Privacy Policy – ctrl-up

1. Data Protection at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data refers to any data by which you can be personally identified. Detailed information on data protection can be found in our Privacy Policy below.

Data Collection on This Website

Who is responsible for data collection?

Data processing on this website is carried out by the website operator. Contact details can be found in the section “Information on the Controller” in this Privacy Policy.

How do we collect your data?

Some data is collected when you provide it to us — for example, information entered into a contact form.

Other data is collected automatically or with your consent when visiting the website through our IT systems. This mainly includes technical data (e.g., browser type, operating system, time of page access). This data is collected automatically as soon as you access this website.

What do we use your data for?

Some of the data is collected to ensure error-free website functionality. Other data may be used to analyze user behavior.

What rights do you have regarding your data?

You have the right to obtain, free of charge, information about the origin, recipients, and purpose of your stored personal data at any time. You also have the right to request rectification or erasure (deletion) of this data.

If you have given consent to data processing, you may withdraw it at any time with effect for the future. You also have the right to request restriction of processing under certain circumstances and to lodge a complaint with the competent supervisory authority.

Analytics Tools and Third-Party Tools

When visiting this website, your browsing behavior may be statistically analyzed, primarily using analytics programs.

Detailed information can be found in the full Privacy Policy below.

2. Hosting

We host the content of our website with the following provider:

External Hosting

This website is hosted externally. Personal data collected on this website is stored on the servers of the hosting provider. This may include IP addresses, contact requests, metadata and communication data, contract data, contact details, names, website access data, and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services (Art. 6(1)(f) GDPR).

If consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG. Our hosting provider processes your data only to the extent necessary to fulfill its service obligations and in accordance with our instructions.

Hosting Provider:

Hetzner Online GmbH
Industriestr. 25
91710 Gunzenhausen
Germany
Tel.: +49 (0)9831 505-0
Fax: +49 (0)9831 505-3

3. General Information and Mandatory Notices

Data Protection

We treat your personal data as confidential and process it in accordance with applicable data protection laws and this Privacy Policy.

Please note that data transmission over the Internet (e.g., via email communication) may have security vulnerabilities. Complete protection against third-party access is not possible.

Controller

The controller responsible for data processing on this website is:

ctrl-up GmbH

represented by its managing director:

Dirk Stobbe
Scharfe Lanke 109–131
13595 Berlin
Germany

Phone: +49 30 2089899-0 | Email: info@ctrl-up.com

Storage Duration

Unless a more specific storage period is specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will take place once these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have given your consent to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data pursuant to Art. 9 para. 1 GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or to access to information on your terminal device (e.g., via device fingerprinting), data processing is additionally carried out on the basis of Section 25 para. 1 TDDDG. Consent may be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data insofar as this is necessary for compliance with a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The specific legal bases applicable in each individual case are set out in the following paragraphs of this Privacy Policy. You can withdraw your consent at any time with effect for the future.

Notice on Data Transfers to Third Countries Without an Adequate Level of Data Protection and on Transfers to US Companies Not Certified Under the DPF

Among other things, we use tools provided by companies based in third countries that do not provide an adequate level of data protection under data protection law, as well as US-based tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are active, your personal data may be transferred to and processed in these countries. Please note that in third countries without an adequate level of data protection, a level of data protection comparable to that in the EU cannot be guaranteed.
We note that the United States is generally considered a secure third country that provides a level of data protection comparable to that of the EU. Accordingly, data transfers to the United States are permissible if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or provides appropriate additional safeguards. Information on transfers to third countries, including the recipients of data, can be found in this Privacy Policy.

Recipients of Personal Data

In the course of our business activities, we cooperate with various external parties. In some cases, this requires the transfer of personal data to such external parties. We only disclose personal data to external parties if this is necessary for the performance of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 para. 1 lit. f GDPR, or if another legal basis permits the data transfer. When using data processors, we disclose personal data of our customers only on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You may withdraw any consent you have already given at any time. The lawfulness of data processing carried out prior to the withdrawal remains unaffected by the withdrawal.

Right to Object to Data Collection in Specific Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL THEREAFTER NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to receive the data that we process automatically on the basis of your consent or in fulfillment of a contract, in a commonly used, machine-readable format, either to yourself or to a third party. If you request the direct transfer of the data to another controller, this will only be carried out insofar as it is technically feasible.

Access, Rectification and Erasure

Within the framework of the applicable legal provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients, and the purpose of the data processing and, where applicable, a right to rectification or erasure of such data. For this purpose, as well as for further questions regarding personal data, you may contact us at any time.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing applies in the following cases:

If you contest the accuracy of your personal data stored by us, we usually require time to verify this. For the duration of the verification, you have the right to request restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you may request restriction of data processing instead of erasure.
If we no longer need your personal data, but you require it for the establishment, exercise or defense of legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21 para. 1 GDPR, a balancing of interests between your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request restriction of the processing of your personal data.
If you have restricted the processing of your personal data, such data – apart from being stored – may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the website operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the change in the browser address line from “http://” to “https://” and by the lock symbol in your browser bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Cookies

Our websites use so-called “cookies.” Cookies are small data packages and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your terminal device. Session cookies are automatically deleted after your visit ends. Persistent cookies remain stored on your terminal device until you delete them yourself or automatic deletion occurs via your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services provided by third-party companies within websites (e.g., cookies for processing payment services).

Cookies serve various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.

Cookies that are required for carrying out the electronic communication process, for providing certain functions requested by you (e.g., for the shopping cart function) or for optimizing the website (e.g., cookies for measuring web audience reach) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of such consent (Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TDDDG); consent may be revoked at any time.

You may configure your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for specific cases or in general, and activate automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this Privacy Policy.

Consent with Borlabs Cookie

Our website uses the consent technology of Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in compliance with data protection regulations. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter “Borlabs”).

When you enter our website, a Borlabs cookie is stored in your browser in which the consents you have given or the withdrawal of such consents are stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected will be stored until you request us to delete it, delete the Borlabs cookie yourself, or the purpose for data storage no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at:
https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

The use of the Borlabs Cookie consent technology takes place in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.

Contact Form

If you send us inquiries via the contact form, the information you provide in the inquiry form, including the contact details you enter there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We will not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR if your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent may be revoked at any time.

The data you enter in the contact form will remain with us until you request its deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your inquiry has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Inquiries by Email, Telephone or Telefax

If you contact us by email, telephone or telefax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of handling your request. We will not pass on this data without your consent.

The data you send to us via contact inquiries will remain with us until you request its deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

The processing is based on Article 6(1)(b) GDPR (contract-related inquiries) or Article 6(1)(f) GDPR (legitimate interest in processing inquiries).

5. Plugins and Tools

Google Maps

This website uses the map service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. This service enables us to integrate map material on our website.

To use the functions of Google Maps, it is necessary to store your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this website has no influence on this data transfer. If Google Maps is activated, Google may use Google Fonts for the purpose of uniform display of fonts. When accessing Google Maps, your browser loads the required web fonts into its browser cache in order to correctly display texts and fonts.

The use of Google Maps is in the interest of an appealing presentation of our online offers and the easy findability of the locations indicated by us on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ und https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

Further information on the handling of user data can be found in Google’s Privacy Policy: https://policies.google.com/privacy?hl=de.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Any company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is used to verify whether data entered on this website (e.g., in a contact form) is entered by a human or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g., IP address, time spent by the website visitor on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitors are not informed that an analysis is taking place.

The storage and analysis of the data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offerings against abusive automated spying and SPAM. If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Further information on Google reCAPTCHA can be found in Google’s Privacy Policy and Terms of Service at the following links:
https://policies.google.com/privacy?hl=de und https://policies.google.com/terms?hl=de.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Any company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active

Wordfence

We have integrated Wordfence on this website. The provider is Defiant Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).

Wordfence is used to protect our website against unauthorized access or malicious cyberattacks. For this purpose, our website establishes a permanent connection to the servers of Wordfence so that Wordfence can compare its databases with the access activity on our website and block it if necessary.

The use of Wordfence is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in ensuring the most effective protection possible of its website against cyberattacks. If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.

6. eCommerce and Payment Providers

Processing of Customer and Contract Data

We collect, process and use personal customer and contract data for the establishment, content design and modification of our contractual relationships. We collect, process and use personal data concerning the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill the user. The legal basis for this is Art. 6 para. 1 lit. b GDPR.

The collected customer data will be deleted after completion of the order or termination of the business relationship and after expiry of any applicable statutory retention periods. Statutory retention periods remain unaffected.

7. Our Own Services

Handling of Applicant Data

We offer you the opportunity to apply to us (e.g., by email, by post or via an online application form). In the following, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that the collection, processing and use of your data will be carried out in compliance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

Scope and Purpose of Data Collection

If you send us an application, we process your associated personal data (e.g., contact and communication data, application documents, notes taken during interviews, etc.) insofar as this is necessary for the decision on the establishment of an employment relationship. The legal basis for this is Section 26 BDSG under German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. Consent may be revoked at any time. Your personal data will only be passed on within our company to persons involved in processing your application.

If the application is successful, the data you have submitted will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship.

Data Retention Period

If we are unable to offer you a position, if you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). After that, the data will be deleted and physical application documents destroyed. Retention serves in particular as evidence in the event of a legal dispute. If it is apparent that the data will be required after the expiry of the 6-month period (e.g., due to a pending or threatened legal dispute), deletion will only take place once the purpose for further retention no longer applies.

Longer retention may also take place if you have given corresponding consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations prevent deletion.