We thank you for your interest in our website. The protection of your personal information is very important to us. Below we shall communicate with you in detail about the handling of your data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the user’s consent.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is carried out in accordance with the requirements of the General Data Protection Regulation (GDPR).
Name and Address of Responsible Body
The body responsible with regards to the GDPR is:
Subject To Change GmbH
Name and Address of the Data Protection Officer
Subject To Change GmbH’s Data Protection Officer is:
Rechtsanwälte / Attorneys-at-Law
Unter den Linden 32–34 / 10117 Berlin
T +49 30 21021960
I. Collection of General Data and Information
The Subject To Change GmbH website collects a range of general data, personal data and information each time you or an automated system accesses it. This general data and information is stored in the log files of the server.
The following can be collected:
- the type of browser and version used,
- the operating system used by the accessing system,
- the website from which an accessing system reaches our website,
- the sub websites which are accessed via an accessing system on our website,
- the date and time of access to the website
- an internet protocol (IP) address,
- the internet service provider of the accessing system and
- other similar data and information used in the case of attacks on our information technology systems
When using this data and information, Subject To Change GmbH does not draw conclusions about you and does not collate your data with other personal data of yours.
Rather, this information is needed in order to:
- correctly deliver the contents of our website requested by you,
- optimize the contents of our website as well as the advertising for these,
- ensure the long-term functionality of our information technology systems and the technology of our website, and
- to provide law enforcement agencies with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore statistically evaluated by Subject To Change GmbH and with the aim of increasing data protection and data security in our company with the end goal of ensuring an optimal level of protection for the personal data we process.
II. Data Protection for Applications and in Application Procedure
Subject To Change GmbH collects and processes the personal data of applicants for the purpose of processing the application procedure. Processing may also be carried out electronically. This is particularly the case if an applicant sends corresponding application documents to Subject To Change GmbH by electronic means, for example, by e-mail or via our applicant portal.
If Subject To Change GmbH concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If Subject To Change GmbH does not conclude an employment contract with the applicant, the application documents will be automatically deleted six months after communication of the rejection decision, provided that there are no other legitimate interests of Subject To Change GmbH to the contrary. Other legitimate interests in this sense are, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
If the applicant gives us permission to store the data she has submitted in the applicant pool, we will include this data in our applicant pool for a period of 2 years and then delete it. Only Subject To Change GmbH’s HR staff have access to this data.
II. Subject To Change GmbH Newsletter
If you would like to subscribe to the newsletter offered on our website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data will not be collected or only on a voluntary basis. We use this data exclusively for the dispatch of the requested information and do not pass it on to third parties.
The data entered in the newsletter registration form will be processed exclusively on the basis of your consent (Art. 6 para. 1 letter a GDPR). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example, via the “Unsubscribe” link in the newsletter. The legality of the data processing processes already carried out remains unaffected by the revocation.
The data you provide us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g., e-mail addresses for the member area) remain unaffected by this. You can also revoke the further sending of newsletters by sending an e-mail to email@example.com
III. Data Protection Regulations of Subject To Change GmbH in Connection with the Free Offer of Digital Content
Collected data and purpose of use
We collect the following data from you if you wish to obtain digital content from us, e.g., White Paper, Case Studies, etc…
- Surname: personal user salutation in e-mails
- First name: personal, gender-specific user salutation in e-mails
- Business e-mail address: Confirmation of e-mail address and of the sending of digital content and offers
- Professional title: Adaptation of the sent contents and offers to the user’s role / job title for reasons of relevance
- Phone number (optional): this will be asked in order to be able to contact you if you tick the optional “I would like to be called and learn more about Subject To Change GmbH” checkbox.
Data collection and use
Sending the digital content requested by the user by e-mail:
After submitting the form, we will send you an e-mail in which you can confirm your e-mail address and the download request for the corresponding content by clicking on the confirmation link. The confirmation link then refers you directly to the content requested in the form (e.g., White Paper, eBook, etc.)
Sending other, similar content and offers by e-mail
If you have confirmed your e-mail address as described under number 1, we will send you other e-mails in the course of the following weeks which refer to other, similar digital content and offers from Subject To Change GmbH. These are based on the content already requested, your role, and the size of the company. You can also revoke the future sending of content by sending an e-mail to firstname.lastname@example.org
IV. Participation Conditions for Subject To Change GmbH Events and Training
Data collection and use
The event organizer and/or Subject To Change GmbH requires the participant’s personal data for the planning and execution of events. The participant agrees that his data may be processed and used for the initiation, implementation and follow-up of the event.
This consent applies in particular with regard to the following purposes:
a) Invitation management by e-mail:
- Sending of registration confirmations by e-mail
- Sending of reminders by e-mail before the event
- Sending of additional information or short-term changes to the registered event participants
- Event planning optimization
- Publication of participant lists (incl. names)
- General contract initiation
The following data will be recorded:
- E-mail address
- Surname, first name
- Job title
- Telephone number (optional)
- Image rights
The participants of the event hereby declare their consent (free of charge) for the creation of images and video recordings of their persons during the events and to the use and publication of such images for the purpose of public reporting (in particular, print media or the internet) on the events. This also includes publication on Subject To Change GmbH homepages, Facebook, Instagram, LinkedIn, Google and other social media sites.
Subject To Change GmbH is not liable for third parties using the images for other purposes without their knowledge, in particular by downloading and/or copying
Furthermore, the participant has the right to revoke the consent given to Subject To Change GmbH for processing and use in the future at any time.
V. Rights of Affected Persons
One of the objectives of the GDPR is to protect and clarify the data protection rights of EU citizens and users within the EU. This means that you as a user still have various rights with regard to your data, even if you have already given it to us. These rights are described in more detail below.
If you wish to contact us in connection with these rights, please contact our data protection officer (the contact details can be found under number II) or directly at email@example.com. We will aim to answer your request as quickly as possible, in any case within one month (extensions may be applied to which we are legally entitled). Please note that we may keep records of our communications in order to better resolve any problems you raise.
You have the following rights:
a) Right to confirmation
Every user of our website has the right to request confirmation from us as to whether we are processing his personal data. If the user wishes to make use of this right, he can contact our data protection officer at any time or contact us directly at firstname.lastname@example.org.
b) Right to information
Every user has the right to receive information from us at any time, free of charge, about the personal data stored about him/her as well as a copy of this information. Furthermore, the user can obtain information about the following: purposes of processing
- the categories of personal data to be processed
- the recipients or categories of recipients to whom the personal data have been or are still being disclosed,
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
- the existence of a right of rectification or deletion of personal data concerning him or of a restriction on processing by the responsible party, or of a right of opposition to such processing
- the existence of a right of appeal to a supervisory authority
- if the personal data is not collected from the data subject: All available information about the origin of the data
- the existence of automated decision-making, including profiling in accordance with Article 22 para. 1 and 4 GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.
Furthermore, the user has the right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the user has the right to obtain information about the appropriate guarantees in connection with the transmission. If a user wishes to make use of this right to information, he or she can contact our data protection officer or contact us directly at email@example.com at any time.
c) Right to rectification
Every user has the right to demand the immediate correction of incorrect personal data concerning him. Furthermore, the user has the right, taking into account the purposes of the processing, to request the completion of incomplete personal data, also by means of a supplementary declaration.
If the user wishes to make use of this right to rectification, he can contact our data protection officer or contact us directly at firstname.lastname@example.org at any time.
d) Right to deletion (right to be forgotten)
Every user has the right to demand from us that the personal data concerning her be deleted immediately, provided that one of the following reasons applies and insofar as processing is not necessary:
- the personal data has been collected or otherwise processed for such purposes for which they are no longer necessary.
- the user withdraws his consent on which the processing was based pursuant to Article 6 para. 1 letter a GDPR or Article 9 para. 2 letter a GDPR, and there is no other legal basis for the processing.
- the user objects to the processing in accordance with Article 21 para 1 GDPR and there are no overriding legitimate grounds for the processing, or the person concerned objects to the processing in accordance with Article 21 para. 2 GDPR.
- the personal data has been processed unlawfully.
- the deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which Subject To Change GmbH is subject.
- the personal data was collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.
- If one of the aforementioned reasons applies and a user wishes to have personal data that is stored with us deleted, she can contact our data protection officer or contact us directly at email@example.com at any time.
e) Right to limitation of processing
Every user has the right to request us to limit processing if one of the following conditions is met:
- the accuracy of the personal data is disputed by the user for a period that enables us to verify the accuracy of the personal data.
- the processing is unlawful, the user refuses to delete the personal data and instead requests the limitation of the use of the personal data.
- Subject To Change GmbH no longer needs the personal data for the purposes of processing, but the user needs it to assert, exercise or defend legal claims.
- the user has filed an objection to the processing according to Art. 21 para. 1 GDPR and it has not yet been determined whether Subject To Change GmbH’s justified reasons outweigh those of the user.
- If one of the above conditions is met and the user wishes to request the limitation of personal data stored with us, he can contact our data protection officer or contact us directly at firstname.lastname@example.org at any time.
f) Right to data transferability
Every user has the right to receive the personal data concerning him, which was made available to us by the user, in a structured, current and machine-readable format. Furthermore, she also has the right to transmit this data to another responsible person without our interference, provided that the processing is based on the consent according to Art. 6 para. 1 letter a GDPR, or Art. 9 para. 2 letter a GDPR, or on a contract according to Art. 6 para. 1 letter b GDPR and the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task in the public interest or in the exercise of public authority which has been transferred to us.
In addition, when exercising their right to data transferability pursuant to Art. 20 para. 1 GDPR, the user has the right to ensure that the personal data be transferred directly from one responsible party to another responsible party, insofar as this is technically feasible and provided that the rights and freedoms of other persons are not affected by this.
To assert the right to data transferability, the user can contact our data protection officer or contact us directly at email@example.com at any time.
g) Right to object
Every user has the right to object at any time to the processing of personal data concerning her on the basis of Art. 6 para. 1 letter e or f GDPR for reasons arising from her particular situation.
h) Right to revoke consent under data protection law
Every user has the right to revoke his consent to the processing of personal data at any time.
If a user wishes to exercise his right to revoke his consent, he can contact our data protection officer or contact us directly at firstname.lastname@example.org at any time.
i) Right to appeal to a supervisory authority
The user has the right to file a complaint with the competent local supervisory authority. Details on how to contact the authority can be found here:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Tel.: +49 (0)30 13889-0
Fax: +49 (0)30 2155050
VI. Routine Deletion and Blocking of Personal Data
Subject To Change GmbH processes and stores your personal data only for the period of time necessary to achieve the storage purpose or if this was provided for in laws or regulations to which Subject To Change GmbH is subject.
If the storage purpose ceases to apply or if a storage period prescribed by law expires, the personal data will be routinely deleted or blocked and in accordance with the statutory provisions, provided that there are no storage obligations to the contrary.
VII. Analysis / tracking tools
The tracking measures listed and used by us are based on Art. 6 para. 1 sentence 1 lit. f GDPR. With the tracking measures used, we want to ensure a needs-based design and the continuous optimization of our website. We additionally use the tracking measures to statistically record the use of our website and evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as justified within the meaning of the aforementioned provision.
We implemented a pop-up to inform you, that our website uses tracking. If you agreed with tracking, you can still use the opt-out features described. The respective data processing purposes and data categories can be found in the corresponding tracking tools.
Some of our Internet pages use “cookies”. Cookies do not cause any damage to your computer and do not contain any viruses. Cookies serve to make our website more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.
Such cookies are not only set by Subject To Change GmbH itself but also on its behalf by third parties such as Google, LinkedIn or Facebook. In order to do this, these third-party companies place cookies which record usage data on the user’s computer on behalf of Subject To Change GmbH. This is regarding such data that can be collected, for example, while the user moves around the Subject To Change GmbH website or clicks on advertising.When you access the website from our data protection regulations, cookies are also set which are stored beyond your current visit to the website (your “session”).
Cookies, which are necessary for the execution of the electronic communication process, are stored on the basis of Art. 6 para. 1 letter f GDPR. Subject To Change GmbH has a legitimate interest in the storage of cookies for the technically error-free and optimized provision of its services. As far as other cookies (e.g., cookies for the analysis of your surfing behavior) are stored, these will be treated separately in this data protection policy.
IX. Google Analytics
Insofar as you have given your consent, this website uses Google Analytics, a web analytics service provided by Google Inc. 1600 Amphitheater Parkway Mountain View, CA 94043, USA. Google Analytics is a web analytics service. Web analysis is the surveying, collation and evaluation of data regarding the behavior of visitors to internet sites. Among other things, a web analysis service collects data on which website a user came from (a “referrer”), which subpages of the website were accessed, or how often and for how long a subpage was viewed. A web analysis is mainly used to optimize a website and for cost-benefit analysis of Internet advertising. Use includes the Universal Analytics operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID, thus analyzing the activities of a user across devices.
Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, your IP address will be shortened by Google beforehand within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
Purposes of processing
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator.
The legal basis for the use of Google Analytics is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.
Recipients / categories of recipients
The recipient of the data collected is Google.
Transmission to third countries
The personal data will be transmitted under the EU-US Privacy Shield on the basis of the adequacy decision of the European Commission in the USA. You can get the certificate here.
Duration of data storage
The data sent by us and linked to cookies, user IDs (eg user ID) or advertising IDs will be automatically deleted after 14 months. The deletion of data whose retention period has been reached is done automatically once a month.
Rights of the Affected
You can revoke your consent at any time with future effect by preventing the storage of cookies by setting your browser software accordingly; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.
X. Google Tag Manager
This website uses Google Tag Manager. This service allows website tags to be managed through a single interface. Google Tool Manager only implements tags. This means: no cookies are used and no personal data is collected. Google Tool Manager triggers other tags, which may collect data. However, Google Tag Manager does not access this data. If deactivated at the domain or cookie level, it will remain in effect for all tracking tags as far as they are implemented with the Google Tag Manager.
XI. Google AdWords
Subject To Change GmbH has integrated Google AdWords on this website. Google AdWords is an Internet advertising service that allows advertisers to place ads in both Google’s search engine results and the Google Advertising Network. Google AdWords allows an advertiser to pre-define certain keywords to display an ad in Google’s search engine results only when the user uses the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, ads are distributed on topical websites using an automated algorithm and according to pre-defined keywords.
The operating company for the Google AdWords service is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The purpose of Google AdWords is to promote our website by displaying interest-based advertising on third-party websites and in the search engine results of Google’s search engine and by displaying advertisements on our website.
If a user reaches our website via a Google ad, a so-called conversion cookie will be stored on the user’s information technology system by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the user. If the cookie has not yet expired, the conversion cookie is used to determine whether certain sub-pages, such as the shopping basket of an online shop system, have been called up on our website. The conversion cookie enables both us and Google to track whether a user who has accessed our website via an AdWords ad has generated revenue, that is, completed or canceled a purchase of goods.
The data and information collected through the use of the conversion cookie is used by Google to generate visit statistics for our website. We use these visit statistics to determine the total number of users who have been referred to us via AdWords ads, that is, to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the person concerned.
The conversion cookie is used to store personal information, such as the websites visited by the person concerned. Personal data, including the IP address of the Internet connection used by the person concerned, is therefore transferred to Google in the United States of America each time she visits our Internet pages. This personal data is stored by Google in the United States of America. Google may disclose personal data collected through the technical process to third parties.
The person concerned can prevent the storing of cookies by our website at any time, as already described above, through an appropriate setting on the internet browser used and thus permanently object to the storing of cookies. Use of such an internet browser setting would also prevent Google from storing a conversion cookie on the information technology system of the person concerned. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.
Furthermore, the person concerned has the option to object to interest-based advertising by Google. To do this, the person concerned must access the link http://www.google.de/settings/ads from each of the Internet browsers they use and adjust the required settings there.
We have concluded a data processing contract with Google based on the so-called EU standard contract clauses. More information and the applicable data protection regulations from Google can be obtained at https://www.google.de/intl/de/policies/privacy/.
XII. Google Re-targeting
This website uses Google Inc. retargeting technology (“Google”). This makes it possible to target visitors to our Internet pages specifically with personalized, interest-based advertising. The insertion of the advertising material is based on a cookie-based analysis of the previous user behavior. No personal data is stored. In the case of retargeting technology, a cookie is stored on your computer or mobile device in order to collect anonymous data about your interests and thus to adapt the advertising individually to the stored information. This will give you advertisement that most likely matches your product and information interests. You may object to the setting of advertising cookies permanently by downloading the browser plug-in available at the following link: http://www.google.com/ads/preferences/html/intl/de/plugin/.
XIII. Integration of Third Party Services
Based on our legitimate interests (interest in the analysis, optimization and operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we use content or service offers from third-party providers.
The IP address is required for the presentation and use of this content.
XIV. Google Maps
This website uses the map service Google Maps via an API. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use the functions of Google Maps it is necessary to save your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this website has no influence on this data transmission.
The use of Google Maps is in the interest of creating an appealing representation of our online offers and to ensure that the places indicated by us on the website are easy to find. This represents a legitimate interest within the meaning of Art. 6 para. 1 letter f GDPR.
You can find more information on the handling of user data in Google’s data protection policy: https://www.google.de/intl/de/policies/privacy
XV. Social Media Plugins
Facebook Tracking Pixels
With your consent we use the “tracking pixel” of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This pixel can be used to track user behavior after it has been redirected to our site by clicking on a Facebook ad. This lets us track the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous for us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, about which we inform you according to our knowledge. Facebook can connect this data to their Facebook account and also use the collected information for their own advertising purposes, according to Facebook’s data usage policy. You have the option to prohibit Facebook and its affiliates from displaying advertisements. You can edit the settings for Facebook’s ads using the following link: https://www.facebook.com/ads/website_custom_audiences/.
Facebook Custom Audiences
Our website uses features of the LinkedIn network. Providers is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States. Each time you visit one of our pages that contains LinkedIn features, it will connect to LinkedIn servers. LinkedIn is informed that you have visited our website with your IP address. If you click LinkedIn’s “Recommend Button” and are logged in to your LinkedIn account, LinkedIn will be able to associate your visit to our website. We point out that we as the provider of the pages have no knowledge of the content of the transmitted data and their use by LinkedIn. For more information, see the LinkedIn privacy statement at: https://www.linkedin.com/legal/privacy-policy.
XVI. Contact Form
When contacting us by e-mail or via a contact form, we store the data you provide in order to answer your questions. The data is deleted after storage is no longer required. If there are legal storage obligations, we shall restrict processing. We delete the data arising in this context after storage is no longer necessary, or limit processing if legal storage obligations exist.
XVII. Right of Modification
We reserve the right to change these data protection regulations at any time within the scope of applicable laws.
Subject To Change GmbH
Rosenthaler Straße 72A
10119 Berlin / Germany
As of April 15, 2020