Privacy Policy

1. Introduction

In the following, we inform you about the processing of personal data when using the web app “Wagebeam” (hereinafter referred to as "SaaS platform"). Personal data is any data that can be related to a specific natural person, e.g., their name or IP address.

1.1. Contact Details

Controller according to Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is your employer.

Processor and technical developer of the SaaS platform is neosfer GmbH, Eschersheimer LandstraĂźe 6, 60322 Frankfurt am Main, Germany, E-Mail: datenschutz@neosfer.com. They are legally represented by Matthias Lais; Kai Werner..

Your data protection officer can be reached via heyData GmbH, SchĂĽtzenstraĂźe 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

This privacy policy is intended to provide data subjects with a non-legally binding overview of the processing of their personal data within the scope of the SaaS platform. For further legal information on data processing, please contact the controller.

1.2. Scope of Data Processing, Processing Purposes, and Legal Bases

The scope of data processing, processing purposes, and legal bases are detailed below. The following legal bases generally apply to data processing:
  • Art. 6 para. 1 sent. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 sent. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g., when a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing required for pre-contractual measures, such as inquiries about our products or services.
  • Art. 6 para. 1 sent. 1 lit. c GDPR applies when we process personal data to comply with a legal obligation, as may be the case, for example, in tax law.
  • Art. 6 para. 1 sent. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests for processing personal data, e.g., for cookies required for the technical operation of our website.

1.3. Data Processing Outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 para. 3 GDPR guarantee the security of the data upon transfer, provided they exist, as is the case, for example, for the United Kingdom, Canada, and Israel.

When transferring data to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has additionally certified under the EU-US Data Privacy Framework.

In other cases (e.g., if no adequacy decision exists), the legal basis for data transfer is generally, unless we provide a deviating notice, Standard Contractual Clauses. These are a set of rules adopted by the EU Commission and part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many providers have made contractual guarantees beyond the Standard Contractual Clauses that protect the data beyond the Standard Contractual Clauses. These include, for example, guarantees regarding data encryption or an obligation of the third party to notify data subjects if law enforcement agencies want to access data.

1.4 Storage Duration

Unless expressly stated otherwise in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted, i.e., the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax reasons.

1.5. Rights of the Data Subjects

Data subjects have the following rights regarding their personal data concerning us:
  • Right to information,
  • Right to rectification or deletion,
  • Right to restriction of processing,
  • Right to object to processing,
  • Right to data portability,
  • Right to withdraw consent given at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities can be found at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to Provide Data

Customers, interested parties, or third parties only need to provide us with the personal data necessary for the establishment, execution, and termination of the business relationship or other relationship, or which we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service, or we may no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7. No Automated Decision-Making in Individual Cases

For the establishment and execution of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 GDPR. Should we use these procedures in individual cases, we will inform you separately, provided this is legally required.

1.8. Contacting Us

When contacting us, e.g., via email or telephone, the data provided to us (e.g., names and email addresses) are stored by us to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 sent. 1 lit. f GDPR) in responding to inquiries directed to us. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

1.9. Customer Surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. We collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so the legal basis for the associated data processing is Art. 6 para. 1 sent. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used our services or purchased goods from us from time to time via email or other means about our offers, provided they have not objected. The legal basis for this data processing is Art. 6 para. 1 sent. 1 lit. f GDPR. Our legitimate interest lies in direct marketing (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time without additional costs, for example via the link at the end of each email or by email to our email address mentioned above.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Registration takes place by selecting the corresponding field on our website, by ticking the corresponding box in a paper document, or by another unambiguous act by which interested parties declare their consent to the processing of their data, so the legal basis is Art. 6 para. 1 sent. 1 lit. a GDPR. Consent can be revoked at any time, e.g., by clicking the corresponding link in the newsletter or by notifying our email address mentioned above. The processing of data up to the point of revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 sent. 1 lit. a GDPR), we also measure the opening and click rates of our newsletters to understand which content is relevant to our recipients.

We send newsletters using the Brevo tool from the provider Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin. The provider processes content, usage, meta/communication data, and contact data in the EU. Further information can be found in the provider's privacy policy at https://de.sendinblue.com/legal/privacypolicy/.

3. Data Processing on Our Website

3.1. Note for Website Visitors from Germany

Our website stores information in the end device of website visitors (e.g., cookies) or accesses information already stored in the end device (e.g., IP addresses). The specific information involved can be found in the following sections.

This storage and access are based on the following provisions:
  • Insofar as this storage or access is strictly necessary for us to provide the service of our website expressly requested by website visitors (e.g., to operate a chatbot used by the website visitor or to ensure the IT security of our website), it is based on § 25 para. 2 no. 2 of the Telecommunications Telemedia Data Protection Act (TDDDG).
  • Otherwise, this storage or access is based on the consent of the website visitors (§ 25 para. 1 TDDDG).
The subsequent data processing is carried out in accordance with the following sections and based on the provisions of the GDPR.

3.2. Informational Use of the Website

When using the website for informational purposes only, i.e., if site visitors do not transmit information to us separately, we collect the personal data that the browser transmits to our server to ensure the stability and security of our website. This constitutes our legitimate interest, so the legal basis is Art. 6 para. 1 sent. 1 lit. f GDPR.

This data includes:
  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request originates
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.e
This data is also stored in log files. It is deleted when its storage is no longer necessary, at the latest after 14 days.

3.3. Web Hosting and Provision of the Website

Our website is hosted by Google Cloud. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data, in the EU. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

It is our legitimate interest to provide a website, so the legal basis for the described data processing is Art. 6 para. 1 sent. 1 lit. f GDPR.

3.4. Contact Form

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in responding to inquiries directed to us. Therefore, the legal basis for the processing is Art. 6 para. 1 sent. 1 lit. f GDPR. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

3.5. Job Advertisements

We publish job advertisements on our website, on pages linked to the website, or on third-party websites. The processing of data provided in the context of the application is carried out for the purpose of conducting the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG. We have marked the data required for conducting the application process accordingly or refer to it. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 sent. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs, and similarly sensitive data in their resumes and cover letters. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent its processing in the context of processing the resume or cover letter. Its processing is then also based on the applicants' consent (Art. 9 para. 2 lit. a GDPR).

Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sent. 1 lit. a GDPR.

We pass on applicants' data to the responsible employees of the personnel department, to our processors in the recruiting area, and to the other employees involved in the application process.

If we establish an employment relationship with the applicant following the application process, we delete the data only after the termination of the employment relationship. Otherwise, we delete the data at the latest six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we delete their data one year after receiving the application.

3.6. Payment Service Providers

We use payment processors to handle payments, who are themselves controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data entered by us in the order process and payment data, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 sent. 1 lit. b GDPR).

These payment service providers are:
  • PayPal (Europe) S.Ă  r.l. et Cie, S.C.A., Luxembourg
  • Stripe Payments Europe, Ltd., Ireland

3.7. Third-Party Providers

3.7.1. Typeform

We use Typeform for questionnaires and forms. The provider is Typeform S.L., C/ Can Rabia 3-5, 4th floor, 08017 – Barcelona, Spain. The provider processes content data (e.g., entries in online forms) and meta/communication data (e.g., device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 sent. 1 lit. a GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g., using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing carried out until the revocation.

The transfer of personal data to a country outside the EEA is based on the legal basis of Standard Contractual Clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted according to the examination procedure under Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed upon with the provider.

The data will be deleted when the purpose of its collection has ceased and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://admin.typeform.com/to/dwk6gt.

3.7.2. Google Analytics

We use Google Analytics for analysis. The provider is Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The provider processes usage data (e.g., visited websites, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 sent. 1 lit. a GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g., using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing carried out until the revocation.

The transfer of personal data to a country outside the EEA is based on the legal basis of an adequacy decision. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed because the EU Commission has decided, within the framework of an adequacy decision pursuant to Art. 45 para. 3 GDPR, that the third country offers an adequate level of protection.

The data will be deleted when the purpose of its collection has ceased and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.3. YouTube Videos

We use YouTube videos for videos on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., visited websites, interest in content, access times) and meta/communication data (e.g., device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 sent. 1 lit. a GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g., using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing carried out until the revocation.

The transfer of personal data to a country outside the EEA is based on the legal basis of consent.

Further information can be found in the provider's privacy policy at https://policies.google.com/privacy.

3.7.4. Google Tag Manager

We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g., visited websites, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 sent. 1 lit. a GDPR. Processing is based on consent. Data subjects can revoke their consent at any time by contacting us, e.g., using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing carried out until the revocation.

The transfer of personal data to a country outside the EEA is based on the legal basis of an adequacy decision. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed because the EU Commission has decided, within the framework of an adequacy decision pursuant to Art. 45 para. 3 GDPR, that the third country offers an adequate level of protection.

We delete the data when the purpose of its collection has ceased. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.5. heyData

We have integrated a data protection seal on our website. The provider is heyData GmbH, SchĂĽtzenstraĂźe 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g., IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 sent. 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data protection compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative for confirmation.

The data is masked after collection so that there is no longer any personal reference. Further information can be found in the provider's privacy policy at https://heydata.eu/datenschutzerklaerung.

4. Data Processing on Social Media Platforms

We are present on social media networks to present our organization and services there. The operators of these networks regularly process user data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to display advertising on the network pages and elsewhere on the internet that corresponds to the users' interests. For this purpose, the network operators store information about usage behavior in cookies on the users' computers. It cannot be ruled out that the operators merge this information with other data. Further information and instructions on how users can object to processing by the site operators can be found in the privacy policies of the respective operators listed below. It may also be that the operators or their servers are located in non-EU countries, so they process data there. This can pose risks for users, e.g., because enforcing their rights is more difficult or government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us to answer the inquiries. This constitutes our legitimate interest, so the legal basis is Art. 6 para. 1 sent. 1 lit. f GDPR.

4.1. YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy can be found here: https://policies.google.com/privacy?hl=de.

4.2. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE. An option to object to data processing is available via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this Privacy Policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. Questions and Comments

For questions or comments regarding this privacy policy, we are available at the contact details provided above.