Kertos | Privacy Policy

Status October 2022

Name and address of the responsible person
General information on data processing
Rights of the data subject
Provision of the website and creation of the log files
Cookies use
Email contact
Application by email
Company websites
Use of company presences in job-oriented networks
Hosting
Content Delivery Networks
Plugins used

I. Name and address of the responsible person & data protection officer

The controller within the meaning of the General Data Protection Regulation (GDPR) and other provisions of data protection law is:

Kertos GmbH
Klosterhofstr. 6
80331 Munich
Germany

datenschutz@kertos.io
www.kertos.io

II. General information on data processing

1. scope of the processing of personal data

We process personal data of our users only insofar as this is necessary for the provision of a functional website and our content and services. The processing of personal data of our users takes place regularly only after consent of the user. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is required by legal regulations.

2. legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 (1) sentence 1 lit. aDSGVO serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6 (1) sentence 1 lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 (1) sentence 1 lit. c DSGVO serves as the legal basis.

In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Article 6 (1) sentence 1 lit. d DSGVO serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-mentioned interest, Article 6 (1) sentence 1 lit. f DSGVO serves as the legal basis for the processing.

3. legal basis for the processing of data on your terminal device

The legal basis for the use of technically necessary cookies and related data processing is § 25 para. 2TTDSG in conjunction with. Art. 6 para. 1 lit. f) DSGVO. The processing serves to facilitate your use of our website and to offer you our services. Our legitimate interest in the processing of cookies arises from the aforementioned purposes. The cookies are deleted after the end of the session (e.g. logging out or closing the browser) or after the expiry of a specified duration.

The legal basis for the use of technically unnecessary cookies is your consent, which you have given us via the cookie banner in accordance with §25 para. 1 TTDSG in conjunction with. Art. 6 para. 1 lit. a) DSGVO have given. For these services, you can revoke your consent at any time with effect for the future or subsequently grant it again by accessing your cookie and privacy settings online via our privacy information and configuring them accordingly. Alternatively, you can prevent the storage of cookies by selecting the appropriate settings on your browser software.

4. data deletion and storage period

The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

IV. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

1. right to information

You may request confirmation from the controller as to whether personal data concerning you are being processed by him.

If there is such processing, you can request information about the following:

the purposes for which the personal data are processed;
the categories of personal data which are processed;
the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
the existence of a right of appeal to a supervisory authority;
any available information on the origin of the data, if the personal data are not collected from the data subject;
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.

2. right to rectification

You have a right of rectification and/or completion vis-à-vis the data controller if the personal data processed concerning you are inaccurate or incomplete.

3. right to restriction of processing

Under the following conditions, you can request the restriction of the processing of personal data concerning you:

if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims, or
if you have objected to the processing pursuant to Art. 21 (1) DSGVO and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.

Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

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4. right to deletion

a) Obligation to delete

You may request the controller to delete the personal data concerning you without undue delay. The controller is also obliged to delete this data immediately if one of the following reasons applies:

The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
You revoke your consent on which the processing was based pursuant to Art. 6 (1) p. 1 lit. a or Art. 9 (2) lit. a DSGVO and there is no other legal basis for the processing.
You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
The personal data concerning you have been processed unlawfully.
The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8 (1) DSGVO.

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b) Information to third parties

If the controller has made public the personal data concerning you and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, to inform data controllers processing the personal data that you, as the data subject, have requested erasure of all links to or copies or replications of such personal data, taking into account the available technology and the cost of implementation.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary to

to exercise the right to freedom of expression and information.
for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO;
for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
for the assertion, exercise or defense of legal claims.

5. right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data relating to you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients by the controller.

6. right to data portability

You have the right to obtain the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that

the processing is based on consent pursuant to Art. 6 para. 1 sentence 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 sentence 1 lit. b DSGVO and
the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6 (1) sentence 1 lit. e or fDSGVO; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of 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, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.

8. right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

9. 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

is necessary for the conclusion or fulfillment of a contract between you and the responsible party,
is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
is done with your express 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 (b) of the GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

With regard to the cases referred to in 1. and 3. above, the controller shall take reasonable measures to safeguard the rights and freedoms as well as your legitimate interests, which include at least the right to obtain the intervention of a person on the part of the controller, to express his own point of view and to contest the decision.

10. right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

V. Provision of the website and creation of log files

1. description and scope of data processing

Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer. The following data is collected:

Information about the browser type and version used
The operating system of the user
The Internet service provider of the user
The IP address of the user
Date and time of access
Websites from which the user’s system accesses our website
Web pages that are called up by the user’s system via our website

This data is stored in the log files of our system. A storage of this data together with other personal data of the user does not take place.

2. purpose of data processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 p. 1 lit. f DSGVO.

3. legal basis for data processing

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 p. 1 lit. f DSGVO. The legitimate interest lies in the purpose of ensuring the functionality of the website, optimizing the website and ensuring the security of the information technology systems.

4. duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session is ended.

In the case of storage of data in log files, this is the case after a maximum of seven days. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

5. possibility of objection and elimination

The collection of data for the provision of the website and the storage of the data in log files is necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

VI. use of cookies

1. description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user calls up a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic character string that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make our website more user-friendly.some elements of our website require that the calling browser can be identified even after a page change.

We also use cookies on our website that allow us to analyze the surfing behavior of users.

In this way, the following data can be transmitted:

Entered search terms
Frequency of page views
Use of website functions

The user data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data is not stored together with other personal data of the user.

2. purpose of data processing

The purpose of the use of technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

We need cookies for the following applications:

Adaptation of the display to the device and operating system

The user data collected through technically necessary cookies are not used to create user profiles.

The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer.

3. legal basis for data processing

The legal basis for the processing of personal data using technically unnecessary cookies is Art. 6 para. 1 p. 1 lit.a DSGVO.

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 p. 1 lit. fDSGVO. The legitimate interest is to ensure the technical functionality of the website.

4. duration of storage, possibility of objection and elimination

Cookies are stored on the user’s computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been saved can be deleted at any time, and this can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website in full.

If you use a Safari browser version 12.1 or higher, cookies are automatically deleted after seven days. This also applies to opt-out cookies, which are set to prevent tracking measures.

VII. email contact

1. description and scope of data processing

On our website it is possible to contact us via the email address provided. In this case, the personal data of the user transmitted with the email will be stored and used exclusively for the processing of the conversation.

2. purpose of data processing

In the case of contact by email, this also constitutes the necessary legitimate interest in the processing of the data.

3. legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f DSGVO.If the email contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.

4. duration of storage

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation is terminated when the circumstances indicate that the matter in question has been conclusively clarified. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. possibility of objection and elimination

The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

The consent can be revoked at any time by sending an email to datenschutz@kertos.io.

All personal data stored in the course of contacting us will be deleted in this case.

VIII. Application by email

1. scope of the processing of personal data

You can send us your application by email. We will collect your email address and the data you provide in the email.

First name, last name
Email address
Date of birth
Information that the applicant wants to provide
Address
Residence
Telephone number
Photo

2. purpose of data processing

The processing of personal data from your application email serves us solely to process your application.

3. legal basis for data processing

The legal basis for the processing of your data is the contract initiation which takes place at the request of the data subject, Art. 6 para. 1S.1 lit. b Alt. 1 DSGVO and § 26 para. 1 p. 1 BDSG.

4. duration of storage

After completion of the application process, the data will be stored for up to three months. After three months at the latest, your data will be deleted. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.

5. possibility of objection and elimination

The applicant has the possibility to object to the processing of personal data at any time. In such a case, the application can no longer be considered. The consent can be revoked at any time by sending an e-mail to hello@kertos.io.

All personal data stored in the course of electronic applications will be deleted in this case.

IX. Company appearances

Use of corporate presences in social networks

Instagram: Instagram, Part of Facebook Ireland Ltd, 4 Grand Canal Square GrandCanal Harbour, Dublin 2 Ireland

On our company page, we provide information and offer Instagram users the opportunity to communicate. If you carry out an action on our Instagram company page (e.g. comments, posts, likes, etc.), it is possible that you make personal data (e.g. clear name or photo of your user profile) public. However, since we generally or to a large extent have no influence on the processing of your personal data by Instagram, the company jointly responsible for the Kertos GmbH corporate presence, we cannot make any binding statements about the purpose and scope of the processing of your data.

In order to ensure appropriate guarantees for the protection of the transfer and processing of personal data outside the EU, the data transfer to and processing of data by Instagram is carried out on the basis of appropriate guarantees pursuant to Art. 46 et seq. of the GDPR, in particular by concluding so-called standard data protection clauses pursuant to Art. 46 (2) lit. c of the GDPR.

Our company presence in social networks is used for communication and information exchange with (potential) customers. In particular, we use the company presence for:

Information and updates on the product and the company, itsemployees, its founders and investors themselves, industry news in the area ofgovernance and compliance, announcements of webinars, events, material andblogposts.

The publications on the company’s website may contain the following content:

Information about products
Information about services
Advertising
Customer contact

Each user is free to publish personal data through activities.

The legal basis for the data processing is Art. 6 para.1 p.1 lit. a DSGVO.

The data generated by the corporate presence is not stored in our own systems.

You can object at any time to the processing of your personal data that we collect in the course of your use of our Instagram corporate presence and assert your data subject rights as set out in IV. of this privacy policy. To do so, send us an informal email to hello@kertos.io.

You can find more information about the processing of your personal data by Instagram and the corresponding objection options here:

Instagram: https://help.instagram.com/519522125107875

YouTube: YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, United States.

On our company page, we provide information and offer YouTube users the opportunity to communicate. If you carry out an action on ourYouTube company site (e.g. comments, posts, likes, etc.), it may be that you make personal data (e.g. plain name or photo of your user profile) public. However, since we generally or to a large extent have no influence on the processing of your personal data by YouTube, the company jointly responsible for the Kertos GmbH corporate presence, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

In order to ensure appropriate safeguards for the protection of the transfer and processing of personal data outside the EU, the transfer of data to and processing of data by Youtube shall be carried out on the basis of appropriate safeguards pursuant to Art. 46 et seq. of the GDPR, in particular by concluding so-called standard data protection clauses pursuant to Art. 46 (2) lit. c of the GDPR.

Our company presence in social networks is used for communication and information exchange with (potential) customers. In particular, we use the company presence for:

In this context, publications about the company’s presence may include the following content:

Information about products
Information about services
Advertising
Customer contact

Each user is free to publish personal data through activities.

The legal basis for the data processing isArt. 6 para.1 p.1 lit. a DSGVO.

The data generated by the company website is not stored in our own systems.

You can object at any time to the processing of your personal data that we collect in the context of your use of our YouTube corporate presence and assert your data subject rights mentioned under IV. of this privacy policy. To do so, send us an informal email to hello@kertos.io.

You can find more information about the processing of your personal data by YouTube and the corresponding objection options here:

YouTube: https://policies.google.com/privacy?gl=DE&hl=de

X. Use of company presencesin job-oriented networks

1. scope of data processing

We use the possibility of company appearances on profession-oriented networks. We maintain a company presence on the following job-oriented networks:

LinkedIn: LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland

On our site we provide information and offer users the possibility of communication.

The company website is used for applications, information/PR and ActiveSourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the company website. For more information, please refer to the privacy policy of:

LinkedIn: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

If you perform an action on our company website (e.g. comments, posts, likes, etc.), you may disclose personal data (e.g. clear name or photo of your user profile).

2. legal basis for data processing

The legal basis for the processing of your data in connection with the use of our corporate presence is Art.6 para.1 p.1 lit. f DSGVO.

3. purpose of the data processing

The purpose of our corporate website is to inform users about our services. Every user is free to publish personal data through activities.

4. duration of storage

We store your activities and personal data published via our corporate website until you revoke your consent. In addition, we comply with the statutory retention periods.

5. possibility of objection and removal

You can object at any time to the processing of your personal data that we collect in the course of your use of our company website and exercise your data subject rights listed under IV. of this data protection declaration. To do so, send us an informal email to the email address stated in this data protection declaration.

You can find more information on objection and removal options here: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

XI. Hosting

The website is hosted on servers of a service provider contracted by us. Our service provider is: TelekomOpen Cloud

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The information stored is:

Browser type and version
Operating system used
Referrer URL
Host name of the accessing computer
Date and time of the server request
IP address

A combination of this data with other data sources is not made. The collection of this data is based on Art. 6 para. 1lit. f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – this is why the server log files must be collected.

The location of the Website’s server is geographically within theEuropean Union (EU) or the European Economic Area (EEA).

XII Content Delivery Networks

1. description and scope of data processing

We host our website with Webflow. The provider is Webflow,Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter:Webflow). When you visit our website, Webflow collects various log files including your IP addresses.

Webflow is a tool for creating and hosting websites. Webflow stores cookies or other recognition technologies that are necessary for the display of the page, to provide certain website features and to ensure security (necessary cookies).

Details can be found in the Webflow privacy policy: EU & Swiss PrivacyPolicy | Webflow

2. purpose of data processing

The use of Webflow functions serves to deliver and accelerate online applications and content.

3. legal basis for data processing

The collection of this data is based on Art. 6 para. 1 lit.f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected.

4. duration of storage

Your personal information will be retained for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law.

5. possibility of objection and removal

For information on how to object to and removeCloudFlare, please visit:
https://www.cloudflare.com/de-de/privacypolicy/

XIII Plugins used

We use plugins for various purposes. The plugins used are listed below:

Service

Provider

Third country transfer (country)

*(no third country transfer)
**(own hosting)
***(adequacy decision)

Purpose of
data processing

Legal basis of
data processing

Information on data protection and appropriate safeguards for third country transfers

Google Web Fonts

Google Ireland Ltd.

Ireland (USA)

Fonts

Art. 6 para. 1 p.1 lit. a DSGVO

https://policies.google.com/privacy?gl=DE&hl=de

https://business.safety.google/gdpr/

Google analytics

Google Ireland Ltd.

Ireland (USA)

Tracking

Art. 6 para. 1 p.1 lit. a DSGVO

https://support.google.com/policies/contact/general_privacy_form

Google Ads

Tracking