your use of the websites and the processing of this data by Google by downloading and installing the browser plugin available at https://support.google.com/adsense/answer/142293?hl=de under "Display settings", "Extension for Campaign Manager deactivation".

Legal basis

The legal basis is the norm of Art. 6 para. 1 lit. a) and Art. 49 para. 1 lit. a) GDPR.

Recipient

The recipient is Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA).

Transfer to third countries

The data is transferred to a Google server in the USA and stored there. The personal data is transmitted on the basis of Art. 49 and/or Art. 46 DSGVO. You will find a list of the subcontractors used by Google under the following link:

https://privacy.google.com/businesses/subprocessors/

Duration of data storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. In addition, the data will be deleted if you revoke your consent or request the deletion of your personal data.

Possibility to object

You can prevent participation in this tracking process in a number of ways: a) by adjusting your browser software accordingly, in particular by suppressing third-party cookies so that you do not receive third-party ads; b) by disabling cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com, https://www.google. de/settings/ads, whereby this setting will be deleted if you delete your cookies; c) by deactivating interest-based ads from the providers that are part of the self-regulation campaign "About Ads" via the link http://www.aboutads.info/choices, whereby this setting will be deleted if you delete your cookies; d) by permanently deactivating them in your Firefox, Internet Explorer or Google Chrome browsers under the link http://www.google.com/settings/ads/plugin, e) by means of an appropriate cookie setting. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent.

Contractual or legal obligation

The provision of personal data is not required by law or contract and is not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide it may mean that you are unable to use our website or cannot use it to its full extent.

Further data protection information:

You can find further information about Campaign Manager at https://www.google.de/doubleclick and about data protection at Google in general at https://policies.google.com/privacy?hl=de&gl=de. Alternatively, you can visit the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org.

Google Tag Manager

Description and purpose

Google Tag Manager is used on this website. The Google Tag Manager is a solution from Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), which enables companies to manage website tags through one interface. Google Tag Manager is a cookie-less domain that does not collect personal information. Google Tag Manager triggers other tags that may collect data. We hereby draw your attention to this separately. The Google Tag Manager does not access this data. If deactivation has been made by the user at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage for the website operator. Google uses pseudonyms for this purpose. The IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google. More information about the Google Tag Manager can be found at: https://www.google.com/intl/tagmanager/

Legal basis

The legal basis for this processing is your consent in accordance with Art. 6 para. 1 lit. a) DSGVO.

Recipient

The data is usually transferred to a Google server in the USA and stored there.

Transfer to third countries

Personal data is transferred to the USA under the Art. 46 GDPR and Art. 49 GDPR.

Duration of data storage

The data is deleted as soon as it is no longer required for the purpose for which it was collected. In addition, the data will be deleted if you revoke your consent or request the deletion of your personal data.

Contractual or legal obligation

The provision of personal data is neither legally nor contractually required and is not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. Failure to provide it may, however, under certain circumstances result in your not being able to use our website or not being able to use it in full.

Further data protection information via link

Further information on terms of use and data protection can be found at: https://policies.google.com/?hl=de&gl=del   https://policies.google.com/privacy?hl=de&gl=de

Integration of other third-party services and content

Description and purpose

It can happen that within this online offer contents of third parties, such as videos, fonts or graphics from other websites are integrated. This always requires that the providers of these contents (hereinafter referred to as "third party providers") are aware of the IP address of the users. Without the IP address, they would not be able to send the content to the browser of the respective user. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. However, we have no influence on this if the third-party providers store the IP address for statistical purposes, for example. As far as we are aware of this, we inform the users about it. We would like to provide and improve our online offer through these integrations.

Legal basis

The legal basis for the integration of other services and content of third parties is Art. 6 para. 1 lit. f) GDPR. Our overriding legitimate interest lies in the intention of an appropriate presentation of our online presence and user-friendly and economically efficient services on our part. For further information, please refer to the respective privacy statements of the providers.

Contractual or legal obligation to provide personal data

The provision of personal data is neither legally nor contractually required and is also not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide it may mean that you are unable to use this function or cannot use it to its full extent.

Data transmission to third countries

The controller may transfer personal data to a third country. In principle, the controller may provide various appropriate safeguards to ensure that an adequate level of protection is provided for the processing operations. It is possible to transfer data transfers on the basis of an adequacy finding, internal data protection rules, approved codes of conduct, standard data protection clauses or an approved certification mechanism pursuant to Art. 46 para. 2 letters a) - f) GDPR.

If the person responsible undertakes a transfer to a third country on the legal basis of Art. 49 para. 1 a) GDPR, you will be informed at this point about the possible risks of a data transfer to a third country.

There is a risk that the third country receiving your personal data may not provide an equivalent level of protection compared to the protection of personal data in the European Union. This may be the case, for example, if the EU Commission has not issued an adequacy decision for the third country in question or if certain agreements between the European Union and the third country in question are declared invalid. Specifically, there are risks in some third countries with regard to the effective protection of EU fundamental rights through the use of monitoring laws (e.g. USA). In such a case, it is the responsibility of the controller and the recipient to assess whether the rights of data subject in the third country enjoy a level of protection equivalent to that in the Union and can be effectively enforced.

However, the basic data protection regulation should not undermine the level of protection of natural persons ensured throughout the Union when personal data are transferred from the Union to controllers, processors or other recipients in third countries or to international organizations, even if personal data are further transferred from a third country or from an international organization to controllers or processors in the same or another third country or to the same or another international organization.

Further functions of the website

Applications

By submitting their application to us, applicants agree to the processing of their data for the purposes of the application procedure in accordance with the type and scope described in this data protection declaration. The legal basis for the processing of applicant data is Art. 88 GDPR, § 26 BDSG-neu and Art. 9 (2) (b) GDPR. Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 GDPR are voluntarily communicated as part of the application procedure, they will also be processed in accordance with Art. 9 Para. 2 lit. b) GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 GDPR are requested from applicants within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 Para. 2 letter a) GDPR (e.g. health data if these are necessary for the exercise of the profession). If made available, applicants can submit their applications to us by means of an online form on our website. The data will be transmitted to us in encrypted form according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not encrypted and that applicants must ensure that they are encrypted themselves. We can therefore not assume any responsibility for the transmission path of the application between the sender and the receipt on our server and therefore recommend rather to use an online form or the postal dispatch. This is because instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post. In the event of a successful application, the data provided by the applicants can be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data is deleted. Applicants' data is also deleted if an application is withdrawn, which applicants are entitled to do at any time. The data will be deleted after the expiry of a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the General Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Safety

We have taken extensive technical and operational precautions to protect your data from accidental or deliberate manipulation, loss, destruction or access by unauthorised persons. Our security procedures are regularly reviewed and adapted to technological progress. In addition, we guarantee data protection on an ongoing basis by constantly auditing and optimizing our data protection organization.

Conclusion

circuly GmbH reserves all rights to make changes and updates to this privacy policy. This privacy policy was created by the dataprotectionsystem and hellotrust, a trademark of Keyed GmbH.