Privacy Policy for Social Networks
In this Privacy Policy, we inform you, in accordance with the provisions of Article 13 of the EU General Data Protection Regulation, about the processing of personal data when you visit and interact with the social media channels listed below. Personal data refers to any data that can be used to personally identify you.
This Privacy Policy applies to the following social media platforms operated by us: Facebook, Instagram, YouTube, LinkedIn, and Xing.
Data Controller (Article 13(1)(a) of the GDPR)
To the extent that we process the data you provide via our social media channels exclusively on our own and determine the purposes and means of processing independently, the controller for data processing within the meaning of the GDPR is:
SINC NOVATION GmbH
Hammerbrücker Straße 3
08223 Falkenstein
Germany
Phone: +49 (0) 37 45.7 64 00-10
Email:contact@sincnovation.com
Website: www.sincnovation.com
Represented by: Niclas Helgers, Jakob Stiels (B.B.A.), and Thomas Meeß
B. Data Protection Officer of SINC NOVATION GmbH
Sebastian Hinderer
CE21 GmbH
Data Protection and AI Officer (TÜV)
IT Security Officer (DGI-AG)
Bergfeldstraße 11 | 83607 Holzkirchen
Phone: +49 157 8507 8716
C. Information Requirements When Collecting Personal Data (Art. 13 GDPR)
I. Facebook and Instagram
(https://www.facebook.com/sincnovation/ and https://www.instagram.com/sincnovation/)
1. Information Requirements Regarding the Collection of Personal Data (Art. 13 GDPR)
In this Privacy Policy, we inform you, in accordance with the provisions of Article 13 of the EU General Data Protection Regulation, about the processing of personal data when you visit and interact with the Facebook page and Instagram profile operated by us. Personal data refers to any data that can be used to personally identify you.
Meta Platforms Ireland Limited (hereinafter “Meta Platforms”) is the provider of both Facebook and Instagram. For this reason, this Privacy Policy applies to our Facebook page and our Instagram profile.
To the extent that the data you submit via our Facebook page and Instagram profile is processed exclusively by Facebook, and Facebook alone determines the purposes and means of processing, the controller for data processing — the provider of Facebook and Instagram in Germany — is:
Meta Platforms Ireland Limited
4 Grand Canal Square
Grand Canal Harbour, Dublin 2
Ireland.
To the extent that the data you submit via our Facebook page and our Instagram profile is processed by both us and Meta Platforms, and we are involved in determining the purposes and means of processing, we and Meta Platforms are jointly responsible pursuant to the judgment of the European Court of Justice of June 5, 2018 in Case C-210/16 (http://curia.europa.eu/juris/document/document.jsf?text=&docid=202543&pageIndex=0&doclang=DE), we and Meta Platforms are joint controllers for data processing within the meaning of Art. 26 of the GDPR. Such joint responsibility applies to the data processing enabled by the operation of our Facebook page and our Instagram profile. This applies in particular to the generation of “Page Insights” and statistics by Meta Platforms, which are then made available to the operator of a Facebook page. Meta Platforms also generates “Page Insights” and statistics for Instagram profiles and makes them available to the Instagram profile operators. Further information on “Page Insights” can be found below in section 2.c. of this statement.
2. Data Protection Officer (Art. 13(1)(b) GDPR)
Data Protection Officer of Meta Platforms Ireland Limited
You can contact the Data Protection Officer of Meta Platforms using a form provided by Meta Platforms: www.facebook.com/help/contact/540977946302970
3. Scope, Purpose, and Legal Basis of Data Processing (Art. 13(1)(c) and (d) of the GDPR)
a. Data Processing by Meta Platforms Ireland Limited
Every time you visit our Facebook page or our Instagram profile (via the link provided on our website or by other means), Meta Platforms processes personal data. Information regarding the processing of personal data by Meta Platforms can be found in the Facebook and Instagram Privacy Policies at: https://de-de.facebook.com/privacy/explanation, https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=Instagram%20Help&bc[1]=Privacy%20and%20Safety%20Center. Additional information regarding the legal bases on which Meta Platforms relies for this data processing can be found at: https://www.facebook.com/about/privacy/legal_bases. Beyond the information provided by Facebook and Instagram, we have no knowledge of the extent to which, for what purposes, for how long, and where data is processed by Meta Platforms; whether and how Meta Platforms fulfills its obligation to delete data; to whom data is disclosed; how data from Meta Platforms is combined with other data and information, analyzed, and marketed, and whether and to what extent Meta Platforms engages in profiling.
In addition, Meta Platforms sets cookies every time you visit our Facebook page or our Instagram profile (via the link provided on our website or by other means). Companies and institutions can integrate Facebook technologies and products into their websites and apps (e.g., social plugins). When you visit websites or use apps provided by companies and organizations that use such Facebook technologies and products, Meta Platforms also use cookies and tracking technologies in those contexts. This enables Meta Platforms to track and analyze your user behavior far beyond Facebook’s own websites. For more information on Meta Platforms’ use of cookies, please see the Facebook and Instagram Cookie Policies at: https://de-de.facebook.com/policies/cookies/, https://help.instagram.com/1896641480634370. You can customize your browser settings to determine whether and which cookies may be stored and when they are deleted. We would like to point out here that you can still visit our Facebook page and our Instagram profile even if your browser blocks cookies.
Meta Platforms processes personal data, sets cookies, and uses tracking technologies regardless of whether you are logged into your Facebook and/or Instagram user account or even have one at all. If you are logged into your Facebook and/or Instagram user account, you allow Meta Platforms to directly associate your user behavior across devices with your personal profile. According to the company, you can prevent this by logging out of your Facebook or Instagram user account.
The provider of Facebook and Instagram in Germany is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The parent company of Meta Platforms Ireland Limited is Meta Platforms Inc., 1 Hacker Way, Menlo Park, California 94025, USA. Personal data and other information are transferred by Meta Platforms to countries within the EU, as well as to the U.S. and other third countries — where data protection standards may be lower than in the EU — and are processed there by Meta Platforms and its partners.
We have no influence over Meta Platforms’ processing of your data or over Meta Platforms’ compliance with applicable data protection regulations.
b. Data Processing by SINC NOVATION GmbH
Please carefully review what personal data you provide to us via Facebook and Instagram. If you wish to prevent Facebook from processing the data you provide, please contact us by other means. You can find our contact information above under Section A of this statement or in the legal notice.
We process your data in connection with our Facebook page and our Instagram profile for communication purposes and, where applicable, to conduct pre-contractual or contractual measures.
We process personal data when you contact us via our Facebook page or Instagram profile and share content such as photos and videos with us, whether by commenting on a post or by sending a message. If you contact us via our Facebook page or Instagram profile, we will process the content of your message as well as any other personal data transmitted in the process. Please note that, in addition to the data and content you actively provide, we may also have access to further information regarding your user profile, your posts, and, for example, “Likes.” Access to this information depends on the privacy settings you have configured in your Facebook/Instagram user account. Facebook and Instagram explain how you can review and change your privacy settings here:
https://www.facebook.com/help/193677450678703/?locale=de_DE and https://help.instagram.com/285881641526716.
We use this data strictly for the specific purpose of communicating with you or processing your request. The legal basis for this data processing is Article 6(1)(f) of the GDPR. Our overriding legitimate interest, as determined through a balancing of interests, is to communicate with you and respond to your inquiries and other requests. To the extent that we are able to do so and provided that we have also processed the data outside of social media platforms (e.g., by sending you an email), we will delete the data you have actively provided once the purpose for processing no longer applies—specifically, after contact with you has been definitively terminated. This does not apply to data stored automatically by Facebook as part of our communication; we have no control over the deletion of this data. Mandatory statutory retention periods remain unaffected.
c. Data Processing by SINC NOVATION GmbH and Instagram/Meta Platforms – Statistics & Page Insights
As mentioned above, we and Facebook are joint controllers for data processing within the meaning of Article 26 of the GDPR in connection with the provision and use of “Page Insights.
“Page Insights” are statistical analyses provided by Facebook to administrators of Facebook Pages and Instagram profiles, which contain evaluations of which individuals or groups interact with the respective Page or profile and the content it contains, and in what ways. “Page Insights,” for example, show us the reach of our page and profile, interaction with our posts, as well as actions taken by visitors, demographic data (e.g., age, gender, location), and other information about visitors, along with the number and type of page views. Facebook uses certain “events”—which consist of data points, such as a user viewing or following our page or profile or commenting on one of our posts—as well as the personal data collected during interactions with our page or profile, which is logged by Facebook servers, to generate “Page Insights.”
Our joint responsibility with Facebook includes the creation of these events and their consolidation into “Page Insights,” which are made available to us as the page operator. The legal basis for this data processing on our part is Article 6(1)(f) of the GDPR. The processing of this data serves to safeguard our legitimate interests—which prevail following a balancing of interests—in optimizing our public image and communication, as well as our marketing and advertising via our Facebook page and Instagram profile, which is made possible by “Page Insights.” As the operator of the page/profile, we do not have access to the personal data processed in connection with events, but only to the aggregated “Page Insights.” The events logged on on Facebook’s servers to generate “Page Insights” are determined exclusively by Facebook and cannot be set up, edited, or otherwise influenced by us as the operators of the Facebook page or Instagram profile.
Pursuant to Article 26(1), second sentence of the GDPR, joint controllers are legally obligated to enter into an agreement that transparently specifies which controller fulfills which data protection obligations under the GDPR. For this reason, Meta Platforms has offered us, as the operator of the Facebook Page, such an agreement on joint controllership in the form of a “Page Insights Addendum Regarding the Controller.” We have agreed to this agreement by continuing to operate our Facebook Page. The agreement is available here:de-de.facebook.com/legal/terms/page_controller_addendum . The agreement stipulates that Meta Platforms is responsible for fulfilling the obligations under the GDPR—including the information obligations under Articles 12 and 13, responding to requests by data subjects to exercise their rights under Articles 15–21 of the GDPR, as well as reporting and notification obligations in the event of a data breach under Articles 33 and 34 of the GDPR—for the processing of “Insights data.” The agreement supplements the Terms of Use www.facebook.com/legal/terms and https://help.instagram.com/581066165581870 and the Guidelines for Pages, Groups, and Events (https://www.facebook.com/policies/pages_groups_events), to which we have agreed in order to operate our Facebook Page and our Instagram profile.
For more information on “Page Insights,” please visit www.facebook.com/legal/terms/information_about_page_insights_data. With regard to “Page Insights,” we have no knowledge beyond the information provided above regarding the extent to which, for what purposes, for how long, and where data is stored by Facebook; whether and how Facebook fulfills its obligation to delete data; to whom data is disclosed; and how data is combined, analyzed, and marketed, and whether and to what extent Facebook engages in profiling.
You can object to the processing of your data for the purposes of personalized advertising by Facebook at any time by using the opt-out option in your Facebook/Instagram user account or by contacting Facebook/Instagram. For more information and choices regarding personalized advertising by Facebook, please visit: www.facebook.com/about/ads. To learn more about the choices you generally have regarding the processing of information and the tracking of your online activities by advertisers and other online services for the purpose of personalized advertising, you can visit the following websites:
Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance at http://www.aboutads.info/
European Digital Advertising Alliance at http://youronlinechoices.eu/.
Your rights as a data subject are outlined in Section D.
II. LinkedIn
(https://de.linkedin.com/company/sinc-novation-gmbh)
1. Information Requirements Regarding the Collection of Personal Data
In accordance with the provisions of Article 13 of the EU General Data Protection Regulation (GDPR), we hereby inform you about the processing of personal data when you visit and interact with the LinkedIn account we operate. Personal data refers to any data that can be used to personally identify you.
2. Data Controller (Art. 13(1)(a) GDPR)
To the extent that we process the data you submit via our LinkedIn account exclusively on our own and determine the purposes and means of processing independently, the data controller for data processing within the meaning of the GDPR is the entity named in Section A.
To the extent that the data you submit via our LinkedIn account is processed exclusively by LinkedIn, and LinkedIn alone determines the purposes and means of such processing, the controller for data processing within the meaning of the GDPR is:
LinkedIn Ireland Unlimited Company
Wilton Place
Dublin, Ireland.
Data Protection Officer (Art. 13(1)(b) of the GDPR)
You can find the Data Protection Officer of SINC NOVATION GmbH under Section B.
LinkedIn Data Protection Officer
You can contact LinkedIn’s Data Protection Officer using a form provided by LinkedIn:
https://www.linkedin.com/help/linkedin/ask/TSO-DPO.
3. Scope, Purpose, and Legal Basis of Data Processing (Art. 13(1)(c) and (d) of the GDPR)
a) Data Processing by LinkedIn
Personal data and other information are transferred by LinkedIn to countries within the EU. “For years, LinkedIn has relied on overlapping safeguards for data transfers in accordance with the Standard Contractual Clauses (SCCs) and the legal Privacy Shield framework. Although this court ruling invalidates the use of the Privacy Shield, the Standard Contractual Clauses remain valid, and LinkedIn continues to transfer data from the EU, the EEA, and Switzerland in accordance with them.” (https://www.linkedin.com/help/linkedin/answer/62533). Information on the processing of personal data by LinkedIn can be found in LinkedIn’s Privacy Policy at: https://de.linkedin.com/legal/privacy-policy. Beyond the information provided by LinkedIn, we have no knowledge of the extent to which, for what purposes, for how long, and where LinkedIn processes data; whether and how LinkedIn fulfills its obligation to delete data; to whom data is disclosed; or how LinkedIn combines data with other data.
b) Data Processing by SINC NOVATION GmbH
We process your data in connection with our LinkedIn accounts for communication purposes and, where applicable, to conduct pre-contractual or contractual measures.
We process personal data when you contact us via our LinkedIn account, e.g., by sending a direct message. If you contact us via our accounts, we will process the content of your message as well as any other personal data transmitted in the process. Please note that, in addition to the data and content you actively provide, we may also have access to further information regarding your user profile, your posts, and, for example, “Likes.” Access to this information depends on the privacy settings you have configured in your user account.
We use this data strictly for the specific purpose of communicating with you or processing your request. The legal basis for this data processing is Article 6(1)(f) of the GDPR. Our overriding legitimate interest, as determined through a balancing of interests, is to communicate with you and respond to your inquiries and other requests. To the extent that we are able to do so and provided that we have also processed the data outside of LinkedIn (e.g., by sending you an email), we will delete the data you actively provided once the purpose for processing no longer applies—specifically, after contact with you has been definitively terminated. This does not apply to data stored automatically by LinkedIn as part of our communication; we have no control over the deletion of this data. Mandatory statutory retention periods remain unaffected.
c) Joint Control
SINC NOVATION GmbH and LinkedIn share joint responsibility for data processing pursuant to Article 26 of the GDPR in connection with the provision of our services, the analysis of user behavior, and the measurement and optimization of advertising.
For these purposes, LinkedIn collects data from logged-in users and other visitors using cookies, pixels, local storage, and other tracking technologies. In addition, user behavior is tracked through emails sent by monitoring which emails are opened, when they are opened, and which links within the emails are clicked. We do not use any analytics tools on these platforms that provide us with statistical analyses of user interaction. The legal basis for this data processing on our part is Article 6(1)(f) of the GDPR. Data processing is based on your consent, which you can provide when visiting the websites. You may revoke your consent at any time with future effect.
LinkedIn does not currently provide an agreement on joint controllership within the meaning of Article 26(1), second sentence, of the GDPR, which specifies which controller fulfills which data protection obligations under the GDPR.
For more information on LinkedIn’s tracking technologies, please visit https://www.linkedin.com/help/linkedin/answer/111735. With regard to the tracking technologies of both platforms, we have no knowledge beyond the information provided above regarding the extent to which, for what purposes, for how long, and where data is stored; whether and how the obligation to delete data is fulfilled; to whom data is disclosed; and how data from LinkedIn is combined with other data and information, analyzed, and marketed, and whether and to what extent LinkedIn engages in profiling.
Your rights as a data subject can be found under Section D.
III. YouTube
(https://www.youtube.com/@SINCNOVATIONGroup)
In the following, we provide you with information in accordance with the provisions of Article 13 of the EU General Data Protection Regulation regarding the processing of personal data when you visit and interact with the YouTube channel we operate. Personal data refers to any data that can be used to personally identify you.
YouTube is provided in Germany by Google Ireland Limited. To the extent that the data you submit via our YouTube channel is processed exclusively by YouTube/Google Ireland, and YouTube/Google Ireland alone determines the purposes and means of the processing, the controller for data processing within the meaning of the GDPR is Google Ireland Limited Gordon House Barrow Street, Dublin 4 Ireland. To the extent that the data you submit via our YouTube channel is processed by both us and YouTube/Google Ireland, and we are involved in determining the purposes and means of processing, we and YouTube/Google Ireland are joint controllers for data processing within the meaning of Article 26 of the GDPR. Such joint responsibility exists, according to the judgment of the European Court of Justice of June 5, 2018, in Case C-210/16 (http://curia.europa.eu/juris/document/document.jsf?text=&docid=202543&pageIndex=0&doclang=DE) for data processing enabled by the operation of a Facebook page. This applies in particular to the generation of “Page Insights” and statistics by Facebook, which are then made available to the operator of a Facebook page. Data processing is also enabled through the operation of our YouTube channel. For YouTube channels, Google collects data and uses “YouTube Analytics” to generate statistics from it. Google makes these statistics available to the YouTube channel operators. Therefore, we assume that in this case as well, we and Google share joint responsibility. Further information on statistics and “YouTube Analytics” can be found below in section 3.c. of this statement.
1. Data Protection Officer (Art. 13(1)(b) GDPR)
a. Data Protection Officer of SINC NOVATION GmbH
See Section B
b. Data Protection Officer of Google Ireland
You can contact Google Ireland’s Data Protection Officer using a form provided by Google Ireland:support.google.com/policies/contact/general_privacy_form .
2. Scope, Purpose, and Legal Basis of Data Processing (Art. 13(1)(c) and (d) of the GDPR)
a. Data Processing by Google Ireland
Every time you visit our YouTube channel (via the link provided on our website or by other means) on the YouTube website, YouTube/Google processes personal data. Information regarding the processing of personal data by YouTube/Google can be found in Google’s Privacy Policy at: policies.google.com/privacy. Beyond this information provided by Google, we have no knowledge of the extent to which, for what purposes, for how long, and where data is processed by YouTube/Google; whether and how YouTube/Google fulfills its obligation to delete data; to whom data is disclosed; how data from YouTube/Google is combined with other data and information, analyzed, and marketed; or whether and to what extent profiling is carried out by YouTube/Google.
In addition, every time you visit our YouTube channel (via the link provided on our website or by other means), YouTube/Google sets cookies on the YouTube websites. Companies and institutions can integrate Google technologies and products into their websites and apps (e.g., social plugins, Google Analytics, Google Maps). When you visit websites or use apps provided by companies and institutions that use such Google technologies or products, Google also sets cookies in these instances. This enables Google to track and analyze your user behavior far beyond the YouTube and Google websites. For more information on YouTube/Google’s use of cookies, please see Google’s Cookie Policy at:policies.google.com/technologies/cookies . You can customize your browser settings to determine whether and which cookies may be stored and when they are deleted. We would like to point out that you can still visit our YouTube channel even if your browser blocks cookies.
Google’s processing of personal data and the setting of cookies occur regardless of whether you are logged into your YouTube or Google user account or even have one at all. If you are logged into your YouTube or Google user account, you allow Google to directly associate your user behavior across devices with your personal profile. According to the company, you can prevent this by logging out of your YouTube/Google user account.
The provider of YouTube in Germany is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. YouTube’s parent company is Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043. Personal data and other information are transferred by Google to countries within the EU, as well as to the U.S. and other third countries—where data protection standards may be lower than in the EU—and are processed there by Google and its partners.
In addition to the YouTube/Google Data and Cookie Policy listed above, your and our use of YouTube is governed by the Terms of Service (https://www.youtube.com/static?template=terms), the Community Guidelines (https://www.youtube.com/intl/de/about/policies/#community-guidelines), as well as other guidelines and notices regarding security and copyright (https://support.google.com/youtube/topic/9223153).
We have no influence over how YouTube/Google processes your data or over Google’s compliance with applicable data protection regulations.
b. Data Processing by SINC NOVATION GmbH
Please carefully review what personal data you provide to us via YouTube in the future. If you wish to prevent YouTube/Google from processing the data you provide, please contact us through other means. You can find our contact information above under Section A of this statement or in the legal notice.
We process your data in connection with our YouTube channel for communication purposes and, where applicable, to conduct pre-contractual or contractual measures.
We process personal data when you contact us via our YouTube channel, for example, by commenting on a post. If you contact us via our YouTube channel, we will process the content of your message as well as any other personal data transmitted in the process. Please note that, in addition to the data and content you actively provide, we may also have access to further information regarding your user profile, your posts, and, for example, “Likes.” Access to this information depends on the privacy settings you have configured in your YouTube user account. YouTube/Google explains how you can review and change your privacy and data protection settings here:support.google.com/youtube/answer/9315727 ,support.google.com/policies/answer/9581826 .
We use this data strictly for the specific purpose of communicating with you or processing your request. The legal basis for this data processing is Article 6(1)(f) of the GDPR. Our overriding legitimate interest, as determined through a balancing of interests, is to communicate with you and respond to your inquiries and other requests. To the extent that we are able to do so and provided that we have also processed the data outside of YouTube (e.g., by sending you an email), we will delete the data you have actively provided once the purpose for processing no longer applies—specifically, after contact with you has been definitively terminated. This does not apply to data stored automatically by YouTube/Google as part of our communication; we have no control over the deletion of this data. Mandatory statutory retention periods remain unaffected.
c. Data Processing by SINC NOVATION GmbH and Google Ireland – YouTube Analytics & Statistics
As mentioned above, we assume that we and YouTube are joint controllers for data processing within the meaning of Art. 26 of the GDPR in connection with the creation and use of statistics or “YouTube Analytics.”
“YouTube Analytics” refers to statistical analyses provided by YouTube/Google to YouTube channel operators, which include evaluations of which individuals or groups interact with the respective YouTube channel and its content, and in what ways. “YouTube Analytics” show us, for example, the reach of our YouTube channel, user interaction with our posts (viewing, commenting, subscribing), and demographic data (e.g., age, gender, location) of visitors, as well as the number of views our videos receive. To generate “YouTube Analytics” statistics, YouTube/Google uses certain events—such as watching or commenting on one of our videos or subscribing to our channel—as well as the personal data collected during interactions with our YouTube channel, which is logged by Google servers.
Our joint responsibility with YouTube/Google includes the collection and consolidation of data for “YouTube Analytics” statistics for our YouTube channel, which are provided to us by YouTube/Google. The legal basis for this data processing on our part is Article 6(1)(f) of the GDPR. The processing of this data serves to safeguard our legitimate interests—which prevail following a balancing of interests—in optimizing our public image and communication, as well as our marketing and advertising via our YouTube channel, which is made possible by “YouTube Analytics.”
YouTube and Google currently do not provide an agreement on joint controllership within the meaning of Article 26(1), second sentence, of the GDPR, which specifies which controller fulfills which data protection obligations under the GDPR.
For more information on “YouTube Analytics,” please visit support.google.com/youtube/topic/9257532. With regard to statistics and “YouTube Analytics,” we have no knowledge beyond the information provided above regarding the extent to which, for what purposes, for how long, and where data is stored by YouTube/Google; whether and how YouTube/Google fulfills its obligation to delete data, to whom data is disclosed, and how data from YouTube/Google is combined with other data and information, analyzed, and marketed, as well as whether and to what extent YouTube/Google engages in profiling.
Your rights as a data subject can be found under Section D.
IV. Xing
(https://www.xing.com/pages/s-ncnovationgmbh)
4. Information Requirements Regarding the Collection of Personal Data (Art. 13 GDPR)
In the following, we provide you with information in accordance with the provisions of Article 13 of the EU General Data Protection Regulation regarding the processing of personal data when you visit and interact with the Xing account we operate. Personal data refers to any data that can be used to personally identify you.
1. Data Protection Officer (Art. 13(1)(b) GDPR)
Xing’s Data Protection Officer
You can contact Xing’s Data Protection Officer using a form provided by Xing: https://www.xing.com/support/contact/security/data_protection
Data Protection Officer of SINC NOVATION GmbH
Please refer to Section B for the contact information of our Data Protection Officer.
Scope, Purpose, and Legal Basis of Data Processing (Art. 13(1)(c) and (d) of the GDPR)
d. Data Processing by Xing
Xing transfers personal data and other information to countries within the EU. For information on Xing’s processing of personal data, please see Xing’s Privacy Policy at: https://privacy.xing.com/de/datenschutzerklaerung. Beyond this information provided by Xing, we have no knowledge of the extent to which, for what purposes, for how long, and where Xing processes data; whether and how Xing fulfills its obligation to delete data; to whom data is disclosed; or how Xing combines data with other data.
e. Data Processing by SINC NOVATION GmbH
We process your data in connection with our Xing account for communication purposes and, where applicable, to conduct pre-contractual or contractual measures. We process personal data when you contact us via our Xing account, e.g., by sending a direct message. If you contact us via our account, we will process the content of your message as well as any other personal data transmitted in the process. Please note that, in addition to the data and content you actively provide, we may also have access to further information regarding your user profile, your posts, and, for example, “Likes.” Access to this information depends on the privacy settings you have configured in your user account. We use the data strictly for the specific purpose of communicating with you or processing your request. The legal basis for this data processing is Article 6(1)(f) of the GDPR. Our overriding interest, as determined through a balancing of interests, is to communicate with you and respond to your inquiries and other requests. To the extent that we are able to do so and provided that we have also processed the data outside of Xing (e.g., by sending you an email), we will delete the data you have actively provided once the purpose for processing no longer applies—specifically, after contact with you has been definitively terminated. This does not apply to data stored automatically by Xing as part of our communication; we have no control over the deletion of this data. Mandatory statutory retention periods remain unaffected.
f. Data Processing by SINC NOVATION GmbH and Xing—Statistics & Page Insights
SINC NOVATION GmbH and Xing share joint responsibility for data processing pursuant to Article 26 of the GDPR in connection with the provision of our services, the analysis of user behavior, and the measurement and optimization of advertising. For these purposes, Xing collects data from logged-in users and other visitors using cookies, pixels, local storage, and other tracking technologies. In addition, user behavior is tracked through emails sent by monitoring which emails are opened, when they are opened, and which links within the email are clicked. We do not use any analytics tools on the platforms that provide us with statistical analyses of user interaction. The legal basis for this data processing on our part is Article 6(1)(a) of the GDPR. Data processing is based on your consent, which you can provide when visiting the websites. You may revoke your consent at any time with future effect. Xing does not currently provide an agreement on joint controllership within the meaning of Article 26(1), sentence 2 of the GDPR, which specifies which controller fulfills which data protection obligations under the GDPR. For more information on Xing’s tracking technologies, please visit https://privacy.xing.com/de/datenschutzerklaerung/informationen-die-wir-auf-grund-ihrer-nutzung-von-xing-automatisch-erhalten. With regard to these tracking technologies, we have no knowledge beyond the information provided above regarding the extent to which, for what purposes, for how long, and where data is stored; whether and how the obligation to delete data is fulfilled; to whom data is disclosed; how Xing combines, analyzes, and markets data with other data and information; and whether and to what extent Xing engages in profiling.
Your rights as a data subject are set forth in Section D.
D. Your Rights as a Data Subject Pursuant to Art. 13(2)(a), (b), (c), and (d) of the GDPR
The General Data Protection Regulation (GDPR) provides individual citizens with various options to review and influence how their personal data is managed. As a data subject affected by the processing of personal data, you have the following specific rights:
a. Right of access pursuant to Article 15 of the GDPR
b. Right to rectification pursuant to Article 16 of the GDPR
c. Right to erasure pursuant to Article 17 of the GDPR
d. Right to restriction of processing pursuant to Art. 18 of the GDPR
e. Right to data portability pursuant to Art. 20 of the GDPR
f. Right to withdraw consent (with future effect) pursuant to Article 7(3) of the GDPR
Right to object to processing pursuant to Article 21 of the GDPR
If we process your personal data to safeguard our legitimate interests, which prevail following a balancing of interests, you have the right to object to the processing at any time on grounds relating to your particular situation.
We will then no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.
If personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
Please note the following:
If the rights listed above concern the processing of data for which we are the sole controller within the meaning of data protection law, you may exercise these rights by contacting us using the contact information provided in Section A of this statement. However, if the rights listed above concern the processing of data for which the providers of the aforementioned social networks are solely or jointly responsible with us under data protection law, we ask that you contact the respective entities listed above directly. This applies in particular to exercising your rights regarding data processing for the creation of “Page Insights.” You can also find information on how to contact the data protection officers of the providers of the aforementioned social networks in the individual sections of this statement under the heading “Data Protection Officer of.”
Right to File a Complaint with the Competent Supervisory Authority Pursuant to Art. 77 of the GDPR
In addition to the rights listed above, and without prejudice to any other legal remedy, you have the right to lodge a complaint with a local data protection supervisory authority. You may submit a complaint regarding the processing of data for which we are the data controller—either alone or jointly with the social media providers—to the data protection supervisory authority in your state. You can find the relevant contact information at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.
You may also contact the lead data protection supervisory authority regarding a complaint concerning the processing of data for which the aforementioned providers are solely or jointly responsible under data protection law. The competent authority is:
For YouTube, LinkedIn, Instagram, and Facebook:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Phone: +353 87 103 0813, +353 87 361 7984
Online contact form: www.dataprotection.ie/en/contact/how-contact-us
Website: www.dataprotection.ie
For Xing:
Free and Hanseatic City of Hamburg
The Hamburg Commissioner for Data Protection and Freedom of Information
Prof. Dr. Johannes Caspar
Ludwig-Erhard-Str. 22, 7th Floor, 20459 Hamburg
Tel.: 040 / 428 54 – 4040
Fax: 040 / 428 54 – 4000
Data Protection Authority in Saxony:
Saxony Data Protection and Transparency Commissioner
Dr. Juliane Hundert
Maternistraße 17, 01067 Dresden
Phone: +49 351 85471-101