Contents

1. Introduction and Overview
 What is Covered
 What is Not Covered

2. Data recording on this website
 Who is the responsible party for recording data (i.e. the “controller”)?
 How do we record your data?
 Analysis tools and tools provided by third parties
 What Personal Data is Collected?
 Devices, Data and Cookies
 Purposes for Processing Personal Data
 Sharing Personal Data
 Children
 How long do we keep your Personal Data?

3. Your rights relating to your Personal Data
 Your Rights as a resident of the European Economic Area (EEU)
 Your Rights as a California resident
 Additional California Privacy Rights

4. General information and mandatory information
 Data protection
 Information about the responsible party (the “controller” in the GDPR)
 Designation of a data protection officer as mandated by law
 International transfer of Personal Data
 Revocation of your consent to the processing of data
 Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
 Right to log a complaint with the competent supervisory agency
 Right to data portability
 SSL and/or TLS encryption
 Information about, rectification and eradication of data
 Right to demand processing restrictions
 Rejection of unsolicited e-mails

5. Recording of data on this website
 Cookies
 Server log files
 Contact form
 Request by e-mail, telephone or fax

6. Social media
 Facebook plug-ins (Like & Share button)
 Twitter plug-in
 Instagram plug-in
 LinkedIn plug-in
 XING plug-in

7. Analysis tools and advertising
 Google Analytics
 IP anonymization
 Browser plug-in
 Contract data processing (Google)
 Archiving period
 Hotjar
 Deactivation of Hotjar
 Contract data processing (Hotjar)
 Google Ads
 Google Remarketing
 Google Conversion-Tracking

8. Newsletter
 Newsletter data

9. Plug-ins and Tools
 YouTube with expanded data protection integration
 Google Web Fonts (local embedding)

10. Custom Services
 Job Applications
 Scope and purpose of the collection of data
 Data Archiving Period
 Admission to the applicant pool

11. Contact Us

12. Distribution

13. Policy History

1. Introduction and Overview

This Privacy Policy describes how DiCentral collects, uses, shares and processes personal and private information relating to individuals ("Personal Data"). The term “personal data” comprises all data that can be used to personally identify you. The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit the websites dicentral.com and smartturn.com. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included below.

What is Covered

DiCentral is the controller of your Personal Data as described in this Privacy Policy. This Privacy Policy applies to the processing of Personal Data collected by us when you:

  • • visit or use our websites that display or link to this Privacy Policy;
  • • visit our branded social media pages;
  • • receive electronic communications from us; or
  • • register for, attend and/or otherwise take part in our events, webinars or contests.

What is Not Covered

This Privacy Policy does not apply to Personal Data that DiCentral receives, sends, or manipulates in its role as service provider on behalf of our customers. DiCentral stores and processes information on behalf of its customers such as when it sends or receives EDI data or provides analytics on behalf of customers. DiCentral is not responsible for the privacy or data security practices of our customers or their trading partners.

When applications are provided by third parties, the Privacy Policy of the third party applies, and this Privacy Policy does not apply. DiCentral websites and services may use applications and services maintained by third parties that are governed by third parties’ Privacy Policies.

2. Data recording on this website

Who is the responsible party for recording data (i.e. the “controller”)?

The data on this website is processed by the operator of the website, DiCentral, whose contact information is available under section “Information Required by Law” on this website.

How do we record your data?

We collect your data as a result of your sharing of your data with us. For instance this may be information you enter into the contact form on our website.

Other data is recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed).

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when you visit this website. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs please consult our Data Protection Declaration below.

What Personal Data is Collected?

DiCentral may collect the following Personal Data. Although we have tried to provide a comprehensive list, this list is not exhaustive. Other Personal Data may be collected that is not on this list:

  • • if you attend an event, we may scan your attendee badge, collect business cards, or collect survey information which contains information, such as name, title, company name, address, country, phone number and email address that we obtain from information you submit on a website controlled or contracted by DiCentral, providing us your business card, or filling out surveys;
  • • if you use and interact with our websites or emails, we automatically collect information about you and your device through cookies, Internet Protocol (IP) addresses or other means;
  • • we also collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you.

Devices, Data and Cookies

DiCentral uses common information-gathering tools, such cookies, web beacons, and similar technologies to automatically collect information that may contain Personal Data. DiCentral gathers information about users automatically on its websites and applications. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage. This information is used to protect our platform against malicious actors and to improve our systems and services. Some of the device and usage data collected within the services, whether alone or in conjunction with other data, could be personally identifying to you.

We use cookies, Internet Protocol (IP) addresses or other data collection services. When you visit our websites, we or an authorized third party may place a cookie on your browser, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage to improve our services or better suit our marketing to you.

DiCentral uses both session-based and persistent cookies on our websites. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our websites. DiCentral or third parties may also place or recognize unique cookies for the purpose of serving you targeted advertising.

Purposes for Processing Personal Data

We collect and process your Personal Data for the following purposes:

  • • Providing services: We process your Personal Data to perform our contract with you for the use of our websites and services and to fulfill our obligations under applicable terms of use/service or contracts. Where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with the content you access and request;
  • • Promoting the security of our websites and services:
  • • Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
  • • Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
  • • Marketing and Sales. We process Personal Data to advertise and market to you. DiCentral treats Person Information obtained solely for marketing purposes differently than Personal Data about you as a customer of DiCentral. You may remove Personal Data stored and processed solely for marketing services by following the instructions described further in this document.
  • • Complying with legal obligations: We process your Personal Data to comply with laws. Sometimes, laws require that we disclose Personal Data to government authorities.

Sharing Personal Data

We may share your Personal Data with other companies if they need it to provide services on our behalf. We only share what is needed for the service, we never sell personal data, and we remain strictly responsible for how your personal data is used.

We may share your Personal Data with our contracted service providers who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, and customer support for the purposes described above.

We may share Personal Data in individual instances, with professional advisers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obligated to share or have a legitimate interest in sharing your Personal Data.

We may share Personal Data with affiliates within DiCentral and companies that we acquire in the future when they are made part of the DiCentral, to the extent such sharing of data is necessary to fulfill a purpose previously described.

We may also share anonymous usage data with DiCentral’s service providers for the purpose of helping DiCentral in such analysis and improvements. Additionally, DiCentral may share such anonymous usage data on an aggregate basis in the normal course of operating our business.

Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal Data from our systems.

How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the "Purposes for Processing Personal Data” above). We use reasonable business judgment to determine the length of such time.

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

3. Your rights relating to your Personal Data

We recognize you to have the following rights with respect to your Personal Data, wherever you reside in the world.

  • Right to access. You can see what data we have collected whenever you want.
  • Right to take your data. Your personal data is yours. You can copy and take it whenever you want.
  • Right to erasure.We'll erase your personal data whenever you ask.
  • Right to object or restrict use.If you want us to stop using your data, we'll stop.
  • Right to non-discrimination.You have the right to non-discriminatory treatment for the exercise of your privacy rights.
  • Right to lodge a complaint.We will protect your privacy and we will honor your choices. And if you feel we've failed in any way, you have the right to lodge a complaint with a data protection authority in your region.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues. You may contact us at legal@dicentral.com; you can also mail us at:

Legal Department
1199 NASA Parkway
Houston, TX 77058, USA.

You have certain rights relating to your Personal Data, subject to local data protection laws.

Your Rights as a resident of the European Economic Area (EEU)

If you are located in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) ensures you have the following rights:

  • • To access your Personal Data held by us (right to access);
  • • To rectify inaccurate Personal Data and, considering the purpose of processing the Personal Data, ensure it is complete (right to rectification);
  • • To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
  • • To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
  • • To transfer your Personal Data to another controller, to the extent possible (right to data portability);
  • • To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  • • Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services; and
  • • To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

Your Rights as a California resident

The California Consumer Privacy Act (CCPA) gives you specific rights as a California resident.

  • Your right to know. We describe the personal information we collect and how we use it in this privacy policy. The information we collect varies depending on your interactions with us and the products and services you use. The California law requires us to let you know the categories of personal information we collect and use.
  • We collect personal information when you interact with us and use our products and services, from certain third-party sources and from our network and the devices you use. We use this information for business and commercial purposes as they are defined by the CCPA. Service providers we use to do work on our behalf (also called vendors in other sections of this privacy policy) may use information for the same purposes. We may also share information for legal compliance, for credit and collections purposes, with your consent and as further described in other sections of this policy.
  • Your right to access. You have the right to request access to specific pieces and categories of personal information we collected about you in the past twelve months. You can do this by accessing our Privacy Dashboard or calling 1.800.333.3972.
  • Your right to delete. You have the right to request that we delete personal information we have about you unless we need it for specific reasons described by the CCPA. You can do this by contacting us at legal@dicentral.com; you can also mail us at: Legal Department; 1199 NASA Parkway, Houston, TX 77058, USA.
  • Your right to say “Do not sell my personal information.”The CCPA gives you the right to say no to the sale of personal information.
  • We do not sell information that personally identifies you such as your name, telephone number, mailing address or email address.
  • We allow third-party advertising companies to collect information about your activity on our websites and in our apps, for example through cookies and similar technologies, mobile ad identifiers, pixels, web beacons and social network plugins. These ad entities use information they collect to help us provide more relevant advertisements and other advertising purposes. This activity may be considered a sale under the CCPA. Visit Digital Advertising Alliance Consumer Choice to learn more about how you can limit this type of advertising.
  • Your right to not be discriminated against. We do not discriminate against you if you exercise any rights described in this section.
  • Where to exercise your rights. If you have questions about your rights under CCPA or want to exercise your rights, you or your authorized agent may contact us at legal@dicentral.com ; you can also mail us at: Legal Department; 1199 NASA Parkway, Houston, TX 77058, USA. We require you to verify your identity using the processes described in the dashboard before we fulfill your request.

Additional California Privacy Rights

California customers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.

California residents under age 18 who are registered users of online sites, services or applications may request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

4. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

We take precautions including organizational, technical and physical measures to help safeguard your Personal Data. However, no measures are perfect. You are responsible for protecting your password and taking reasonable precautions to protect your Personal Data.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.

Information about the responsible party (the “controller” in the GDPR)

The data processing controller on this website is

DiCentral GmbH
Fraunhoferstraße 9
85737 Ismaning

Phone: +49 89 45 30 40 – 0
E-mail: info-germany@dicentral.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

Designation of a data protection officer as mandated by law

We have appointed a data protection officer for our company.

Frank Dieffenbach
Frank Dieffenbach Beratung im Gesundheitswesen
Schloßwiese 3
D-67146 Deidesheim

Phone: +49 6326 982005
E-mail: privacy-germany@dicentral.com

International transfer of Personal Data

DiCentral is based in Texas in the U.S. but we have offices all over the world. In most cases we need to securely transfer and store your information in the USA. To meet data protection requirements, we are a member of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, and we are subject to enforcement by the U.S. Federal Trade Commission. This means we adhere to the Privacy Shield Principles of notice, choice, and accountability for onward transfer, security, data integrity, purpose limitation, access, recourse, enforcement, and liability. We are the data controller, and we remain responsible for any of your personal information that is shared with third parties for processing on our behalf.

DiCentral has committed to cooperating with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland. Under certain conditions, you may invoke binding arbitration to resolve any complaint. We are subject to U.S. law, and we may be required to share data with U.S. law enforcement agencies. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website. For more information regarding our Privacy Shield certification, please see https://www.privacyshield.gov/list.

Our website uses, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities.

To reiterate, your Personal Data may be collected, transferred to and stored by us in countries where we operate. Therefore, your Personal Data may be processed outside the European Economic Area (EEA), and in countries which are not subject to an adequacy decision by the European Commission, and which may not provide for the same level of data protection as the EEA. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

  • • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
  • • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • • If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
  • • If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in section “Information Required by Law” to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

5. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

In some cases it is possible that third party cookies are stored on your device once you enter our site (third party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimization of the website (e.g. cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • • The type and version of browser used
  • • The used operating system Referrer URL
  • • The hostname of the accessing computer
  • • The time of the server inquiry
  • • The IP address
  • • This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular, retention periods.

Request by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular, statutory retention periods - remain unaffected.

6. Social media

Facebook plug-ins (Like & Share button)

We have integrated plug-ins of the social network Facebook on this website. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.

You will be able to recognize Facebook plug-ins by the Facebook logo or the “Like” button on this website. An overview of the Facebook plug-ins is available under the following link: https://developers.facebook.com/docs/plugins/.

Whenever you visit this website and its pages, the plug-in will establish a direct connection between your browser and the Facebook server. As a result, Facebook will receive the information that you have visited this website with your plug-in. However, if you click the Facebook “Like” button while you are logged into your Facebook account, you can link the content of this website and its pages with your Facebook profile. As a result, Facebook will be able to allocate the visit to this website and its pages to your Facebook user account. We have to point out that we as the provider of the website do not have any knowledge of the transferred data and its use by Facebook. For more detailed information, please consult the Data Privacy Declaration of Facebook at: https://www.facebook.com/privacy/explanation.

If you do not want Facebook to be able to allocate your visit to this website and its pages to your Facebook user account, please log out of your Facebook account while you are on this website.

The use of the Facebook plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be revoked at any time.

Twitter plug-in

We have integrated functions of the social media platform Twitter into this website. These functions are provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. While you use Twitter and the “Re-Tweet” function, websites you visit are linked to your Twitter account and disclosed to other users. During this process, data are transferred to Twitter as well. We must point out that we the providers of the website and its pages do not know anything about the content of the data transferred and the use of this information by Twitter. For more details, please consult Twitter’s Data Privacy Declaration at: https://twitter.com/en/privacy.

The use of Twitter plug-ins is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be revoked at any time.

You have the option to reset your data protection settings on Twitter under the account settings at https://twitter.com/account/settings.

Instagram plug-in

We have integrated functions of the public media platform Instagram into this website. These functions are being offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.

If you are logged into your Instagram account, you may click the Instagram button to link contents from this website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user account. We have to point out that we as the provider of the website and its pages do not have any knowledge of the content of the data transferred and its use by Instagram.

Data are stored and analyzed on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the highest possible visibility on social media. If a respective declaration of consent has been obtained, the data will be processed exclusively on the basis of Art. 6 Sect. 1 lit. a DGDPR. Any such consent may be revoked at any time.

For more information on this subject, please consult Instagram’s Data Privacy Declaration at: https://instagram.com/about/legal/privacy/.

LinkedIn plug-in

This website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.

Any time you access a page of this website that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.

The use of the LinkedIn plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be revoked at any time.

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

XING plug-in

This website uses functions of the XING network. The provider is the New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.

Any time one of our sites/pages that contains functions of XING is accessed, a connection with XING’s servers is established. As far as we know, this does not result in the archiving of any personal data. In particular, the service does not store any IP addresses or analyze user patterns.

Data are stored and analyzed on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the highest possible visibility on social media. If a respective declaration of consent has been obtained, the data will be processed exclusively on the basis of Art. 6 Sect. 1 lit. a DGDPR. Any such consent may be revoked at any time.

For more information on data protection and the XING share button please consult the Data Protection Declaration of Xing at: https://www.xing.com/app/share?op=data_protection.

7. Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g. cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing (Google)

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en.

Hotjar

This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (website: https://www.hotjar.com).

Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so-called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference.

We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so-called conversion funnels).

Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator.

Hotjar uses technologies that make it possible to recognize the user for the purpose of analyzing the user patterns (e.g. cookies or the deployment of device fingerprinting).

The use of this analysis tool is based on Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

Deactivation of Hotjar

If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link: https://www.hotjar.com/opt-out.

Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device.

For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link: https://www.hotjar.com/privacy.

Contract data processing (Hotjar)

We have entered into a contract data processing agreement with Hotjar to implement the stringent European Data Protection Regulations.

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g. location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

The use of Google Ads is based on Art. 6 Sect. 1 lit. et seq. GDPR. The website operator has a legitimate interest in marketing the operator’s services and products as effectively as possible.

Google Remarketing

This website uses the functions of Google Analytics Remarketing. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Remarketing analyzes your user patterns on our website (e.g. clicks on specific products), to allocate a certain advertising target groups to you and to subsequently display matching online offers to you when you visit other online offers (remarketing or retargeting).

Moreover, it is possible to link the advertising target groups generated with Google Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g. cell phone) in a manner tailored to you as well as on any of your devices (e.g. tablet or PC).

If you have a Google account, you have the option to object to personalized advertising under the following link: https://www.google.com/settings/ads/onweb/.

The use of Google Remarketing is based on Art. 6 1 lit. et seq. GDPR. The website operator has a legitimate interest in the marketing of the operator’s products that is as effective as possible. If a respective declaration of consent was requested, processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given consent may be revoked at any time.

For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.

Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Conversion Tracking on the basis of Art. 6 Sect. 1 lit. et seq. GDPR. The operator of the website has a legitimate interest in the analysis of the user patterns with the aim of optimizing both, the operator’s web presentation and advertising. If a respective declaration of consent was requested (e.g. concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given consent may be revoked at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en.

8. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

9. Plug-ins and Tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video.

Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Web Fonts (local embedding)

This website uses so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.

For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en .

10. Custom Services

Job Applications

We offer website visitors the opportunity to submit job applications to us (e.g. via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g. contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 New GDPR according to German Law (Negotiation of an Employment Relationship), Art. 6 Sect. 1 lit. b GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6 Sect. 1 lit. a GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 New GDPR and Art. 6 Sect. 1 lit. b GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application).

Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6 (1) (a) GDPR) or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6 para. 1 lit. a GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

11. Contact Us

If you have any questions, or if you are an Authorized Agent seeking to make a request on behalf of a consumer under California’s Consumer Privacy Act, please send an email to our Data Privacy Officer at legal@dicentral.com.

You can also write to us at:

ATTN: Data Privacy Officer
Legal Department
1199 NASA Parkway
Houston, TX 77058, USA

Updates to this policy will be posted at dicentral.com.

12. Distribution

This policy is to be displayed at least once (as determined by tracking cookie) to each visitor to the DiCentral website.

13. Policy History

Version Date Description Approved By
1.0 1/25/2019 Initial policy release Security Policy team
1.1 4/15/2020 Review Security Policy team
1.2 4/28/2021 Restated key ideas to highlight
compliance with General Data
Protection Regulation (European Union
GDPR) and California Consumer
Privacy Act (CCPA).
Security Policy team

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