Privacy
Introduction
Below, we provide information about the processing of personal data when using
our website www.sitebrunch.com
and our social media profiles.
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
The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is sitebrunch GmbH, Eifflerstraße 43, 22769 Hamburg, Germany, email: andreas.siegel@sitebrunch.com. We are legally represented by Andreas Siegel, Johannes Zimmer, Lukas Schardt, and Götz Teege.
Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany, www.heydata.eu, email: datenschutz@heydata.eu.
1.2. Scope of data processing, processing purposes, and legal bases
The scope of data processing, processing purposes, and legal bases are explained in detail below. The following are generally considered to be the legal basis for data processing:
Art. 6 (1) (a) GDPR serves as the legal basis for processing operations for which we obtain consent.
Art. 6 (1) (b) GDPR is the legal basis if the processing of personal data is necessary for the performance of a contract, e.g. if a website visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, such as inquiries about our products or services.
Art. 6 (1) (c) GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.
Art. 6 (1) (f) GDPR serves as the legal basis if we can invoke legitimate interests for the processing of personal data, e.g., for cookies that are necessary 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 by the EU Commission pursuant to Art. 45 (3) GDPR guarantee the security of the data during transfer, insofar as these 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 by the EU Commission if the service provider has additionally certified itself under the EU-US Data Privacy Framework.
In other cases (e.g., if no adequacy decision exists), the legal basis for data transfer is usually standard contractual clauses, unless we indicate otherwise. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. Pursuant to Art. 46(2)(b) GDPR, they ensure the security of data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These include, for example, guarantees regarding the encryption of data or regarding the obligation of the third party to notify data subjects if law enforcement agencies want to access data.
1.4. Storage duration
Unless expressly stated 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 there are no legal retention obligations preventing deletion. If the data is not deleted because it is required for other and 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 are required to retain for commercial or tax reasons.
1.5. Rights of data subjects
Data subjects have the following rights vis-à-vis us with regard to their personal data:
Right to information,
Right to correction or deletion,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Right to withdraw consent 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 for data protection supervisory authorities are available 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 are only required to provide us with personal data within the scope of a business relationship or other relationship that is necessary for the establishment, execution, and termination of the business relationship or other relationship, or that we are legally obligated to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service, or we will 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
We do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. If we use these procedures in individual cases, we will provide separate information about this, provided that this is required by law.
1.8. Contacting us
When you contact us, e.g. by email or telephone, we store the data you provide (e.g. names and email addresses) in order to answer your questions. The legal basis for processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in responding to inquiries addressed to us. We delete the data collected in this context after storage is no longer necessary, or restrict processing if there are legal retention obligations.
1.9. Customer surveys
From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is in our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 (1) (f) GDPR. We delete the data once the results of the surveys have been evaluated.
Newsletter
We reserve the right to inform customers who have already used our services or purchased goods from us about our offers from time to time by email or other means, unless they have objected to this. The legal basis for this data processing is Art. 6 (1) (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 emailing our email address above.
Interested parties have the option of subscribing to a free newsletter. We process the data provided during registration exclusively for the purpose of sending the newsletter. Registration takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document, or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking on the corresponding link in the newsletter or by sending a message to our email address given above. The processing of the data until revocation remains lawful even in the event of revocation.
Based on the consent of the recipients (Art. 6 (1) (a) GDPR), we also measure the open and click rates of our newsletters to understand which content is relevant to our recipients.
We send newsletters using the HubSpot tool from HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/de/privacy-policy). The provider processes content, usage, meta/communication data, and contact data in the EU.
Data processing on our website
3.1. Note for website visitors from Germany
Our website stores information on the end device of website visitors (e.g., cookies) or accesses information that is already stored on the end device (e.g., IP addresses). The following sections provide details on what information this is.
This storage and access is based on the following provisions:
Insofar as this storage or access is absolutely necessary in order for us to provide the service expressly requested by website visitors on our website (e.g., to operate a chatbot used by website visitors or to ensure the IT security of our website), it is based on Section 25 (2) No. 2 TDDDG.
Otherwise, this storage or access is based on the consent of the website visitors (Section 25 (1) TDDDG).
Subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.
3.2. Informational use of the website
When the website is used for informational purposes, i.e. when visitors to the site do not send us any information separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is in our legitimate interest, so the legal basis is Art. 6 (1) (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.
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 Hetzner. The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication data, or contact data, within the EU. Further information can be found in the provider's privacy policy at https://www.hetzner.com/de/rechtliches/datenschutz.
It is in our legitimate interest to provide a website, so the legal basis for the data processing described is Art. 6 (1) (f) GDPR.
We use the Bunny CDN content delivery network for our website. The provider is BunnyWay d.o.o., Cesta komandanta Staneta 4A 1215, Medvode, Slovenia. The provider processes the personal data transmitted via the website, e.g., content, usage, meta/communication, or contact data, in the USA. Further information can be found in the provider's privacy policy at https://bunny.net/privacy.
We have a legitimate interest in using sufficient storage and delivery capacities to ensure optimal data throughput even during peak loads. The legal basis for the data processing described is therefore Art. 6 (1) (f) GDPR.
The legal basis for transfers to countries outside the EEA is 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 (Article 46(2)(c) GDPR) issued in accordance with the examination procedure under Article 93(2) GDPR, which we have agreed with the provider.
3.4. Job advertisements
We publish job vacancies in our company on our website, on pages linked to the website, or on third-party websites.
The data provided in the application is processed for the purpose of carrying out the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) GDPR in conjunction with § 26 (1) BDSG. We have marked the data required to carry out the application process accordingly or point it out. 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 for this is their consent (Art. 6 (1) (a) GDPR).
We ask applicants to refrain from providing information on political opinions, religious beliefs, and similar sensitive data in their CVs and cover letters. This information is 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 consent of the applicants (Art. 9 (2) (a) GDPR).
Lastly, 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 (1) (a) GDPR.
We pass on the applicants' data to the relevant employees in the human resources department, to our processors in the area of recruiting, and to other employees involved in the application process.
If we enter into an employment relationship with the applicant following the application process, we only delete the data after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.
If applicants have given us their consent to use their data for further application procedures, we only delete their data one year after receiving the application.
3.5. Customer account
Visitors to the website can open a customer account on our website. We process the data requested in this context on the basis of the consent of the website visitor. The legal basis for processing is therefore Art. 6 (1) (a) GDPR.
Consent can be revoked at any time, e.g. via the contact details provided in our privacy policy. Revocation does not affect the lawfulness of processing prior to revocation. If consent is revoked, we will delete the data unless we are obliged or entitled to continue storing it.
3.6. Technically necessary cookies
Our website uses cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the website more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter “technically necessary cookies”), the legal basis for the associated data processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we use technically necessary cookies for the following purpose or purposes:
Cookies that store log-in data
3.7. Third-party providers
3.7.1. heyData
We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g., IP addresses) in the EU.
The legal basis for processing is Art. 6 (1) (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 to confirmation.
The data is masked after collection so that it is no longer personally identifiable. Further information is available in the provider's privacy policy at https://heydata.eu/datenschutzerklaerung.
Data processing on social media platforms
We are represented on social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles based on their online behavior, which are used, for example, to display advertising on the network pages and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information about user behavior in cookies on the users' computers. It cannot be ruled out that the operators may combine 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 is also possible that the operators or their servers are located in non-EU countries, meaning that they process data there. This may pose risks for users, e.g. because it makes it more difficult to enforce their rights or because government agencies may access the data.
When users of the networks contact us via our profiles, we process the data provided to us in order to respond to their inquiries. This is in our legitimate interest, so the legal basis is Art. 6 (1) (f) GDPR.
4.1. LinkedIn
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. You can object to data processing via the ad settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Changes to this privacy policy
We reserve the right to change this privacy policy with future effect. The latest version is available here.
Questions and comments
If you have any questions or comments regarding this privacy policy, please contact us using the contact details provided above.