Privacy policy

We are delighted about the visit of our website. ACTICO GmbH (hereinafter ‘ACTICO’, ‘we’ or ‘us’) attaches great importance to the security of users’ data and compliance with data protection provisions. Hereinafter, we would like to inform about how personal data is processed on our website.

Controller and data protection officer

Controller:
ACTICO GmbH, Charlottenstrasse 2, 88045 Friedrichshafen
Tel.: +49 7541 39726-0
E-Mail: info@actico.com

Data Security and Information Security:
Email: data-security@actico.com
Phone: +49 7541 39726-0

External data protection officer:

Aigner Business Solutions GmbH
Goldener Steig 42
94116 Hutthurm, Germany

Phone: +49 8505 919 270

Email: swen.goslar@aigner-business-solutions.com

Terms

The specialist terms used in this Privacy Policy are to be understood as legally defined in article 4 GDPR.

Information on data processing

Automated data processing (log files etc.)

Our website can be visited without actively providing personal information about the user. However, every time our website is accessed, we automatically store access data (server log files), such as the name of the internet service provider, the operating system used, the website the user visited us from, the date and duration of the visit and the name of the file accessed, as well the IP address of the device used (for security reasons, such as to recognise attacks on our website) for a duration of 14 days. This data is solely evaluated for the purpose of improving our offering and does not enable conclusions to be drawn about the person of the user. This data is not merged with other data sources. The legal basis for the processing of data is article 6 (1) (f) GDPR. We process and use the data for the following purposes: 1. to provide the website, 2. to improve our websites and 3. to prevent and identify errors/malfunctions and the abuse of the website. The processing enables us to pursue legitimate interests in ensuring the functionality of the website and its error-free, secure operation, as well as in adapting this website to suit users’ needs.

Consent Management Tool

We use a consent management procedure on our online offer in order to be able to store and manage the consent given by visitors to our online offer in a verifiable manner in accordance with the requirements of the GDPR. At the same time, visitors to our online offering can manage the consent and preferences granted or revoke consent via the service we have integrated.

The consent status is stored on the server and/or in a cookie (so-called opt-in cookie) or a comparable technology in order to be able to assign the consent to a user or their device. In addition, the time of the declaration of consent is recorded.

Categories of data subjects:
website visitors who use the Consent Management Tool.

Categories of data:
User data (e.g. web pages visited, interest in content, access times), meta and communication data (e.g. device information, IP addresses).

Purposes of processing:
fulfilment of accountability obligations, consent management

Legal bases:
legal obligation (Art. 6 para. 1 lit. c) DSGVO i.V.m. Art. 7 DSGVO)

Consent management:
You can manage your consent by clicking on the grey icon, at the bottom left of your browser window.

Cookiebot/Usercentrics

Recipient: Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany
Data protection: https://usercentrics.com/de/datenschutzerklaerung/

Hosting incl. Content Delivery Network

Our online offer is hosted by an external service provider. Personal data of visitors to our online offer, in particular so-called log files, are stored on the servers of our service provider. Likewise, this may be data that is generated or collected during the active use of our online offer. By using a specialised service provider, we can provide our online offer securely and efficiently. The hosting provider we use does not process the data for its own purposes.

We also use a so-called Content Delivery Network (CDN) in order to be able to provide the content of our online offer more quickly. When visitors to our website access graphics, scripts or other content, for example, these are provided quickly and optimally with the help of regionally and internationally distributed servers. When the files are accessed, a connection is established to the servers of a CDN provider, whereby personal data of the visitors to our website are processed, for example the IP address, browser data or the so-called user agent.

Categories of data subjects:
website visitors

Categories of data:
User data (e.g. web pages visited, interest in content, access times), meta and communication data (e.g. device information, IP addresses).

Prposes of processing:
Proper design of our online offer

Legal grounds:
consent (Art. 6 para. 1 lit. a) DSGVO); legitimate interests (Art. 6 para. 1 lit. f) DSGVO).

Legitimate interests:
Proper presentation and optimisation of the website, faster website accessibility, avoidance of downtime, high scalability.

HubSpot CMS

Tool: HubSpot, Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141 USA
Data protection: https://legal.hubspot.com/de/privacy-policy

Akamai Technologies GmbH

Tool: Akamai Technologies GmbH, Parkring 22, 85748 Garching, Germany
Privacy: https://www.akamai.com/de/legal/compliance/privacy-trust-center
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Wistia

Tool: Wistia Inc., 120 Brookline St, Cambridge, MA 02139 USA
Privacy: https://wistia.com/privacy
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Use of cookies (general, functionality, opt-out links etc.)

We use ‘cookies’ on our website to make visiting our website more attractive and to enable certain functions to be used. The use of cookies serves our legitimate interest in making a visit to our website as pleasant as possible and is based on article 6 (1) (f) GDPR. Cookies are standard internet technology used to store and retrieve login details and other usage information for all the users of a website. Cookies are small text files that are deposited on your end device. They enable us to store user settings, inter alia, to ensure that our website can be shown in a format tailored to your device. Some of the cookies we use are deleted after the end of a browser session, i.e. when closing the browser (known as ‘session cookies’). Other cookies remain on the user’s end device and enable us or our partner companies to recognise the browser on the next visit (known as ‘persistent cookies’).

The browser can be set so that the user is informed when cookies are to be stored and can decide whether to accept them in each individual situation, to accept them under certain circumstances, or to exclude them in general. In addition, cookies can be retrospectively deleted to remove data that the website stored on your computer. Deactivating cookies (known as ‘opting out’) can limit our website’s functionality in some respects.

Categories of data subjects:
Website visitors, users of online services

Opt-Out:
Internet Explorer: https://support.microsoft.com/de-de/help/17442
Firefox: https://support.mozilla.org/de/kb/wie-verhindere-ich-dass-websites-mich-verfolgen
Google Chrome: https://support.google.com/chrome/answer/95647?hl=de
Safari: https://support.apple.com/de-de/HT201265

Legal bases:
Consent (article 6 (1) (a) GDPR), legitimate interest (article 6 (1) (f) GDPR)
The pertinent legal basis is specifically stated for each tool in question

Legitimate interests:
Storing of opt-in preferences, presentation of the website, assurance of the website’s functionality, provision of user status across the entire website, recognition for the next website visitors, user-friendly online offering, assurance of the chat function

Online marketing

We process personal data within the framework of online marketing, particularly regarding potential interests and to measure the effectiveness of our marketing measures, with the aim of continually boosting our reach and the prominence of our online offering.

We store the relevant information in cookies or use similar procedures for the purpose of measuring the effectiveness of our marketing measures and identifying potential interests. The data stored in the cookies could include the content viewed, webpages visited, settings, and the functions and systems used. However, plain data from users is not normally processed for the above purposes. If so, the data is changed so that the actual identity of the user is not known to us, nor the provider of the tool used. The changed data is often stored in user profiles.

In the event that user profiles are stored, the data can be used, read, supplemented, and expanded on the server of the online marketing procedure when other online offerings are visited that use the same online marketing procedure.

We can calculate the success of our adverts using summarised data that is made available to us by the provider of the online marketing procedure (known as ‘conversion measurement’). As part of these conversion measurements, we can trace whether a marketing measure caused a visitor to our online offering to decide to make a purchase. This evaluation serves to analyse the success of our online marketing.

Categories of data subjects:
Website visitors, users of online services, prospective customers, communication partners, business partners and contractual partners

Data categories:
Usage data (e.g. websites visited, interest in content, access times), metadata and communication data (e.g. device information, IP addresses), location data, contact data (e.g. email address, telephone number), content data (e.g. text inputs, photographs, videos)

Purposes of processing:
Marketing (sometimes interest-based and behavioural, as well), conversion measurement, target group formation, click tracking, development of marketing strategies and increase in the efficiency of campaigns

Legal bases:
Consent (article 6 (1) (a) GDPR), legitimate interest (article 6 (1) (f) GDPR)

Legitimate interests:
Optimisation and further development of the website, increase in profits, customer loyalty and acquisition

Google Tag Manager

Tool: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy: https://policies.google.com/privacy
Opt-out-link: https://tools.google.com/dlpage/gaoptout?hl=de or https://myaccount.google.com/
Legal base: Legitimate interest (article 6 (1) (f) GDPR)
Legitimate interests: Coordination of different tools, management, easy handling and representation
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Google Analytics

Tool: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy: https://policies.google.com/privacy
Opt-out-link: https://tools.google.com/dlpage/gaoptout?hl=de
oder https://myaccount.google.com/
Legal base: Consent (article 6 (1) (a) GDPR)
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Google AdWords and conversion measurement

Tool: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy: https://policies.google.com/privacy
Opt-out-link: https://tools.google.com/dlpage/gaoptout?hl=de
oder https://myaccount.google.com/
Legal base: Consent (article 6 (1) (a) GDPR)

Google Doubleclick

Tool: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy:  https://policies.google.com/privacy
Opt-out-link: https://tools.google.com/dlpage/gaoptout?hl=de
oder https://myaccount.google.com/
Legal base: Consent (article 6 (1) (a) GDPR)
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

LinkedIn Ads, LinkedIn Analytics

Tool: LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085, USA
Privacy: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy
Opt-out-link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Legal base: Consent (article 6 (1) (a) GDPR)
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Twitter

Tool: Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Irland
Privacy: https://twitter.com/de/privacy
Opt-out-link: https://help.twitter.com/de/rules-and-policies/twitter-cookies#privacy-options
Legal base: Consent (article 6 (1) (a) GDPR)

VWO

Tool: Wingify Software Pvt. Ltd. tätig als VWO, Heidenkampsweg 58, 20097 Hanburg, Germany
Privacy: https://vwo.com/de/privacy-policy/
Opt-out-link: https://vwo.com/de/opt-out/
Legal base: Consent (article 6 (1) (a) GDPR)

Presence on social media

We maintain online presences on social networks and career platforms so we can exchange information with users registered there and easily contact them.

Sometimes, data belonging to social network users is used for market research and, by extension, for advertising purposes. Users’ usage behaviour, such as their stated interests, can lead to user profiles being created and used in order to adapt adverts to suit the interests of the target group. To this end, cookies are normally stored on users’ end devices, which sometimes occurs regardless of whether you are a registered user of the social network.

In conjunction with the use of Kununu, we also make use of the associated messenger service to communicate easily with users. We would like to point out that the security of some services can depend on the user’s account settings. Even in cases of end-to-end encryption, the service provider can draw conclusions about the fact that the user is communicating with us, when they do so, and, on occasion, capture location data.

Depending on where the social network is operated, the user data can be processed outside the European Union or outside the European Economic Area. This can lead to risks for users because it is more difficult for them to assert their rights, for example.

Categories of data subjects:
Registered users and non-registered users of the social network

Data categories:
Master data (e.g. name, address), contact data (e.g. email address, telephone number), content data (e.g. text inputs, photographs, videos), usage data (e.g. websites visited, interest in content, access times), metadata and communication data (e.g. device information, IP addresses)

Purposes of processing:
Increase in the reach, networking of users

Legal bases:
Consent (article 6 (1) (a) GDPR), legitimate interest (article 6 (1) (f) GDPR)

Legitimate interests:
Interaction and communication on social media pages, increase in profits, findings regarding target groups

Facebook

Tool: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland
Privacy: https://www.facebook.com/privacy/explanation
and https://www.facebook.com/legal/terms/page_controller_addendum
Opt-out-link: https://www.facebook.com/settings?tab=ads

LinkedIn

Tool: LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085, USA
Privacy: https://www.linkedin.com/legal/privacy-policy
Opt-out-link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Kununu

Tool: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
Privacy: https://privacy.xing.com/de/datenschutzerklaerung
Opt-out-link: https://www.xing.com/settings/privacy/data/tracking

Twitter

Tool: Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Irland
Privacy: https://twitter.com/de/privacy
Opt-out-link: https://help.twitter.com/de/rules-and-policies/twitter-cookies#privacy-options

YouTube

Tool: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy: https://policies.google.com/privacy?hl=de&gl=de
Opt-out-link: https://tools.google.com/dlpage/gaoptout?hl=de
or https://myaccount.google.com/
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Xing

Tool: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
Privacy: https://privacy.xing.com/de/datenschutzerklaerung
Opt-out-link: https://www.xing.com/settings/privacy/data/tracking

Plug-ins and integrated third-party content

We have integrated functions and content obtained from third-party providers into our online offering. For example, videos, depictions, buttons or contributions (hereinafter termed ‘content’) can be integrated.

To enable visitors to our online offering to be shown content, the third-party provider in question processes the user’s IP address, inter alia, to transmit the content to the browser and display it. It is not possible to integrate third-party content without this processing taking place.

Sometimes, additional information is collected via ‘pixel tags’ or web beacons through which the third-party provider receives information about the use of the content or visitor traffic to our online offering, technical information about the user’s browser or operating system, the visit time or referring websites. The data collected in this manner is stored in cookies on the user’s end device. We have taken security precautions to prevent this data from being automatically transferred, with the aim of protecting the personal data of visitors to our online offering. This data is only transferred if the visitor uses the buttons or click on the third-party content. To this end, we use Heise’s Shariff solution/two-click solution.

Information about the use of Shariff for the CMS system in question can be found at: https://github.com/heiseonline/shariff

Information about the functioning and use of the ‘two-click solution’ from the computer magazine c’t is available at: https://www.heise.de/ct/artikel/2-Klicks-fuer-mehr-Datenschutz-1333879.html.

Categories of data subjects:
Users of plug-ins or third-party content

Data categories:
Usage data (e.g. websites visited, interest in content, access times), metadata and communication data (e.g. device information, IP addresses) contact data (e.g. email address, telephone number), Master data (e.g. name, address)

Purposes of processing:
Design of our online offering, increase in the reach of adverts on social media, sharing of contributions and content, interest-based and behavioural marketing, cross-device tracking

Legal bases:
Consent (article 6 (1) (a) GDPR)

LinkedIn plug-ins and buttons

Tool: LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085, USA
Privacy: https://www.linkedin.com/legal/privacy-policy
Opt-out-link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Legal base: Consent (article 6 (1) (a) GDPR)
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

YouTube

Tool: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Privacy: https://policies.google.com/privacy?hl=de&gl=de
Opt-out-link: https://tools.google.com/dlpage/gaoptout?hl=de
or https://myaccount.google.com/
Legal base: Consent (article 6 (1) (a) GDPR)
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Xing plug-ins and buttons

Tool: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
Privacy: https://privacy.xing.com/de/datenschutzerklaerung
Opt-out-link: https://www.xing.com/settings/privacy/data/tracking
Legal base: Consent (article 6 (1) (a) GDPR)

Online conferences, meetings and webinars

We make use of the opportunity to hold online conferences, meetings and webinars. To do so, we use offerings provided by other carefully selected providers.

When actively using offerings of this nature, data regarding the participants in the communication is processed and stored on the servers of the third-party services used, provided this data is necessary for the communication process. In addition, usage data and metadata can also be processed.

We may record meetings for the purpose of providing evidence of the content of the discussions. If we wish to record meetings, we will inform you transparently in advance and ask for your consent.

Categories of data subjects:
Participants in the online offering in question (conference, meeting, webinar)

Data categories:
Master data (e.g. name, address), contact data (e.g. email address, telephone number), Content data (e.g. text inputs, photographs, videos), metadata and communication data (e.g. device information, IP addresses)

Purposes of processing:
Processing of enquiries, increase in efficiency, promotion of cross-company or cross-location collaboration

Legal bases:
Consent (article 6 (1) (a) GDPR)

Microsoft Teams

Tool: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA
Privacy: https://privacy.microsoft.com/de-de/privacystatement
Opt-out-link: https://account.microsoft.com/privacy/ad-settings/signedout?ru=https:%2F%2Faccount.microsoft.com%2Fprivacy%2Fad-settings
Legal base: Consent (article 6 (1) (a) GDPR)

GoToMeeting

Tool: LogMeIn, 320 Summer Street, Boston, MA 02210, USA
Privacy: https://www.logmeininc.com/de/legal/privacy
Opt-out-link: http://preferences-mgr.truste.com/
Legal base: Consent (article 6 (1) (a) GDPR)

Blog and forum

We have provided a blog or comparable opportunities for publication on our webpage. We want to give visitors to our online offering the option of contacting us or sharing their thoughts and suggestions with us in this manner.

If users of our online offering publish comments and contributions on our website, we are obliged to prevent unlawful content, or the publication of the same, from appearing on our website. We collect the IP addresses of the users in question so that we can adhere to this obligation and protect our interests in being indemnified in the event that we are used for third-party content. This also helps us to identify spam.

Beyond this, users of the function provided are not obliged to make details available that could lead to conclusions being drawn about the identity of the user in question. A contribution can even be published under a pseudonym, meaning that the user can then decide themselves what data and content we process.

Categories of data subjects:
Users of the function in question

Data categories:
Master data (e.g. name, address), contact data (e.g. email address, telephone number), content data (e.g. text inputs, photographs, videos), usage data (e.g. websites visited, interest in content, access times), contract data (e.g. subject of the contract, term, customer category), metadata and communication data (e.g. device information, IP addresses)

Purposes of processing:
Networking of users, creation of customer loyalty, services and feedback

Legal bases:
Consent (article 6 (1) (a) GDPR), legitimate interest (article 6 (1) (f) GDPR)

Legitimate interests:
Indemnification in the event of liability, prevention, security of the webpage, duplication of communication channels with visitors to the online offering, optimisation and further development of online offering

Use of survey services on the website with data transfer

We carry out questionnaires and surveys (hereinafter ‘surveys’) on our online offering. This helps us to improve our offering and better meet our customers’ needs. To this end, it is not necessary to be able to trace whether we can associate feedback with a particular person. Before your survey is evaluated, the data we process to provide and execute our surveys on a technical level is anonymised. Participation in the survey is voluntary.

Categories of data subjects:
Participants in the online surveys

Data categories:
Metadata and communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times), master data (e.g. name, address), contact data (e.g. email address, telephone number)

Purposes of processing:
Marketing, increase in customer loyalty and new customer acquisition, improvement/optimisation of the offering

Legal bases:
Consent (article 6 (1) (a) GDPR)

LamaPoll

Tool: Lamano GmbH & Co. KG, Prenzlauer Allee 36G, 10405 Berlin
Privacy: https://www.lamapoll.de/Support/Datenschutz

Newsletter and mass communication (including tracking, if applicable)

On our online offering, users have the option of subscribing to our newsletter or to notifications on various channels (hereinafter referred to overall as ‘newsletters’). We only send newsletters to recipients who have agreed to receive the newsletter, and within the framework of statutory provisions. We use a select service provider to send out our newsletter.

An email address must be provided to subscribe to our newsletter. If applicable, we collect extra data, such as to include a personal greeting in our newsletter.

Our newsletter is only sent after the ‘double opt-in procedure’ has been fully completed. If visitors to our online offering decide to receive our newsletter, they will receive a confirmation email that serves to prevent the fraudulent input of wrong email addresses and preclude a single, possibly accidental, click from causing the newsletter to be sent. The subscription to our newsletter can be ended at any time with future effect. An unsubscription (opt-out) link is given at the end of every newsletter.

In addition, we are obliged to provide proof that our subscribers actually want to receive the newsletter. To this end, we collect and store their IP address, along with the time of subscription and unsubscription.

Our newsletters are designed so that we can obtain findings about improvements, target groups or the reading behaviour of our subscribers. We are able to do this thanks to a ‘web beacon’ or tracking pixel that reacts to interactions with the newsletter, such as looking at whether links are clicked on, whether the newsletter is opened at all, or at what time the newsletter is read. For technical reasons, we can associate this information with individual subscribers.

Categories of data subjects:
Newsletter subscribers

Data categories:
Master data (e.g. name, address), contact data (e.g. email address, telephone number), metadata and communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times)

Purposes of processing:
Marketing, increase in customer loyalty and new customer acquisition, analysis and evaluation of the campaigns’ success

Legal bases:
Consent (article 6 (1) (a) GDPR)

HubSpot

Tool: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA
Privacy: https://legal.hubspot.com/de/privacy-policy
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Contacting us

On our online offering, we offer the option of contacting us directly or requesting information via various contact options. We use a management tool for these enquiries so that we always have an overview of contact that has been made with us.

In the event of contact being made, we process the data of the person making the enquiry to the extent necessary for answering or handling their enquiry. The data processed can vary depending on the method via which contact is made with us.

Categories of data subjects:
Individuals submitting an enquiry

Data categories:
Master data (e.g. name, address), contact data (e.g. email address, telephone number), content data (e.g. text inputs, photographs, videos), metadata and communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times)

Purposes of processing:
Processing requests

Legal bases:
Consent (article 6 (1) (a) GDPR), performance of contract (article 6 (1) (b) GDPR)

HubSpot

Tool: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA
Privacy: https://legal.hubspot.com/de/privacy-policy
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Salesforce

Tool: Salesforce, Inc., The Landmark @ One Market Street, Suite 300, San Francisco, CA 94105 USA
Privacy: https://www.salesforce.com/de/company/privacy/
Data transfer: yes (USA)
Guarantee: Standard contractual clauses

Advertising communications

We also use data provided to us for advertising purposes, particularly to provide information on various channels about new products from us or in our portfolio of offerings. However, promotional contact from our side is only undertaken within the framework of the statutory requirements, and once consent has been granted, insofar this is necessary.

If the recipients of our advertising do not want to receive it, they can inform us of this at any time with future effect. We are happy to acquiesce to their request.

Categories of data subjects:
Communication partners

Data categories:
Master data (e.g. name, address), contact data (e.g. email address, telephone number)

Purposes of processing:
Direct marketing

Legal bases:
Consent (article 6 (1) (a) GDPR), legitimate interest (article 6 (1) (f) GDPR)

Legitimate interests:
Retention of existing contacts/contractual partners and acquisition of new ones

Data transfer

We transfer the personal data of visitors to our online offering for internal purposes (e.g. for internal administration or to the HR department so we can meet statutory or contractual obligations). Internal data transfer or the disclosure of data only occurs to the extent necessary, under the pertinent data protection provisions.

We are a globally active company headquartered in Germany. Data of visitors to our online offering is stored in our central customer database in Germany, in compliance with the pertinent data protection provisions, and is processed across the group for internal administrative purposes. It is not processed for purposes other than administrative ones.

Legal bases:
Legitimate interests (article 6 (1) (f) GDPR)

Legitimate interests:
‘Small-group exemption’, centralised management and administration within the company to make use of synergy effects, cost savings, increased efficiency

We transfer data to countries outside the EEA (known as ‘third countries’). This occurs due to the above-mentioned purposes (transfer within the group and/or to other recipients). Transfer is only effected to fulfil our contractual and legal obligations, or on the basis of the consent that the data subject granted prior to this. In addition, this transfer takes place in compliance with the applicable data protection laws, and particularly in accordance with article 44 ff. GDPR, especially on the basis of adequacy decisions made by the European Commission or certain guarantees (e.g. standard protection clauses available at https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32021D0914&from=DE etc.).

Storage period

In principle, we store the data of visitors to our online offering for as long as needed to render our service or to the extent that the European body issuing directives and regulations or another legislator stipulates in laws and regulations to which we are subject. In all other cases, we delete personal data once the purpose has been fulfilled, with the exception of data that we need to continue to store to comply with legal obligations (e.g. if retention periods under tax law and trade law require us to keep documents such as contracts and invoices for a certain period of time).

Automated decision-making

We do not use automated decision-making or profiling.

Legal bases

The decisive legal bases primarily arise from the GDPR. They are supplemented by national laws from member states and can, if applicable, be applied alongside or in addition to the GDPR.

Consent:
Article 6 (1) (a) GDPR serves as the legal basis for processing procedures regarding which we have sought consent for a particular purpose of processing.

Performance of a contract:
Article 6 (1) (b) serves as the legal basis for processing required to perform a contract to which the data subject is a contractual party or for taking steps prior to entering into a contract, at the request of the data subject.

Legal obligation:
Article 6 (1) (c) GDPR is the legal basis for processing that is required to comply with a legal obligation.

Vital interests:
Article 6 (1) (d) GDPR serves as the legal basis if the processing is necessary to protect the vital interests of the data subject or another natural person.

Public interest:
Article 6 (1) (e) GDPR serves as the legal basis for processing that is necessary to perform a task in the public interest or to exercise public force that is transferred to the controller.

Legitimate interest:
Article 6 (1) (f) GDPR serves as the legal basis for processing that is necessary to protect the legitimate interests of the controller or a third party, provided this is not outweighed by the interests or fundamental rights and fundamental freedoms of the data subject that require personal data to be protected, particularly if the data subject is a child.

Rights of the data subject

Right of access:
Pursuant to article 15 GDPR, data subjects have the right to request confirmation as to whether we process data relating to them. They can request access to their data, along with the additional information listed in article 15 (1) GDPR and a copy of their data.

Right to rectification:
Pursuant to article 16 GDPR, data subjects have the right to request that data relating to them, and that we process, be rectified or completed.

Right to erasure:
Pursuant to article 17 GDPR, data subjects have the right to request that data relating to them be erased without delay. Alternatively, they can request that we restrict the processing of their data, pursuant to article 18 GDPR.

Right to data portability:
Pursuant to article 20 GDPR, data subjects have the right to request that data made available to us by them be provided and transferred to another controller.

Right to lodge a complaint:
In addition, data subjects have the right to lodge a complaint with the supervisory authority responsible for them, under article 77 GDPR.

Right to object:
If personal data is processed on the basis of legitimate interests pursuant to article 6 (1) (1) (f) GDPR, under article 21 GDPR data subjects have the right to object to the processing of their personal data, provided there are reasons for this that arise from their particular situation or the objection relates to direct advertising. In the latter case, data subjects have a general right to object that is to be put into effect by us without a particular situation being stated.

Withdrawal of consent

Some data processing procedures can only be carried out with the express consent of the data subject. Once granted, you are able to withdraw consent at any time. To do so, sending an informal note or email to datenschutz@actico.com is sufficient. The legality of the data processing carried out up to the point of withdrawal shall remain unaffected by the withdrawal.

External links

Our website includes links to online offerings from other providers. We note that we have no influence over the content of the online offerings linked to and over whether their providers comply with data protection provisions.

Amendments

We reserve the right to amend this information on data protection, in compliance with the applicable data protection provisions, if changes are made to our online offering so that it complies with the legal requirements.

This Privacy Policy was drawn up by the DDSK GmbH.

Date: January 2024