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    Data protection of Systain Consulting GmbH

    Data protection information from Systain Consulting GmbH, Brandstwiete 1, 20457 Hamburg for the website www.systain.com

    In the following data protection information, we inform you about the data processing carried out by Systain Consulting GmbH, Brandstwiete 1, 20457 Hamburg ( “Systain ” and/or ” we” and/or ” person responsible ” ) . Hard processing of personal data in accordance with the GDPR and the Federal Data Protection Act (BDSG 2018).

    Please read our data protection information carefully. If you have any questions or comments about our data protection information, please contact us at datenschutz@systain.com.

    Contents overview

    1. Name and contact details of the person responsible for processing

    2. Contact details regarding data protection requests

    3. Online presence and website optimization (using cookies) including consent

    3.1. Cookies – General information and consent requirement

    3.2. Options for intervention / browser settings

    3.3 Consent management by the provider WebToffee

    3.4. Consent to the use of individual online services / the collection of tracking data

    4. Contact

    5 categories of recipients

    5.1 Processor

    5.2 Other Third Party Partners

    6. Sending emails

    6.1 Newsletter

    6.2 Sending emails

    7. Participation in events and web seminars

    8. Data protection notice for applicants

    8.1. Data processing to carry out the application process

    8.2 Duration of storage

    8.3 Recipients of applicant data

    9. Recipients outside the EU

    10. Duration of storage of the data

    11. Your Rights

    11.1. Your rights in detail

    1. Name and contact details of the person responsible for processing

    This data protection information applies to data processing by

    Systain Consulting GmbH

    Brandstwiete 1

    20457 Hamburg

    represented by the managing director:

    Hubertus Drinkuth

    for the websites: www.systain.com.

    2. Contact details regarding privacy requests

    If you have any questions regarding data protection at Systain Consulting GmbH , you are welcome to contact datenschutz@systain.com.

    3. Online presence and website optimization (using cookies) including consent

    collect data about the behavior of users on the website mentioned (tracking data). This includes , among other things, which individual sub-pages were accessed. For this purpose , we can, among other things, set cookies in the browser used by the respective user. In principle, the collection of tracking data is only permitted if you have previously consented to this ( § 25 Para . 1 S. 1 TTDSG) . You can give such consent by clicking on the ” Accept all” button in the ” Cookie banner ” displayed on this website. However, the granting of consent is not necessary for the processing of such tracking data, which is required for the website to offer ( § 25 Para . 2 No. 2 TTDSG) . The information about your usage behavior can be used by us, among other things, to show you interesting offers on our website or to advertise you on other websites using personalized content (e.g. retargeting) . Insofar as personal data about your usage behavior on this website can also be used by other providers, e.g. for the purpose of ” enhancing your own information ” , such use will only take place in these cases if you have previously consented to it to have. In these cases , the further processing of the data collected on this website is usually the sole responsibility of the provider. As part of this further processing, the providers can transmit the data to the USA . With regard to the USA, the European Court of Justice has determined that this is a country with an insufficient level of data protection. In this context, there is a particular risk that your data will be processed by American institutions/ authorities for control and monitoring purposes without you being given an adequate legal remedy. We only process tracking data that we collect and store ourselves in pseudonymised form. This prevents the data from being assigned to you personally. If you want to delete individual cookies set in your browser or want to find out which service providers / providers have set cookies in your browser, you can do / find out about this via a ” preference manager”. One of these is available, for example, at www.youronlinechoices.com. You also have the option of setting your browser in such a way that it prevents the setting of cookies or only allows the setting of certain types of cookies . Details on the possibility of changing the settings of the common browser types (including Google Chrome , Firefox) can be found under Section 3.2. of this Privacy Notice.

    3.1. Cookies – General information and consent requirement

    Cookies are used on this website. Cookies are small text files that your browser creates automatically and that are stored on your end device (laptop, tablet, smartphone, etc. ) . Information is stored in the cookie that arises in connection with the specific end device used . However, this does not mean that we are immediately informed of your identity . Some of the cookies we use are deleted after the end of the browser session (so-called session cookies) . Other cookies remain on your computer and enable us to recognize your computer on your next visit (so-called permanent or cross-session cookies ). In particular, these cookies are used, among other things, to make our offer more attractive for you. Thanks to these files, it is possible, for example , to display information on this website that is tailored specifically to your interests.

    According to the legal requirements, the storage of information on end devices and (desktops, mobile phones, tablets, etc. ) – e.g. by setting cookies – as well as the retrieval of information from end devices ( tracking) is fundamentally prohibited Only permitted if you have previously given your consent. The legal basis for this is § 25 paragraph 1 sentence 1 TTDSG . However, consent does not have to be given if such storage / retrieval is necessary for the website offer. The legal basis for this is § 25 paragraph 2 number 2 TTDSG . A requirement is given, for example, with regard to ensuring the following functionalities / achieving the following purposes:

    – Ensuring system security

    – Enable affiliate billing.

    With regard to the data processing that is necessary for the operation of the website, you have no right of objection.

    You can use this website without data being retrieved from or stored on your end device for purposes that are not required for the offering of this website. For this reason, when you use this website – unless you give your consent – only ” basic tracking ” is activated.

    3.2. Options for intervention / browser settings

    You can of course set up your browser so that it does not store our cookies on your end device . The help function in the menu bar of most web browsers tells you how to stop your browser from accepting new cookies, how to have your browser notify you when you receive a new cookie, or how to delete all of them delete cookies that have already been received and block them for all others .

    Please do the following:

    In Internet Explorer:
    1. From the ” Extras ” menu, select “Internet Options”.
    2 . Click on the “Privacy” tab.
    3. Now you can make the security settings for the Internet zone. Here you set whether and which cookies should be accepted or rejected.
    4. Confirm your setting with “OK” .

    In Firefox:
    1. From the ” Extras ” menu, select Settings.
    2 . Click on “Privacy”.
    3. Select the entry ” Create according to user-defined settings” from the drop-down menu.
    4. Now you can set whether to accept cookies , how long you want to keep those cookies and add exceptions to which websites you always or never want to allow to use cookies.
    5 . Confirm your setting with “OK” .

    In Google Chrome:
    1. Click the Chrome menu on the browser toolbar.
    2. Now select “Settings”.
    3. Click “Show advanced settings”.
    4. Under “Privacy” click “Content Settings”.
    5. Under “Cookies” you can make the following settings for cookies:
    • Delete cookies
    • Block cookies by default
    • Delete cookies and website data by default after closing the browser < br> • Allow exceptions for cookies from specific websites or domains

    If you want to delete individual cookies set in your browser or want to find out which service providers / providers have set cookies in your browser, you can also do this via a ” preference manager”. Such is available, for example, at www.youronlinechoices.com.  

    3.3 Consent management by the provider WebToffee

    We use the WebToffee consent tool, registered as Mozilor Limited, 10 Paxton Crescent, Shenley Lodge, Milton Keynes, MK5 7PY, United Kingdom ( “ CookieYes ”) to manage your settings and document consent from users of our services. ). CookieYes is used, among other things, to save the cookie settings for the entire website. CookieYes stores information about the categories of cookies used by the website and whether users have given or withdrawn their consent to the use of each category. This allows us to prevent cookies from being set in each category in the user’s browser if consent is not given for individual categories. CookieYes uses cookies for information storage, which have a normal lifespan of one year, so that the settings of returning visitors are saved. The legal basis for this is Article 6 Paragraph 1 c GDPR .

    3.4. Consent to the use of individual online services / the collection of tracking data

    As in Section 4.1. As already explained in this information on data protection, we collect and process tracking data in part on the basis of consent. You give this consent by clicking on the “ ACCEPT” button in a banner on the website that links to these consent texts. By clicking on the ” ACCEPT” button, you give your consent for us to store data on your end device (e.g. by setting cookies) or to retrieve data from your end device . Furthermore, by clicking on the ” ACCEPT ” button, you give your consent to the use of certain advertising functionalities from third-party providers, the use of which requires consent . You also have the option of clicking on ” Settings ” in the banner and managing your consent preferences there. You can subsequently change your consent and preferences in our Consent management at any time . A distinction is made there between “ technically necessary ” , “ performance ” and “marketing ” . The data processing that takes place in connection with these advertising functionalities is described below (Section 4.4.1 to Section 4.4.3 of this data protection declaration ).

    All data processing that is recorded by the consent you gave by clicking on the ” ACCEPT” button serves the same purpose, namely that of ” advertising ” .

    Revocation of all consent

    You can revoke all consents that you have given by clicking on the “Accept” button in the banner by clicking here: [ cookie_reject ]

    3.4.1 Necessary: Technically necessary cookies (no consent required)

    3.4.1.1 Web analysis with Matomo

    For the purpose of the needs-based design and continuous optimization of this website, we use the open source software of the web analysis service provider Matomo on the legal basis in Article 6 Paragraph 1 Letter f) DSGVO (legitimate interest). The Matomo plugin enables us to store so -called ” cookies ” (text files) on your computer, which enables us to analyze your use of the website . Here we will evaluate your use of the website and compile reports on website activity .

    3.4.2 Consent for performance cookies

    3.4.2.1 Consent for Google Analytics

    For the purpose of the needs-based design and continuous optimization of systain.com, we also use Google Analytics on the basis of consent. The basic version of Google Analytics is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ( ” Google ” ). Google Analytics uses, among other things, so-called “ cookies ” (text files) and similar technologies that are stored on your end device and enable an analysis of your use of the website . This information is used to evaluate your use of the website and to compile reports on website and app activities. The processing of the data after it has been transmitted by Systain to Google Ireland Limited is carried out by Google as the sole data protection officer. In this context, Google Ireland Limited, as the sole controller under data protection law, can store data about you in the USA. With regard to the USA, the European Court of Justice has determined that this is a country with an insufficient level of data protection. In this context, there is a particular risk that your data will be processed by American institutions/ authorities for control and monitoring purposes without you being able to adequately remedy this. The legal basis for this data processing is Article 6 Paragraph 1 Letter a) GDPR .

    You can revoke your consent to data processing by Google Analytics at any time here in our consent management system by deselecting the ” Performance ” category or by rejecting your consent to the use of Google Analytics.

    3.4.2.2 Web Analysis with Zoho PageSense

    Zoho PageSense is used to track visitor behavior on a website, including for A/B tests that allow analysis of website usage. Furthermore, it serves to optimize the website experience through the use of surveys.

    PageSense does not collect the personal data of every website visitor who takes part in a test. The cookie data used to assign tests is not assigned to an IP address. The information generated by the cookie about your use of our website includes:

    browser type/version,

    Duration of website visit,

    Date and time of website visit,

    Recording of the website visit,

    Identity API details ,

    Number of poll appearances and response status,

    pages visited,

    Dwell times in the respective places on the website

    Zoho PageSense will use this information to evaluate your use of our website, to compile reports on website activity and to provide us with other services related to website activity and internet usage . You can prevent the storage of cookies by setting 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.

    Regarding the trial period, PageSense retains all reports for 90 days after the end of the trial period. On the 91st day, all recorded data will be deleted .

    The legal basis for this data processing is Article 6 Paragraph 1 Letter a) GDPR .

    Zoho PageSense at any time here in our consent management system by deselecting the ” Performance ” category or by rejecting your consent to the use of Zoho PageSense.

    3.4.3 Consent for Marketing

    3.4.3.1 Consent for Google Remarketing

    This website uses the Google Remarketing service. Google Remarketing is an online advertising program of Google Ireland Limited 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ( ” Google ” ). We use the remarketing -Function within the Google AdWords service. With the remarketing function , we can present you with advertisements based on your interests on other websites within the Google advertising network . For this purpose, your surfing behavior on our website is analyzed, e.g. which offers you have viewed. This enables us to show you individualized advertising on the online search engine Google itself, so-called “ Google ads” and on other websites , even after you have visited our website . For this purpose , Google stores a cookie in your browser when you visit Google services or websites in the Google advertising network . Your visits are recorded via this cookie. The cookie is used to uniquely identify your web browser and not to identify you personally. It is possible for Google to use the data about your usage behavior collected via this website for its own purposes or for the purposes of other Google customers (e.g. to display individualized advertising from third parties). Such further processing of the data as well as the processing of the data after it has been transmitted by us to Google is carried out by Google as the sole data protection officer. In this context, Google, as the sole controller under data protection law, can store data about you in the USA. With regard to the USA, the European Court of Justice has determined that this is a country with an insufficient level of data protection. In this context, there is a particular risk that your data will be processed by American institutions/ authorities for control and monitoring purposes without you being able to adequately remedy this. The legal basis for this data processing is Article 6 Paragraph 1 Letter a) GDPR (consent).

    You can revoke your consent to data processing by Google Remarketing at any time here in our consent management system by deselecting the “Marketing ” category or by rejecting your consent to the use of Google Analytics.

    4. Contact

    You have the option of contacting us in several ways. By e-mail, by phone, by contact form or by post. If you contact us, we use the personal data that you voluntarily provide to us in this context solely for the purpose of being able to contact you and process your request .

    The legal basis for this data processing is Article 6 Paragraph 1 Letter a), Article 6 Paragraph 1 Letter b), Article 6 Paragraph 1 Letter c) GDPR and Article 6 Paragraph 1 Letter f) GDPR.

    5. Categories of recipients < /strong>


    5.1 Processor

    We use contract processors to process your data. A processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the data controller . Contract processors do not use the data for their own purposes, but carry out the data processing exclusively for the person responsible.

    5.2 Other Third Party Partners

    We also use other third-party partners who are required to provide services and achieve various purposes. We transmit personal data to these third – party partners if this is necessary for the provision of services.

    The legal basis for this data transfer is Article 6 Paragraph 1 Letter b), f ) GDPR .

    6. Sending emails

    6.1 Newsletter

    On our website we offer you the opportunity to register for our e – mail newsletter. A newsletter will only be sent if you have consented to receiving it by providing your e-mail address.

    In order to be sure that no errors were made when entering the e -mail address, we use the so-called double opt-in procedure (DOI procedure):

    After you have entered your e-mail address in the registration field and given your consent to receive the newsletter, we will send you a confirmation link to the e-mail address provided. Only when you click on this confirmation link will your e-mail address be added to our mailing list for sending the newsletter.

    The legal basis for this data processing is Article 6 Paragraph 1 Letter a) GDPR .

    Note on the right of withdrawal

    You can revoke your consent at any time with effect for the future by sending a message to datenschutz@systain.com or by using the unsubscribe option at the end of each newsletter.

    6.2 Sending emails

    If you have a contractual relationship with us, we will inform you at irregular intervals on the basis of presumed consent about relevant content or offers that are directly related to the existing contractual relationship or to which we have been associated in the past were already in contact. The legal basis for this data processing is Art. 6 Para. 1 Letter f) GDPR .

    will receive recommendations and information from us by e-mail at irregular intervals . The advertised services are similar to those services that we have been in contact with in the past. The legal basis for this data processing is Art. 6 Para. 1 Letter f) GDPR .

    Note on the right to object

    You can object to the use of your personal data for the aforementioned purposes at any time by sending an email to datenschutz@systain.com < / a> or via the unsubscribe option at the end of each email.

    If you object, your data will be blocked for further advertising data processing. We would like to point out that in exceptional cases, even after receipt of your objection, advertising material may still be sent temporarily. This is technically due to the necessary lead time in the context of the selection and does not mean that we have not implemented your objection.

    7. Participation in events and web seminars

    You can register for events and web seminars on this website in order to take part in them. If you want to take part in an event or web seminar , the information required for this will be collected from the people taking part. These concern your first name, last name, company name and contact details (e.g. e-mail address). If you also provide further personal data, we process the personal data that you provide here voluntarily, exclusively in the context of holding the event or sending additional information material. By registering for our web seminars , you agree that the personal data you provide will be forwarded to Systain Consulting GmbH, which may contact you with further information on web seminars, studies, events and offers from Systain Consulting . The data will not be passed on to third parties and consent can be withdrawn at any time. We reserve the right not to confirm registrations – for example, our web seminars are not accessible to consultants .

    The legal basis for this data processing is Article 6 Paragraph 1 Letter b), f) GDPR .

    8. Data protection notice for applicants

    You can apply for open positions on our careers page . Below we would like to provide you with information on the processing of your personal data in connection with an application.

    8.1. Data processing to carry out the application process

    If you apply to us via our careers page for an open position, we will process the following data from you in order to carry out the application process and possible employment with us: Salutation, first name, last name , E-mail address, address, date of birth, telephone number, application documents (CV, cover letter) and any other optional information.

    We process the data that you have sent us in connection with your application in order to assess your suitability for the position (or any other open positions in our company – if your consent is required according to the legal basis, we will obtain them beforehand) and to carry out the application process . If further data is processed as part of the ongoing application process, we will inform you about this separately.

    The legal basis for the processing of your personal data in this application process is primarily § 26 BDSG. After that, the processing of the data required in connection with the decision on the establishment of an employment relationship is permitted .

    Should the data be required for legal prosecution after the application process has been completed, data processing can take place on the basis of the requirements of Article 6 GDPR, in particular to safeguard legitimate interests in accordance with Article 6 paragraph 1 letter f) GDPR. Our interest then lies in the assertion or defense of claims.

    8.2 Duration of storage

    > Applicant data: In principle, your application data is stored for a period of 6 months. In the event of a rejection, these will then be made anonymous. In the event that you have agreed to further storage of your personal data, we will transfer your data to our talent management system . The data will be deleted there after two years . For more information on the Talent Management System, see point 9 of this data protection information.

    Employee data: If you have received an offer for a position as part of the application process , the data from the application data system will be transferred to our personnel master data system . In principle, the data is then stored for the duration of the employment relationship , unless longer retention periods are provided for by law.

    8.3 Recipients of applicant data

    Your applicant data will be viewed by the HR department after your application has been received. Suitable applications are then forwarded internally to the department heads for the open position. If consent is required by law and we have this, the application documents may also be forwarded to other responsible persons from other departments. In principle, only those people in the company who need your data for the proper course of our application process have access to it. This also includes the members of the employee representatives. In the course of system care and maintenance, the persons entrusted with this may gain knowledge of your data. The relevant persons or service providers, if any, are committed to data secrecy.

    9. Recipients outside the EU

    With the exception of the processing for which we explain the possibility of transferring data to recipients based outside the EU in this information on data protection , we do not pass on your data to recipients based outside of the European Union or the European Economic Area. The data is transmitted on the basis of so-called Standard Contractual Clauses of the EU Commission.

    10. Duration of storage of the data

    The duration of storage of the data collected about you depends on the purpose for which we process the data . The storage takes place as long as this is necessary for the achievement of the intended purpose. Insofar as we have to store certain categories of data for a certain period of time due to legal obligations (e.g. tax obligations), the storage of the data continues after it is no longer necessary to achieve the respective purpose, exclusively for Purpose of fulfilling the legal obligation. In this case the data will be blocked for access.

    Example of storage periods

    • Use of data for marketing purposes (without tracking): 3 years.
    • Consents: Permanent storage as long as the consents are used continuously (e.g. permanent sending of e-mail newsletters).
    • Tracking data: 2 years.
    • Data for the purpose of implementing (advertising) objections: Unlimited storage.

    11. Your Rights

    You have rights as a data subject in connection with the processing of personal data by us. For example, you have the right to request information regarding the data we have stored about you. You can also revoke consent given to us and object to individual data processing. You also have the right to have inaccurate data corrected and you can request that we transmit certain data to you in a commonly used electronic format . You also have the right to have the data we have stored about you deleted . In this regard, please note that we may be obliged for legal reasons to continue to store the data despite the assertion of your right to erasure . In addition, we have an interest in the continuation of the storage of your data in individual constellations, which outweighs your interest in their deletion ( e.g. if we still have outstanding claims against you ) .

    11.1. Your rights in detail

    In addition to the right to revoke the consent you have given us , you have the following additional rights if the relevant legal requirements are met:

    • the right to information about your personal data stored by us ( Article 15 GDPR ) < /strong>, in particular you can obtain information about the processing purposes, the category of personal data, the categories from recipients to whom your data was or will be disclosed, the planned storage period, the origin of their data, if they were not collected directly from you;

    • the right to have incorrect data corrected or correct data completed (Article 16 GDPR );

    • the right to erasure of your data stored by us (Article 17 GDPR), provided that we do not have to comply with any statutory or contractual retention periods or other statutory obligations or rights for further storage ( e.g , if we have outstanding claims against you ) ;

    • the right to restriction of the processing of your data (Article 18 GDPR ), if you dispute the accuracy of the data, the processing is unlawful, but you request its deletion decline; the person responsible no longer needs the data , but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Article 21 GDPR;< / p >

    • the right to data portability (Article 20 GDPR ) < /strong>, i.e. the right to have selected data that we have stored about you transmitted in a common , machine- readable format , or to request the transfer to another person responsible;

    • the right to lodge a complaint with a supervisory authority . As a rule , you can contact the supervisory authority at your usual place of residence or work or at our company headquarters.

    You can assert the aforementioned rights to which you are entitled vis-à-vis us at datenschutz@systain.com . You can also assert your right to data portability at datenschutz@systain.com .

    Status: August 2022