Privacy Policy

Name and Address of the Data Controller

The data controller within the meaning of the General Data Protection Regulation, other data protection laws in force in the member states of the European Union, and other provisions relating to data protection is:

External Data Protection Officer

Our external data protection officer can be reached at:

E-Mail: datenschutz-engomo@exacon-gmbh.de

Individuals concerned may contact the data controller or our data protection officer directly with any questions regarding data protection and the processing of their personal data.

When does engomo GmbH collect and process personal data?

We collect and process your personal data in the following cases, among others:

If you contact us directly—for example, through the contact forms on our website, by email, or by phone—and you are interested in our products or services, or have any other inquiry.

When you purchase products from us (e.g., software).

If you hire us to provide services (such as app configuration).

If you request information about our products and services (e.g., brochures or price lists).

When you respond to our direct marketing activities (for example, when you fill out a reply card at a trade show or enter a contest).

If you send us your application materials.

What types of personal data may be collected?

When you contact us or use our services, we collect the following categories of personal data, among others:

Contact information: Name, address, phone number, email address.

Other personal data, such as information you provide regarding your date of birth, education, employment status, employer, or account information.

Contract Information: Customer number, contract number, products and services ordered.

Credit and Identity Information: Data used to verify your identity, such as identification documents; as well as information regarding transactions, including any payments that have not been made to us.

Website Use and Communication: Information about how you use our website through cookies and other tracking technologies.

Data Processing in Connection with the Sale of Our Products and the Provision of Services

Nature and Purpose of the Processing

engomo GmbH collects, processes, and uses personal data in connection with the sale of products and the provision of services. The following categories of data are processed in this context:

Personal information: Last name, first name, address, email address, bank account information, etc.

Contract Information: Customer Number, Contract Number

Identification Information

engomo GmbH uses your personal data to communicate with you in connection with contract fulfillment (sale of products, provision of services) or to process a request you have submitted (e.g., a request for a quote). For all aspects of contract fulfillment or the handling of a request, we will contact you—without requiring separate consent—for example, in writing, by phone, via messaging services, or by email, depending on the contact information you have provided.

Legal basis:

Data processing in connection with the sale of our products and the provision of services is based on the performance of a contract or the implementation of precontractual measures (Art. 6(1)(b) of the GDPR).

Recipient:

The recipients of the data may include technical service providers who act as data processors.

Retention period:

We will retain your data only for as long as is necessary for the specific purposes for which we process it. If we process data for multiple purposes, it will be automatically deleted or stored in a format that does not allow direct identification of you as soon as the last specific purpose has been fulfilled.

Use for the Purpose of Fulfilling a Contract: To fulfill contractual obligations, data collected from you may be retained for as long as the contract remains in effect, as well as for an additional 6 or 10 years thereafter, depending on the nature and scope of the contract, in order to comply with statutory retention requirements and to resolve any inquiries or claims after the contract has expired. In addition, there are contracts for the delivery of products and services that require longer retention periods; see also “Use for the Assessment of Claims” below.

Use for the Purpose of Investigating Claims: We may retain data that, in our discretion, is necessary to investigate or defend against claims made against us, or to initiate criminal proceedings or bring claims against you, us, or third parties, for as long as such proceedings could be brought.

Processing of Voluntary Information:

You need only provide the data that is necessary for entering into and performing a contract with us, or that we are legally required to collect. Without this data, we will generally not be able to enter into a contract with you. The provision of optional data is voluntary.

Data Processing in Connection with Online Meetings, Telephone and Video Conferences, and Webinars

Nature and Purpose of the Processing:

engomo GmbH uses video conferencing tools to plan, conduct, or participate in online meetings, video conferences, conference calls, or webinars (hereinafter collectively referred to as “online meetings”). When engomo GmbH acts as the host (organizer) of an online meeting, emails containing invitation links are sent to potential meeting participants. If necessary for the purpose of documenting the results of an online meeting, chat content is recorded during the online meeting. This is typically the case when conducting business meetings. If you are registered as a user with the respective application provider, reports on “online meetings” (meeting metadata, data on phone dial-in, questions and answers in webinars, survey functionality in webinars) may be stored by the respective application provider.

The following categories of data are processed:

User information: First name, last name, phone number (optional), email address, password (if “single sign-on” is not used), profile picture (optional), department (optional); meeting metadata: topic, description (optional), participant IP addresses, device/hardware information; When dialing in by phone: Information on the incoming and outgoing phone numbers, country name, start and end times, and other connection data such as the IP address of the dialing device; Text, audio, and video data: You have the option to use the chat, question, or poll features during an online meeting. The text you enter is processed, displayed in the “online meeting,” and logged. To enable video display and audio playback, data from your device’s microphone and any video camera on your device is processed for the duration of the meeting.

Legal basis:

Data processing in connection with the conduct of business meetings is based on the performance of a contract or the implementation of precontractual measures (Art. 6(1)(b) GDPR). Data processing in connection with the conduct of webinars is based on the performance of a contract or the implementation of pre-contractual measures (Art. 6(1)(b) GDPR). Processing may also be based on a legitimate interest of engomo GmbH (Art. 6(1)(f) GDPR). engomo GmbH has a legitimate interest in holding webinars instead of in-person seminars when required or necessary, should a situation arise that makes this necessary. Both the conduct of business meetings and the conduct of webinars involve data processing that only indirectly serves these purposes. This applies in particular to the processing of data pertaining to employees of engomo GmbH. Data processing may also be based on consent. This is particularly the case if you initiate the use of the online tool or if you voluntarily provide us with data that is not required for the provision of the online service (so-called optional information) (Art. 6(1)(a) GDPR).

Recipient:

We do not disclose data to third parties unless it is specifically intended for disclosure or we are legally obligated to do so. Please note that, as with in-person meetings, content from online meetings is often used to communicate information to customers, prospective clients, or third parties and is therefore intended for disclosure. “Chat histories” may be disclosed to colleagues who are also involved in managing the relevant project. In addition to the technical managers, certain employees at our data center who manage the online service may also have access to the personal data generated in this context. In particular, in the case of support requests, it may be necessary for these colleagues to access your data. For the provision and conduct of online meetings using the “Teams” software solution, the provider “Microsoft Ireland Operations Limited, South County Business Park, One Microsoft Place, Carmanhall and Leopardstown, Dublin, D18 P521, Ireland” may also access data. This provider acts as a data processor on our behalf. Where possible, the data is stored and processed on the provider’s servers within the EU. However, processing in the United States or another country outside the EEA cannot be ruled out. Processing of personal data therefore also takes place in a third country. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR. For further information, please refer to Microsoft’s privacy statement at:

For the provision and conduct of online meetings using the “Zoom” software solution, the provider “Zoom Video Communications, 55 Almaden Blvd, Suite 600, San Jose, California (95113), USA” may also access data. This provider acts as a data processor on our behalf. Where possible, the data is stored and processed on the provider’s servers within the EU. However, processing in the United States or another country outside the EEA cannot be ruled out. Processing of personal data therefore also takes place in a third country. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR. For further information, please refer to the privacy policy of “Zoom Video Communications” at:

The provider “TeamViewer Germany GmbH, Bahnhofsplatz 2, 73033 Göppingen, Germany” may also access data for the purpose of setting up and conducting online meetings using the “TeamViewer” software solution. This provider acts as a data processor on our behalf. The data is stored and processed on the provider’s servers in the EU. For more information, please refer to TeamViewer's privacy statement at:

Retention period:

The data will be deleted as soon as it is no longer necessary for the aforementioned purposes. If your data is processed based on a declaration of consent, or if you have lodged a justified objection to the processing, we will delete your data immediately. A different rule applies if we are required to retain data due to statutory retention obligations. We will delete data that we have collected in connection with project execution—in particular, chat logs—no later than two months after the project ends. If you are registered as a user with the online service we use, reports on “online meetings” (meeting metadata, dial-in data, questions and answers in webinars, and survey data from webinars) may be stored by the tool provider for up to one month.

Processing of Voluntary Information:

When conducting meetings, we regularly collect metadata that is technically necessary for holding online meetings or that we are legally required to collect. To participate in an online meeting or enter the “meeting room,” you must at least provide your name. Providing optional information is voluntary.

Withdrawal of Consent:

If data processing during an online meeting is based on your consent, you may revoke that consent at any time with future effect. You also have the option to object to the processing, for example, by turning off or muting your camera or microphone through the applications.

Schedule an appointment via Calendly

Nature and Purpose of the Processing:

engomo GmbH uses the Calendly tool, provided by Calendly LLC, to facilitate simple, fast, and hassle-free scheduling. We do this to improve our service for customers and suppliers and to increase the efficiency of our employees. When using Calendly, you will be asked to provide personal data such as your name, email address, and phone number. You also have the option to describe your request and provide us with additional information. When you use the tool, the information you enter in the request form—including the details you provide there—will be stored and transmitted over the Internet. For more information, please refer to the privacy policy of Calendly LLC, which is available at:

Legal basis:

The legal basis for processing the data you have entered is your consent (Art. 6(1)(a) of the GDPR).

Recipient:

The recipient of the data is Calendly LLC, with whom we have entered into a data processing agreement. In this context, personal data is processed in the United States (a third country outside the EU). An adequate level of protection is ensured through the use of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR.

Retention period:

These cookies expire after 30 days and are not used to identify individuals.

Processing of Voluntary Information:

The processing of data in connection with Calendly is voluntary. Alternatively, you can also schedule appointments with us through other means (e.g., by phone or email).

Withdrawal of Consent:

You may revoke your consent at any time, effective for the future. If you would like Calendly to delete your data immediately, you can notify us using the contact information provided. We will then delete any stored entries without delay.

Data Processing in Connection with Job Applications and the Application Process

Nature and Purpose of the Processing:

engomo GmbH collects, processes, and uses applicant data for the purpose of handling the application process. Application materials may be submitted to us by mail or electronically (e.g., via email, a web form, or job portals). Authorized employees from the Human Resources department, as well as other employees (involved in the application process) as necessary, have access to your data. Application documents may continue to be stored after the application process has ended to defend against any claims arising from legal requirements (e.g., to meet the burden of proof in proceedings under the General Equal Treatment Act [AGG]). If an application is rejected, there is the option to retain the application documents in a “talent pool” for consideration in future job openings. For detailed information on data processing related to applications and the application process, please refer to our Privacy Policy for Applicants at:

Data Processing When Using Our Website

We are pleased that you are visiting our website and would like to inform you that when you visit our site, data is processed that may be personally identifiable. If a data subject wishes to use specific services via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

SSL Encryption

The engomo GmbH website uses SSL encryption for security reasons and to protect the transmission of confidential information, such as the inquiries you send to us. You can recognize an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the padlock icon in your browser’s address bar. When SSL encryption is enabled, the data you transmit to us generally cannot be read by third parties.

Server Log Files

The provider of the engomo GmbH website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This information includes:

Browser Type/Browser Version

Operating System Used

Source URL

IP address in anonymized form

Time of the server request

Amount of data sent in bytes

This data cannot be linked to specific individuals. This data is not combined with other data sources. This information is required to (1) correctly deliver the content of our website, (2) optimize the content of our website, (3) ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) provide law enforcement agencies with the information necessary for criminal prosecution in the event of a cyberattack. This anonymously collected data and information is used for statistical purposes and evaluated with the goal of improving data protection standards within our company. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

Cookies

Nature and Purpose of the Processing:

To the extent that you allow us to do so through your browser settings or by giving your consent when you first visit our website, so-called “cookies” may be used when you use our website. Cookies are text files that are transferred from a website server to your hard drive. This automatically provides us with certain data, such as your IP address, the browser you are using, your operating system, and your Internet connection. Cookies cannot be used to run programs or transfer viruses to a computer. The information contained in cookies allows us to make navigation easier for you and ensure that our web pages are displayed correctly. The purpose of cookies is to improve the user experience on our website. For example, users of a website that uses cookies do not have to re-enter their login credentials every time they visit, as this information is retrieved by the website from the cookie stored on the user’s computer system. Of course, you can also view our website without cookies.

Legal basis:

Cookies are used based on the user's consent (Art. 6(1)(a) of the GDPR).

Retention period:

The duration for which cookies are stored depends on your browser settings. You can delete individual cookies or all cookies via your browser settings. Web browsers are typically set to accept cookies. In general, you can disable the use of cookies at any time through your browser settings and thereby permanently opt out of the placement of cookies. Please use your web browser’s help functions to learn how to change these settings and how to delete cookies or block them from being stored in the first place. Please note that certain features of our website may not work if you have disabled cookies.

Processing of Voluntary Information:

The use of cookies is voluntary. Please note, however, that if you reject cookies, you may not be able to use our website to its full extent.

Consent:

Your consent is given by enabling cookies in the cookie banner. By doing so, you consent to the data processing described herein.

Withdrawal of Consent:

Consent may be revoked at any time with future effect. If you do not wish to have cookies stored, you can prevent this by revoking your consent. You can also prevent cookies from being stored by adjusting the settings in your browser:

Web Analytics Tools | Performance and Statistics

engomo GmbH has integrated components for the use of web analytics tools on this website for the purpose of collecting and evaluating data on visitor behavior on the website. In this context, so-called performance and statistics cookies from third-party providers are stored in your browser, which enable an analysis of the use of our website. Among other things, engomo GmbH collects data on which website a user came from to access this website, which subpages of the website were accessed, and how often and for how long a subpage was viewed. In some cases, the user’s mouse movements may also be analyzed. engomo GmbH uses the data and information collected, among other things, to evaluate the activity on this website and to compile online reports. Information about your use of this website may be transmitted to the provider of the relevant web analytics tool and stored there. engomo GmbH employs a procedure that truncates and anonymizes the IP address of the data subject’s Internet connection when access to our website occurs from a member state of the European Union or from another signatory state to the Agreement on the European Economic Area. The provider of the web analytics tool will use the collected information on behalf of engomo GmbH to analyze your browsing behavior on the website, to compile reports on website activity, and to provide other services related to website and internet usage.

Legal basis:

The processing of data for web analytics is based on the user’s consent (Art. 6(1)(a) of the GDPR).

Recipient:

Through the use of Google Analytics, Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland, is the recipient of data. However, processing in the United States cannot be ruled out; therefore, personal data is also processed in a third country outside the EU. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR. We have entered into a data processing agreement with the recipient. For further information, please refer to Google’s Privacy Policy, which is available at: https://policies.google.com/privacy?hl=de. You can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link:

Browser Add On to deactivate Google Analytics

By using HubSpot, HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA, is the recipient of data. Data processing takes place on a server within the EU; however, the processing of personal data in a third country outside the EU cannot be ruled out. An adequate level of protection is ensured through the use of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR. We have entered into a data processing agreement with HubSpot, Inc. For further information, please refer to the HubSpot Privacy Policy, which is available at:

https://legal.hubspot.com/de/privacy-policy

Through the use of Mouseflow, Mouseflow, ApS, Flaesketorvet 68, 1711 Copenhagen V, Denmark, is the recipient of data. We have entered into a data processing agreement with Mouseflow. For more information, please refer to Mouseflow’s privacy policy, which is available at:

https://mouseflow.com/privacy/

Retention period:

The data will be deleted as soon as it is no longer required for our record-keeping purposes.

Processing of voluntary information:

The processing of data in connection with web analytics tools takes place on a voluntary basis.

Profiling:

With the help of the tracking tool Google Analytics, website visitor behavior can be evaluated and interests analyzed. To this end, we create a pseudonymous user profile.

Consent:

Your consent is granted by activating the relevant cookies (performance and statistics cookies) in the cookie banner. By doing so, you declare your agreement to the described data processing.

Withdrawal of consent:

Consent may be revoked at any time with effect for the future. If you do not wish for performance and statistical cookies to be stored, you can prevent this by revoking your consent. You can also prevent the storage of cookies by adjusting the settings in your browser accordingly:

Cookie-Settings

Use of Google AdWords

Nature and purpose of the processing:

This website uses Google AdWords, a conversion tracking service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland (hereinafter: "Google"). If you arrived at our website via an ad placed by Google, Google AdWords places a cookie on your computer. This occurs when users click on an ad placed by Google. When users visit pages on our website, both we and Google can recognize that the users clicked on the ad and were redirected to that page. Through Google AdWords, engomo GmbH obtains various statistics regarding users who clicked on our ad and were redirected to a page equipped with a conversion tracking tag, provided they have given their consent. However, engomo GmbH does not receive any information that would allow for the personal identification of users. For further information, please refer to Google’s privacy policy, which can be accessed at:

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

Legal basis:

The legal basis for the integration of Google AdWords and the associated data transfer to Google is your consent (Art. 6 para. 1 lit. a GDPR).

Recipient:

The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. However, processing in the United States cannot be ruled out; consequently, the personal data is also processed in a third country outside the EU. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR.

Retention period:

These cookies expire after 30 days and are not used for personal identification.

Processing of voluntary information:

The processing of data in connection with Google AdWords takes place on a voluntary basis.

Withdrawal of consent:

Consent may be revoked at any time with effect for the future. If you do not wish for cookies set by Google to be stored, you can prevent this by revoking your consent in the cookie settings:

Cookie-Settings

If you do not wish to participate in tracking, you can also decline the setting of the necessary cookie—for example, by using a browser setting that generally disables the automatic setting of cookies, or by configuring your browser to block cookies from the domain "googleleadservices.com". Please note that you must not delete the opt-out cookies if you do not wish for measurement data to be recorded. If you delete all cookies in your browser, you will need to set the respective opt-out cookie again.

Use of Adobe Typekit Web Fonts

Nature and purpose of the processing:

This website uses Adobe Typekit Web Fonts to ensure the consistent display of fonts. When you visit our site, your browser loads the required web fonts into its cache in order to display text and fonts correctly. To do this, your browser must connect to Adobe’s servers, informing Adobe that this website has been accessed via your IP address. However, neither engomo GmbH nor Adobe receives any information that would allow for the personal identification of users in this context. If your browser does not support web fonts, a standard font from your computer will be used. For further information, please consult Adobe’s privacy policy, available at:

https://www.adobe.com/de/privacy/policies/adobe-fonts.html

Legal basis:

The legal basis for the integration of Adobe Typekit Web Fonts and the associated data transfer to Adobe is your consent, given by agreeing to the storage of cookies (Art. 6(1)(a) GDPR).

Recipients:

The recipient of the data is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. However, processing in the United States cannot be ruled out; consequently, personal data is also processed in a third country outside the EU. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR.

Use of Google Maps

Nature and purpose of the processing:

This website embeds a map from the "Google Maps" service. When you visit our site, your browser loads the required map into its cache in order to display it correctly. This process requires the browser you are using to connect to Google's servers, resulting in the processing of data—specifically users' IP addresses and location data—by Google. However, neither engomo GmbH nor Google receives information in this context that would allow for the personal identification of users. If your browser does not support Google Maps, no map will be displayed. For further information, please refer to Google's privacy policy, which can be found at:

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

Legal basis:

The legal basis for the integration of Google Maps and the associated data transfer to Google is your consent, provided by agreeing to the storage of cookies and authorizing the sharing of your location data in your smartphone settings (Art. 6(1)(a) GDPR).

Recipients:

The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. However, processing in the United States cannot be ruled out; consequently, the personal data is also processed in a third country outside the EU. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Article 46(2)(c) and (d) of the GDPR.

Retention period:

These cookies expire after 30 days and are not used for personal identification.

Processing of voluntary information:

The processing of data in connection with Google Maps takes place on a voluntary basis.

Withdrawal of consent:

You may revoke your consent at any time, with effect for the future. If you do not wish to have maps displayed via Google Maps, you can refuse the setting of the cookie required for this purpose—for example, by adjusting your browser settings to generally disable the automatic setting of cookies. You can also disable the sharing of your location data in your smartphone's settings.

Deployment and Use of Google Tag Manager

Nature and purpose of the processing:

We use "Google Tag Manager" on our website, a service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google Tag Manager enables us to manage website tags via a web interface. Google Tag Manager, which implements the tags, operates on a cookie-free domain and does not itself collect any personal data. The tool merely triggers other tags, which may in turn collect data. Google Tag Manager does not access this data. If a deactivation has been performed at the domain or cookie level, it remains in effect for all tracking tags implemented using Google Tag Manager.

You can find further information on data protection on the following Google webpages:

Privacy Policy:

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

FAQ Google Tag Manager:

https://www.google.com/intl/de/tagmanager/faq.html

Google Tag Manager Terms of Use

https://www.google.com/intl/de/tagmanager/use-policy.html

Use and Application of Social Media Plugins

Nature and purpose of the processing:

engomo GmbH uses various social networks to reach a broad audience and increase the reach of its content. In this context, so-called social media plugins are integrated into our website. These plugins are marked with a logo or the label "Social Plugin." When you access a specific page on our website that contains such a plugin, your browser establishes a direct connection to the servers of the respective social network. The plugin content is transmitted directly from the social network to your browser and embedded into the page. Through this integration, the social network receives information that your browser has accessed the corresponding page of our website, even if you do not have a profile on that social network or are not currently logged in. This information (including your IP address) is transmitted directly from your browser to a server of the social network and stored there. If you are logged into your account on one of these social networks while using our website, the social network can directly associate your visit to our website with your profile. If you interact with the social media plugin—for example, by clicking the "Like" button or posting a comment—this information is also transmitted directly to a server of the social network and stored there. Furthermore, the information is published on your profile and displayed to your profile friends. If you do not want a social network to directly associate the data collected via our website with your profile, you must log out of the social network before visiting our website.

Legal basis:

The legal basis for the integration of social media plugins and the associated data transfer to the respective provider is your consent (Art. 6(1)(a) GDPR).

Recipients:

Vimeo Social Plugin: The data recipient is Vimeo, LLC, 555 West 18th Street, New York 10011. Consequently, personal data is also processed in a third country outside the EU. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Art. 46(2)(c) and (d) of the GDPR. Further information regarding data processing by Vimeo can be found in the privacy policy available at https://vimeo.com/privacy.

Processing of voluntary information:

The processing of data in connection with the use of social media plugins takes place on a voluntary basis.

Retention period:

Data is stored until revocation.

Withdrawal of consent:

Consent may be revoked at any time with effect for the future. If you do not wish for information to be transmitted to the respective provider, you can prevent this by logging out of the relevant social media account before visiting our website.

Subscription to our newsletter and newsletter tracking

Nature and purpose of the processing:

engomo GmbH offers interested parties the opportunity to subscribe to a newsletter. The personal data transmitted to us in this context is determined by the input form used for this purpose. We routinely collect your e-mail address and, where applicable, your name for addressing purposes. The purpose of the newsletter is to provide regular information to our customers, interested parties, and business partners regarding our offers, new products and services, or prize draws. In principle, the newsletter can only be received if the interested party possesses a valid e-mail address and registers for the newsletter service. Upon registration, a confirmation e-mail is sent once using the double opt-in procedure to verify and authorize the provided e-mail address. When you sign up for the newsletter, we also store your IP address as well as the date and time of registration in order to trace any potential misuse of e-mail addresses. Data collected during newsletter registration is used exclusively for sending the newsletter. The newsletters sent are subject to statistical analysis. This is carried out by engomo GmbH to measure the success of online marketing campaigns. Using an embedded tracking pixel, we can determine whether and when a newsletter was opened by recipients and which links within the e-mail were accessed. This data is collected to optimize newsletter distribution and to better tailor the content of future newsletters to recipients' interests.

Legal basis:

The legal basis for sending the newsletter and for the associated tracking is your consent (Art. 6(1)(a) GDPR).

Recipients:

The recipient of the data is HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA. Data processing takes place on a server within the EU; however, the processing of personal data in a third country outside the EU cannot be ruled out. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Art. 46(2)(c) and (d) of the GDPR. We have entered into a data processing agreement with HubSpot, Inc. For further information, please refer to the HubSpot Privacy Policy, which is available at:

https://legal.hubspot.com/de/privacy-policy

Retention period:

Data is stored until revocation.

Processing of voluntary information:

You only need to provide the data required to sign up for and receive the newsletter. This consists of your valid email address and your name. Without this data, we will generally be unable to deliver our newsletter to interested parties. Providing optional data is voluntary.

Withdrawal of consent:

Consent may be revoked at any time with effect for the future. The newsletter subscription may be cancelled at any time. A link for revoking consent is included in every newsletter. Alternatively, you may notify engomo GmbH of your wish to unsubscribe from the newsletter by other means (e.g., via email or post).

Newsletter distribution to existing customers

Nature and purpose of the processing:

engomo GmbH occasionally sends newsletters to existing customers for the purposes of customer care and marketing. In this context, your email address and—where applicable—your name (for addressing purposes) are processed. The purpose of the newsletter is to provide our customers with regular information about our offers, new products, and services. We also provide information regarding any upcoming or recommended software updates for our software products.

Legal basis:

The legal basis for sending newsletters to existing customers is our legitimate interest (Art. 6(1)(f) GDPR). engomo GmbH has an interest in informing its customers about new products and services. Notifications regarding upcoming or recommended software updates for our software products are provided on the basis of contract performance (Art. 6(1)(b) GDPR).

Recipients:

The recipient of the data is HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA. Data processing takes place on a server within the EU; however, the processing of personal data in a third country outside the EU cannot be ruled out. An adequate level of protection is ensured through the application of standard data protection clauses pursuant to Art. 46(2)(c) and (d) of the GDPR. We have entered into a data processing agreement with HubSpot, Inc. For further information, please refer to the HubSpot Privacy Policy, which is available at:

https://legal.hubspot.com/de/privacy-policy

Retention period:

Data collected from you may be retained for 3 to 10 years following collection for customer support and marketing purposes, unless you request the deletion of such data and there are no contractual or statutory retention obligations preventing such deletion.

Processing of voluntary information and withdrawal:

Participation in the newsletter service and the associated data processing are voluntary. You may object to the processing at any time with effect for the future. A link for withdrawing your consent is included in every newsletter. You also have the option of notifying engomo GmbH of your wish to unsubscribe from the newsletter in other ways (e.g., by email or by post).

Routine deletion and blocking of personal data

engomo GmbH processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of processing, or as provided for by the European legislator or another legislator in laws or regulations to which the controller is subject. If the purpose of processing ceases to apply or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with statutory provisions.

Your rights as a data subject

To exercise your data subject rights or address other matters related to data protection, please use the contact details provided for the controller or the data protection officer. As a data subject within the meaning of the GDPR, you have the following rights vis-à-vis the controller:

Right of access (Art. 15 GDPR)

You may request information from us at any time regarding the data we hold about you. This information covers, among other things, the categories of data we process, the purposes of such processing, the source of the data (if not collected directly from you), and, where applicable, the recipients to whom we have disclosed your data. You may obtain a free copy of your data from us. Should you require additional copies, we reserve the right to charge a fee for them.

Right to rectification (Art. 16 GDPR)

You may request the correction of your data. We will take reasonable measures to keep the data we hold and continuously process about you accurate, complete, and up-to-date, based on the most current information available to us.

Right to erasure (Art. 17 GDPR)

You may request the deletion of your data from us, provided the legal requirements for doing so are met. Pursuant to Art. 17 GDPR, this may be the case, for example, if:

the data are no longer necessary for the purposes for which they were collected or otherwise processed;

you withdraw your consent, which serves as the basis for the data processing, and there is no other legal basis for the processing;

you object to the processing of your data and there are no overriding legitimate grounds for the processing, or you object to the data processing for direct marketing purposes;

the data was processed unlawfully;

processing is not necessary to ensure compliance with a legal obligation requiring us to process your data—particularly with regard to statutory retention periods—or to establish, exercise, or defend legal claims.

Right to restriction of processing (Art. 18 GDPR)

You may request that we restrict the processing of your data if:

you contest the accuracy of the data, specifically for the period we require to verify the accuracy of the data;

the processing is unlawful and you object to the erasure of your data and request the restriction of its use instead;

we no longer need your data, but you require it to establish, exercise, or defend legal claims;

You have objected to the processing until it is clear whether our legitimate reasons outweigh yours.

Right to data portability (Art. 20 GDPR)

Upon your request, we will transfer your data—to the extent technically feasible—to another controller. However, you are only entitled to this right if the data processing is based on your consent or is necessary for the performance of a contract. Instead of receiving a copy of your data, you may also ask us to transmit the data directly to another controller specified by you.

Right to object (Art. 21 GDPR)

You may object to the processing of your data at any time for reasons arising from your particular situation, provided that the data processing is based on your consent or on our legitimate interests or those of a third party. In such a case, we will no longer process your data. This does not apply if we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, or if we require your data for the establishment, exercise, or defense of legal claims.

Right to withdraw consent under data protection law (Art. 7(3) GDPR)

You have the right to revoke your data protection consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent prior to the revocation.

Deadlines for fulfilling data subjects' rights

We generally aim to respond to all requests within 30 days. However, this timeframe may be extended depending on the specific data subject right involved or the complexity of your request. Restrictions on providing information regarding data subject rights In certain situations, legal requirements may prevent us from providing information about all of your data. If we are required to refuse your request for information in such a case, we will also inform you of the reasons for the refusal.

Competent supervisory authority

engomo GmbH takes your concerns and rights very seriously. However, should you believe that we have not adequately addressed your complaints or concerns, you have the right to lodge a complaint with a competent data protection authority. The State Commissioner for Data Protection and Freedom of Information P.O. Box 10 29 32 70025 Stuttgart Phone: 07 11/61 55 41-0 Fax: 07 11/61 55 41-15