Take 25 Pictures GmbH – Privacy Policy
1. Controller
Take 25 Pictures GmbH, Friedrichstr. 14-16, 25774 Lunden, Germany, represented by the Managing Director: Hauke Schlichting. (“Take 25 Pictures GmbH” or “we”), thanks you for visiting our web pages at www.take25pictures.com (“web pages”).
Any personal data shall be saved, processed and used by us under adherence to any applicable privacy regulations (especially the General Data Protection Regulation (GDPR), the German Federal Data Protection Act [Bundesdatenschutzgesetz, BDSG] and the German Telemedia Act [Telemediengesetz, TMG]).
Personal data is any information that refers to an identified or identifiable natural person (hereafter referred to as the “data subject”); a natural person shall be considered to be identifiable who may be directly or indirectly identified, especially through identifiers, such as a name, identification number, location data, online identifiers or one or several special characteristics that represent expressions of the physical, physiological, genetic, psychological, economic, cultural or social identity that can be assigned to this natural person. Information that cannot be associated with your true identity does not constitute personal data; this includes the number of users of our web pages or comparable summarized data.
2. Processing Purpose and Legal Basis
By default, our web servers temporarily protocol the connection data of requesting computers that visit our web pages, the date and duration of visits, the identification data of the browser and operating system type and the websites from which they visit us.
We use tracking software to determine the frequency of use and number of users of our website. This software does not record data through which we can derive personal information, but we will learn your IP address when accessing our website. This data will only be used in anonymized and summarized form for statistical purposes and for the development of the website. These purposes for the processing are grounds for the legitimate interest we pursue (Article 6(1) f) GDPR. You may object to the collection and use of your IP address for statistical purposes by deactivating your internet browser’s “Track User” function.
Irrespective thereof, you may generally visit our web pages without personal data being collected by us. Our web pages provide information on the Take 25 Pictures GmbH in particular for investor relation and public information purposes.
We, as the controller, will collect, process and use personal data on the basis of Article 6(1) a) or b) of the GDPR that you provide to us of your own accord for the execution of a contract or pre-contractual measures, when contacting us or if you grant your permission for the respective processing. Furthermore, we may process your personal data if such processing is necessary for safeguarding legitimate interests of ours or of a third party, unless outweighed by your interests or basic rights or basic freedoms that require the protection of your personal data (Article 6(1) f) GDPR), as further explained hereafter, or if necessary for the fulfillment of other legal obligations of Take 25 Pictures GmbH (Article 6(1) c) GDPR) or according applicable legal regulations of a member state of the European Union.
a) Communication Purposes
We will process and use your name, company name, private or business address, email address, telephone number (“inventory data”) and/or any other personal data which you might send us on your own accord to the extent necessary in order to respond to your communication or requests (Article 6(1) b) GDPR).
a) Recruiting
On our web pages we can publish job advertisements for open positions at Take 25 Pictures GmbH or at an affiliated company which belongs to Take 25 Pictures GmbH. Responsible for the recruiting and processing of your application is the company named in the individual job advertisement.
If you have submitted your application to us or to another affiliated company of the Take 25 Pictures GmbH (“Affiliate”), we and/or our Affiliate will process the information and documents submitted including the personal data contained in your application for the further handling of your application (§ 26(1) BDSG). Such personal data might include your name, address, email address, telephone number, information on your professional education/CV, certificates and/or any other information which you might have disclosed on your own accord in connection with your application. The provision of your personal data is necessary for conducting the recruitment process. You are not obliged by law or by contract to provide us with your personal data for recruitment purposes. Please note, however, that we cannot process your application if you refrain from providing us with necessary information.
If we or the Affiliate to which you submitted your application, could not hire you in the recent recruiting procedure but would like to store your application in order to take your application into account for future vacancies, we or the Affiliate will contact you and ask for your respective consent (Art. 6(1) a GDPR). Prior to that, we or the Affiliate will inform you on the details (e.g. retention period of your application).
3. Data Transfers to Third Parties
We will not provide your personal data to third parties without your express permission, which you may revoke at any time, or unless we are authorized to do so by law.
This includes service providers commissioned by us who support us with our business operations (abuse prevention, advertising agencies, IT service providers for operating our web pages).
In any case, the extent of the transmitted data will be limited to the minimum required for achieving the objective of the data processing.
Should we be legally required to disclose certain personal data due to court orders or requests by prosecution or regulatory authorities or authorized third parties for investigative procedures or because of suspicions of crimes, unlawful acts or other actions that may result in liability for you or us, we will disclose the data required for the investigation, such as your name, address, email address or order history (Article 6(1) c) GDPR). Moreover, we might process and use your personal data in order to enforce or defend claims.
4. Data Transfers into Non-EEA / Non-EU Countries
We may also transfer your personal data to third parties outside of EEA / EU member states for which the European Commission does not find privacy protection levels to be comparable to those of the EU (e.g., the US). In such cases, before transferring your data, we will ensure that the recipient possesses an adequate privacy protection level, especially by first obtaining your consent for the processing, or through specific safeguards according to Article 44 et seq. GDPR such as the EU-US Privacy Shield self-certification for US recipients or by concluding so-called EU Standard Contractual Clauses for the third country. You may receive a copy of appropriate safeguards such as these Standard Contractual Clauses from our data protection officer on request; see Section 12 for contact details. Moreover, you can find further information on the members of the EU-US Privacy Shield here: www.privacyshield.gov/list.
5. Newsletters
Our web pages offer subscriptions to a free email newsletter. When subscribing for the newsletter, data submitted through the input screen for registration will be transmitted to us (your name, email address, if applicable, telephone number for text messages). We will request your permission to process your data during the registration process or subsequent visits to our web pages (Article 6(1) a) GDPR, Section 7(2) of the German Act Against Unfair Competition [Gesetz gegen den unlauteren Wettbewerb, UWG]) and refer to this Privacy Policy. In the event of such consent we may send such newsletters to you through the newsletter platforms “MailChimp” and “Mandrill”, operated by Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA (together “MailChimp”) which we have assigned. MailChimp is certified with the „EU-US Privacy Shield“ and is therefore obligated to comply with the European data protection regulations. Furthermore, we have concluded a „Data Processing Agreement” with MailChimp, in which MailChimp has agreed to protect the data of our users according to the provisions of this Data Processing Agreement, to process data on our behalf and in particular not to transfer data to any third parties. Please find further information in regard to data processing by MailChimp in MailChimp’s Privacy Policy. We will provide the details of the processing of your personal data to you transparently before the completion of your newsletter subscription.
6. Cookies
Several of our websites use cookies to make visiting our web pages more attractive and allow use of certain functions. Cookies are small text files saved onto your computer. Most of the cookies we use are so-called “session cookies.” These will be automatically deleted after your visit to our web pages. Furthermore, we use permanent cookies, which enable us to recognize you when you visit our website in the future for the optimization of user settings. The legal basis for the use of cookies for the operation of our website and certain services on behalf of our users is Article 6(1) f) GDPR. In addition, if and where legally required we obtain your consent (Article 6(1) a) DSGVO). You may prevent cookies from being saved onto your computer through according browser settings. However, this may limit navigational options on our web pages.
7. Google Analytics
Take 25 Pictures GmbH uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, 94043 CA, USA, (“Google”). Google Analytics saves information about your use of these web pages (including your IP address) on cookies. (For information about cookies, please see above). The information saved by Google Analytics on cookies will be transmitted to a Google server in the US where it is stored and assessed. Please note that Google Analytics was extended by the code “gat._anonymizeIp(); on our web pages. This ensures that IP addresses are collected anonymously (through so-called IP masking). Through this process, IP addresses are usually shortened by Google servers in member states of the European Union or in other states party to the European Economic Area Agreement before being saved or transmitted to Google servers in the US. IP addresses that have not been shortened are only transmitted to Google servers in the US in exceptions, though, even in such cases, the IP addresses will be shortened before being saved.
Google will use the transmitted data to assess your use of our web pages, compile web page activity reports and perform additional services for our web pages for us. (We therefore have a data processing agreement with Google). The purpose of using Google Analytics is the continuous improvement of our websites and optimize your user experience. These purposes are also the grounds for our legitimate interest for the processing (Article 6(1) f) GDPR). Furthermore, the processing is based on your consent in regard to the processing by Google for these purposes and as explained above which you may give us by clicking a respective button on this website (Article 6(1) a) DSGVO).
You may prevent the collection of your data by Google Analytics and its transfer to and processing by Google by deactivating cookies (see above).
Furthermore, you may also prevent the collection of your data by Google Analytics, if you click on the following link. In this case, an opt-out cookie will be placed which will prevent the future collection of your data by Google Analytics when you visit this website in the future: Deactivate Google Analytics.
Google also offers a deactivation add-on for common desktop browsers. These add-ons block Google Analytics and prevent personal data on your use of our web pages (including your IP address) from being transferred to and processed by Google. This browser plugin can be downloaded and installed at: http://tools.google.com/dlpage/gaoptout
Irrespective thereof, any data collected by Google Analytics will automatically be deleted after 14 months with or without your interactions in this matter.
Further information about the purpose and scope of data collection and further processing and use by Google, including notices about your rights and privacy protection configuration options, can be found under the following links:
http://www.google.com/analytics/terms/us.html and
http://www.google.com/analytics/privacyoverview.html.
8. Google Tag Manager
Furthermore, Take 25 Pictures GmbH uses Google Tag Manager. Google Tag Manager enables the management of website tags through an interface. Google Tag Manager implements only tags. This means, that Google Tag Manager does not use cookies and that no personal data is collected from you. Google Tag Manager triggers other tags, which might gather data. However, Google Tag Manager does collect such data. If you have deactivated certain functions on domain or browser level (regarding the deactivation of cookies see above: Sect. 6), the deactivation persist for any respective tracking tags, if these are being implemented by Google Tag Manager.
9. Social PlugIns
Affiliated companies of Take 25 Pictures GmbH operate own online presences on Facebook (“Company Pages”), and our web pages may include links to such Company Pages. When you visit this Company Page, Facebook processes personal data. This might even be the case, if you are not logged in with your Facebook account. The provider of a Company Page receives detailed information from Facebook, but only statistics which consist of aggregated information regarding the use of the respective Company Page. These statistics contain information on e.g. how often the Company Page was visited or how many different users have visited the Company Page and/or accessed and/or evaluated articles on this Company Page. Because of the statistics neither we nor the respective provider of the Company Page can assess which individuals have visited the Company Page, or accessed and/or evaluated certain articles. However, it is obvious – as it is common on Facebook – which Facebook-user has evaluated or commented an article on the Company Page. Futher information on the processing can be found in Facebook’s privacy policy [http://de-de.facebook.com/policy.php#].
10. Data Subject Rights
Under the applicable privacy protection regulations, you may exercise the following rights at any time:
Demand the disclosure of personal data saved about you;
Demand the recitification or erasure of inaccurate personal data;
Demand if applicable processing restrictions of your personal data (in certain legally regulated cases, e.g., required storage periods, your data may be blocked instead of deleted);
Object to the processing of your personal data processed by us due to legitimate interests (Article 6(1) f) of the General Data Protection Regulation);
In the event of processing based on your consent on a contract between you and us you have the right to demand to receiveyou’re the personal data concerning you, which have provided to us in a structured, commonly used and machine-readable format and have the right to demand that we transmit those data to another controller if this is technically feasible (data portability).
Revoke any permission granted to us with future effect. However, this will not affect the legitimacy of any processing performed under your permission prior to its revocation.
You may assert the above-stated rights against us, e.g., by contacting us through the paths described at the end of this Privacy Policy. We will notify any recipients to whom we disclosed your personal data about any correction, deletion or processing restrictions regarding your personal data, unless doing so proves to be impossible or unreasonable.
In case of complaints about the treatment of your personal data, you may also contact the competent regulatory authorities.
11. Retention Period
We will, under adherence to any applicable privacy regulations, delete any personal data saved about you without your involvement if notifying you is no longer necessary to achieve the aims pursued by saving the data or if saving the data is not permitted for other legal reasons. In some legally required cases (e.g., legally required storage periods), your data may be blocked instead of deleted.
In the event of an application, your personal data will be stored / deleted and hard copies will be sent back to you.
If you applied for a specific vacancy, your application data will be stored for up to six months after we informed you about the final decision for this position.
Afterwards your data and the documents you provided will be deleted.
If an employment relationship is entered into with you on the basis of your application or applicable law allows us a further storage of your personal data for specific reasons, your application data will be further processed for the purposes of such employment relationship (Art. 6(1) b) GDPR) or stored, processed and used for a longer period if applicable law allows us to do so. In that event we will inform you respectively prior to such storage, processing or use of your personal data according to the applicable data protection law, where and insofar as you do not already have such information.
12. Data Protection Officer
Should you have any questions about this Privacy Policy or the treatment of your personal data, please do not hesitate to contact our data protection officer at any time, including for requests, suggestions or complaints, as follows:
By mail:
Take 25 Pictures GmbH
Friedrichstr. 14-16
25774 Lunden, Germany
By email:
info@take25pictures.com