PRIVACY POLICY

In this privacy policy we inform you about the processing of personal data when using our website.

Personal data is information that relates to an identified or identifiable person. This includes, above all, information that allows conclusions to be drawn about your identity, for example your name, your telephone number, your address or e-mail address. Statistical data that we collect, for example, when you visit our website and that cannot be linked to your person do not fall under the concept of personal data.

Content of this privacy policy

  1. Contact person
  2. Data processing on our website
    2.1 Calling up our website / access data
    2.2 Contacting us
    2.3 Applications
  3. Use of cookies and comparable technologies
    3.1 Legal basis and revocation
    3.2 Necessary tools
    3.3 Analysis tools
    3.4 Marketing tools
  4. Online presence in social networks
  5. Transfer of data
  6. Data transfer to third countries
  7. Storage period
  8. Your rights, in particular revocation and objection
  9. Changes to the privacy policy

1. Contact person

The contact person and so-called controller for the processing of your personal data when visiting this website within the meaning of the EU General Data Protection Regulation (GDPR) is.

Turbine Kreuzberg GmbH
Prinzessinnenstr. 19/20
10969 Berlin

Phone: +49 30 28 47 26 40 25
fax: +49 30 28 47 26 40 75

datenschutz@turbinekreuzberg.com

Data Protection Officer

heyData GmbH
Kantstraße 99
10627 Berlin

info@heydata.eu

For all questions regarding data protection in connection with our services or the use of our website, you can also contact our data protection officer at any time. She can be reached at the above postal address and at the e-mail address given above (keyword: "Attn. Data Protection Officer"). We expressly point out that if you use this e-mail address, the contents will not be exclusively noted by our data protection officer. Therefore, if you wish to exchange confidential information, please first contact us directly via this e-mail address.

2. Data processing on our website

2.1 Calling up our website / access data

Each time you use our website, we collect the access data that your browser automatically transmits to enable you to visit the website. The access data includes in particular:

  • IP address of the requesting device,
  • date and time of the request,
  • Address of the website called up and the requesting website,
  • information about the browser used and the operating system,
  • online identifiers (e.g. device identifiers, session IDs).

The data processing of this access data is necessary to enable the visit of the website and to ensure the permanent functionality and security of our systems. The access data is also temporarily stored in internal log files for the purposes described above, in order to compile statistical information about the use of our website, to further develop our website with regard to the usage habits of our visitors (e.g. if the proportion of mobile devices used to access the pages increases) and to generally maintain our website administratively.
The legal basis is Art. 6 para. 1 p. 1 lit. b DSGVO, if the page view occurs in the course of the initiation or execution of a contract, and otherwise Art. 6 para. 1 p. 1 lit. f DSGVO due to our legitimate interest in the permanent functionality and security of our systems.
The log files are stored for 7 days and archived after subsequent anonymization.

2.2 Contacting

You have various options for contacting us. This includes contacting us by e-mail or telephone. In this context, we process data exclusively for the purpose of communicating with you.
The legal basis is Art. 6 para. 1 p. 1 lit. b DSGVO, insofar as your information is required to answer your inquiry or to initiate or execute a contract, and otherwise Art. 6 para. 1 p. 1 lit. f DSGVO due to our legitimate interest that you contact us and we can answer your inquiry. We only make promotional telephone calls if you have given your consent for this. If you are not an existing customer, we will also send you promotional e-mails only on the basis of your consent. The legal basis in these cases is Art. 6 para. 1 p. 1 lit. a DSGVO.
The data collected when we use it will be deleted after we have fully processed your request, unless we still need your request to fulfill contractual or legal obligations (see Section 7 "Storage period").

2.3 Applications

You can apply for open positions. For this purpose, we use the applicant management system of Personio. The purpose of the data collection is the selection of applicants for the possible establishment of an employment relationship. For the receipt and processing of your application, we collect the following data in particular: First and last name, e-mail address, application documents (e.g. references, resume), date of earliest possible job start and salary requirement. The legal basis for processing your application documents is Art. 6 para. 1 p. 1 lit. b and Art. 88 para. 1 DSGVO in conjunction with Section 26 para. 1 p. 1 BDSG.

3. Use of cookies and comparable technologies

This website uses cookies and comparable technologies (collectively "tools"), which are either provided by ourselves or by third parties.

A cookie is a small text file that is stored on your device by the browser. Cookies are not used to run programs or download viruses onto your computer. Comparable technologies are in particular web storage (local / session storage), fingerprints, tags or pixels. Most browsers are set by default to accept cookies and similar technologies. However, you can usually adjust your browser settings so that cookies or comparable technologies are rejected or only stored with your prior consent. If you refuse cookies or similar technologies, not all of our offers may function properly for you.
In the following, the tools we use are listed according to category. In particular, we inform you about the providers of the tools, the storage period of the cookies and the transfer of data to third parties. We also explain in which cases we obtain your voluntary consent to use the tools and how you can revoke this consent.

If - even despite the greatest care - the information in the cookie banner contradicts that in this privacy policy, the information in this privacy policy takes precedence.

3.1 Legal basis and revocation

3.1.1 Legal basis

We use tools necessary for website operation on the basis of our legitimate interest pursuant to Art. 6 (1) p. 1 lit. f DSGVO to enable you to use our website more conveniently and individually and to make use of it as time-saving as possible. In certain cases, these tools may also be necessary for the performance of a contract or for the implementation of pre-contractual measures, in which case the processing is carried out in accordance with Art. 6 para. 1 p. 1 lit. b DSGVO.
We use all other tools, in particular those for marketing purposes, based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a DSGVO and pursuant to Section 15 para. 3 p. 1 TMG, insofar as usage profiles are created for the purposes of advertising or market research. Data processing with the help of these tools only takes place if we have received your consent in advance.
If personal data is transferred to third countries, we refer you to section 6 ("Data transfer to third countries"), also with regard to the possible associated risks. We will inform you if we have concluded standard contractual clauses or other guarantees with the providers of certain tools. If you have given your consent to use certain tools, we (also) transfer the data processed when using the tools to third countries on the basis of this consent.

3.1.2 Obtaining your consent

To obtain and manage your consent, we use the Usercentrics tool from Usercentrics GmbH, Rosental 4, 80331 Munich, Germany ("Usercentrics"). This generates a banner that informs you about data processing on our website and gives you the option to consent to all, some or no data processing through optional tools. This banner appears the first time you visit our website and when you revisit the selection of your preferences to modify them or withdraw consents. The banner will also appear on subsequent visits to our website if you have deactivated the storage of cookies or if the cookie has been deleted by Usercentrics or has expired.
Your consent or revocation, your IP address, information about your browser, your terminal device and the time of your visit are transmitted to Usercentrics during your visit to our website. In addition, Usercentrics uses a necessary cookie to store your given consents and revocations. If you delete your cookies, we will ask you for your consent again when you visit the site at a later time.

The data processing by Usercentrics is necessary to provide you with the legally required consent management and to comply with our documentation obligations. The legal basis for the use of Usercentrics is Art. 6 para. 1 p. 1 lit. f DSGVO, justified by our interest in meeting the legal requirements for cookie consent management.

3.1.3 Revocation of your consent or change of your selection

You can revoke your consent for certain tools at any time in our Cookie Banner. To do so, click the following Cookie Settings. There you can also change the selection of tools you wish to consent to using, as well as obtain supplementary information on cookies and the respective storage period. Alternatively, you can assert your wi-derruf for certain tools directly with the provider..

3.2 Necessary Tools

We use certain tools to enable the basic functions of our website ("Necessary Tools"). Without these tools, we could not provide our service. Therefore, Necessary Tools are used without consent based on our legitimate interests pursuant to Art. 6 (1) p. 1 lit. f DSGVO or to fulfill a contract or to perform pre-contractual measures pursuant to Art. 6 (1) p. 1 lit. b DSGVO.

3.2.1 Own cookies

We use our own necessary cookies in particular

  • for load balancing,
  • to save your language settings,
  • to note that information placed on our website has been displayed to you - so that it is not displayed again the next time you visit the website.

3.2.2 Google Tag Manager

Our website uses Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for users from the European Economic Area and Switzerland and by Google LLC 1600 Amphithe-atre Parkway Mountain View, CA 94043, USA (together "Google") for all other users.

The Tag Manager is used to manage tracking tools and other services, so-called website tags. A tag is an element that is stored in the source code of our website in order, for example, to record specified usage data. The Google Tag Manager ensures that the usage data required by our partners is forwarded to them.

The Google Tag Manager does not require the use of cookies.

The legal basis is Art. 6 (1) p. 1 lit. f DSGVO, based on our legitimate interest in integrating and managing multiple tags on our website in a straightforward manner.

We have concluded an order processing agreement with Google. Partially, data is processed on a Google server in the USA. In the event that personal data is transferred to the USA or other third countries, we have concluded standard contractual clauses with Google in accordance with Art. 46 Para. 2 lit. c DSGVO. For further information, please refer to section 6 ("Data transfer to third countries").

You can find more detailed information on this in the in Google's information on the Tag Manager.

3.3 Analysis tools

In order to improve our website, we use tools for the statistical collection and analysis of general usage behavior based on access data ("analysis tools"). We also use analytics services to evaluate the use of our various marketing channels.

The legal basis for the analysis tools is - unless otherwise stated - your consent pursuant to Art. 6 (1) p. 1 lit. a DSGVO. For revocation of your consent, see 3.1.3: "Revoking your consent or changing your selection". In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the data transfer (Art. 49 (1) p. 1 lit. a DSGVO). Please refer to section 6 ("Data transfer to third countries") for the associated risks.

3.3.1 Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). According to Google, the contact for all data protection issues is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies and similar technologies to analyze and improve our website based on your user behavior. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The data generated in this context may be transferred by Google to a server in the USA for evaluation and stored there.
We have made the following data protection settings for Google Analytics:

  • IP anonymization (shortening of the IP address before evaluation so that no conclusions can be drawn about your identity).
  • Automatic deletion of old logs / limitation of the storage period
  • Deactivated advertising function (including target group remarketing by GA Audi-ence)
  • Disabled personalized ads
  • Disabled Measurement Protocol
  • Disabled cross-page tracking (Google signals)
  • Disabled data sharing with other Google products and services

The following data is processed by Google Analytics:

  • Anonymized IP address;
  • Referrer URL (previously visited page);
  • Pages viewed (date, time, URL, title, time spent);
  • Downloaded files;
  • Clicked links to other websites;
  • Achievement of specific goals (conversions), if applicable;
  • Technical information: Operating system; Browser type, version and language; Device type, brand, model and resolution;
  • Approximate location (country and city, if applicable, based on anonymized IP address).

Google Analytics sets the following cookies for the specified purpose with the respective storage duration:

  • "_ga" for 2 years and "_gid" for 24 hours (both used to recognize and distinguish website visitors by a user ID);
  • "_gat" for 1 minute (to reduce requests to Google servers);
  • IDE" for 13 months (third-party cookie to recognize and distinguish website visitors by a user ID, to record interaction with

recording interaction with advertising and in the context of playing out personalized advertising).
We have concluded an order processing agreement with Google for the use of Google Analytics as well as standard contractual clauses in the event that personal data is transferred to the USA or other third countries.
For more information, please refer to the Google privacy policy.

3.4 Marketing tools

We also use tools for advertising purposes ("marketing tools"). Some of the access data collected when using our website is used for interest-based advertising. By analyzing and evaluating this access data, we are able to display personalized advertising, i.e. advertising that corresponds to your actual interests and needs, on our website and on the websites of other providers.

The legal basis for the marketing tools is your consent according to Art. 6 para. 1 p. 1 lit. a DSGVO. For revocation of your consent, see 3.1.3: "Revoking your consent or changing your selection". In the event that personal data is transferred to the USA or other third countries, your consent also expressly extends to the data transfer (Art. 49 (1) sentence 1 lit. a DSGVO). Please refer to section 6 ("Data transfer to third countries") for the associated risks.

In the following section, we would like to explain these technologies and the providers used for this in more detail. The data collected may include in particular:

  • the IP address of the device;
  • the identification number of a cookie;
  • the device identifier of mobile devices (Device ID);
  • Referrer URL (previously visited page);
  • Pages viewed (date, time, URL, title, length of stay);
  • Downloaded files;
  • Clicked links to other websites;
  • Achievement of specific goals (conversions), if applicable;
  • Technical information: Operating system; Browser type, version and language; Device type, brand, model and resolution;
  • Approximate location (country and city, if applicable).

However, the collected data is stored exclusively pseudonymously, so that no direct conclusions can be drawn about individuals.

3.4.1 Facebook Pixel

For marketing purposes, our websites use the "Facebook Pixel" service of the social network Facebook, a service offered for users outside the USA and Canada by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland and for all other users by Facebook Inc, 1601 Willow Road, Menlo Park, California 94025, USA (together "Facebook").

We use Facebook Pixel to analyze the general use of our websites and to track the effectiveness of Facebook advertising ("Conversion Tracking"). In addition, we use Facebook pixels to play you individualized advertising messages based on your interest in our products ("retargeting"). This also involves target group remarketing through Custom Audience. For this purpose, Facebook processes data that the service collects via cookies, web beacons and comparable storage technologies on our websites.

The data generated in this context may be transferred by Facebook to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we have concluded standard contractual clauses with Facebook.

If you are a member of Facebook and have allowed Facebook to do so via the privacy settings of your account, Facebook can also link the information collected about your visit to us to your member account and use it for the targeted placement of Facebook ads. You can view and change the privacy settings of your Facebook profile at any time.

If you have not consented to the use of Facebook Pixel, Facebook will only display general Facebook Ads that are not selected based on the information collected about you on this website.

You can find more information about this in the Facebook privacy notices.

3.4.2 Google Ads conversion tracking and Ads remarketing (formerly AdWords)

Our websites use the "Google Ads" service, which is offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for users from the European Economic Area and Switzerland and by Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (together "Google") for all other users.

Google Ads uses "Google Ads conversion tracking" to record and analyze customer actions defined by us (such as clicking on an ad, page views, downloads). We use "Google Ads-Remarketing" to show you individualized advertising messages for our products on partner websites of Google. Both services use cookies and similar technologies for this purpose.

The data generated in this context may be transferred by Google to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we have concluded standard contractual clauses with Google.

If you use a Google account, Google may, depending on the settings stored in the Google account, link your web and app browsing history to your Google account and use information from your Google account to personalize ads. If you do not wish this association with your Google account, it is necessary to log out of Google before accessing our website.

If you have not consented to the use of Google Ads, Google will only display general advertising that has not been selected based on the information collected about you on this website. In addition to withdrawing your consent, you also have the option of disabling personalized advertising in the Advertising settings at Google.

The following cookies are set by Google:

  • "_gcl_au" for 90 days.
  • "_gcl_aw" for 90 days.

You can find more information about this in the Notes on data use and the Privacy policy of Google.

3.4.3 Google Marketing Platform and Ad Manager (formerly DoubleClick)

Our website uses the Google Marketing Platform and the Google Ad Manager, services which are offered for users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and for all other users by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (together "Google").

These services use cookies and similar technologies to present you with advertisements that are relevant to you. The use of the services enables Google and its partner websites to serve ads based on previous visits to our website or other websites on the Internet.

The data generated in this context may be transferred by Google to a server in the USA for analysis and stored there. In the event that personal data is transferred to the USA, we have concluded standard contractual clauses with Google.

If you have not consented to the use of Google Marketing Platform and Ad Manager, Google will only display general advertising that has not been selected on the basis of the information collected about you on this website. In addition to withdrawing your consent, you also have the option of disabling personalized advertising in the Advertising settings at Google.

The following cookies are set by Google:

  • "IDE" for 12 months.

You can find more information about this in the Privacy policy of Google.

4. Online presences in social networks

We maintain online presences in social networks in order to communicate there with customers and interested parties, among others, and to provide information about our services.

User data is generally processed by the social networks concerned for market research and advertising purposes. In this way, usage profiles can be created based on the interests of the users. For this purpose, cookies and other identifiers are stored on the users' computers. Based on these usage profiles, for example, advertisements are then placed within the social networks but also on third-party websites.

As part of the operation of our online presences, it is possible that we can access information such as statistics on the use of our online presences, which are provided by the social networks. These statistics are aggregated and may include, in particular, demographic information and data on interaction with our online presences and the posts and content distributed via them. For details and links to the data of the social networks that we as operators of the online presences can access, please refer to the list below.

The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO, based on our legitimate interest in effectively informing users and communicating with users, or Art. 6 para. 1 p. 1 lit. b DSGVO, in order to stay in contact with and inform our customers, as well as to carry out pre-contractual measures with future customers and interested parties.

For the legal basis of the data processing carried out by the social networks on their own responsibility, please refer to the data protection notices of the respective social network. The links below also provide you with further information on the respective data processing as well as the options to object.

We would like to point out that data protection requests can be asserted most efficiently with the respective provider of the social network, as only these providers have access to the data and can take appropriate measures directly. Below is a list with information on the social networks on which we operate online presences:

Facebook (USA and Canada: Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA; all other countries: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).

Instagram (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).

Google/ YouTube(Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ir-land).

Twitter (Twitter International Company, One Cumberland Place, Fenian Street, Dub-lin 2, D02 AX07 Ireland).

LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland).

Xing/Kununu (XING SE, Dammtorstraße 30, 20354 Hamburg, Germany)

5. Transfer of data

A transfer of the data collected by us takes place in principle only if:

  • you have given your express consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO,
  • the disclosure is necessary for the assertion, exercise or defense of legal claims pursuant to Art. 6 (1) sentence 1 lit. f DSGVO and there is no reason to assume that you have an overriding legitimate interest in not having your data disclosed,
  • we are legally obliged to disclose your data according to Art. 6 para. 1 p. 1 lit. c DSGVO or
  • this is legally permissible and necessary according to Art. 6 para. 1 p. 1 lit. b DSGVO for the processing of contractual relationships with you or for the implementation of pre-contractual measures that take place at your request.

Part of the data processing may be carried out by our service providers. In addition to the service providers mentioned in this privacy policy, this may include, in particular, data centers that store our website and databases, software providers, IT service providers that maintain our systems, agencies, market research companies, group companies and consulting companies. If we pass on data to our service providers, they may only use the data to perform their tasks. The service providers have been carefully selected and commissioned by us. They are contractually bound to our instructions, have suitable technical and organizational measures in place to protect the rights of the data subjects and are regularly monitored by us.

In addition, a transfer may take place in connection with official inquiries, court decisions and legal proceedings if it is necessary for legal prosecution or enforcement.

6. Data transfer to third countries

As explained in this Privacy Policy, we use services whose providers are partly located in or process personal data in so-called third countries (outside the European Union or the European Economic Area), i.e. countries whose data protection level does not correspond to that of the European Union. Insofar as this is the case and the European Commission has not issued an adequacy decision (Article 45 GDPR) for these countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses of the European Union or binding internal data protection regulations.

Where this is not possible, we base the data transfer on exceptions of Art. 49 DSGVO, in particular your explicit consent or the necessity of the transfer for the performance of the contract or for the implementation of pre-contractual measures.

If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed. When obtaining your consent via the cookie banner, you will also be informed of this.

7. Storage period

In principle, we store personal data only as long as necessary to fulfill the purposes for which we collected the data. Thereafter, we delete the data immediately, unless we still need the data until the expiry of the statutory limitation period for evidence purposes for civil law claims or because of statutory retention obligations.

For evidentiary purposes, we must retain contractual data for three years from the end of the year in which the business relationship with you ends. Any claims become statute-barred at this point at the earliest in accordance with the standard statutory limitation period.

Even after this, we still have to store some of your data for accounting reasons. We are obliged to do so because of legal documentation obligations that may arise from the German Commercial Code, the German Fiscal Code, the German Banking Act, the German Money Laundering Act and the German Securities Trading Act. The periods specified there for the retention of documents are two to ten years.

8. Your rights, in particular revocation and objection

You are entitled to the data subject rights formulated in Art. 15 - 21, Art. 77 DSGVO at any time:

  • Right to withdraw your consent;
  • Right to object to the processing of your personal data (Art. 21 DSGVO);
  • Right to information about your personal data processed by us (Art. 15 DSGVO);
  • Right to rectify your personal data stored by us that is incorrect (Art. 16 DSGVO);
  • Right to erasure of your personal data (Art. 17 DSGVO);
  • Right to restrict the processing of your personal data (Art. 18 DSGVO);
  • Right to data portability of your personal data (Art. 20 GDPR);
  • Right to lodge a complaint with a supervisory authority (Art. 77 DSGVO).

To exercise your rights described here, you can contact us at any time using the contact details above. This also applies insofar as you wish to receive copies of guarantees demonstrating an adequate level of data protection. Provided that the respective legal requirements are met, we will comply with your data protection request.

Your requests to assert data protection rights and our responses to them will be stored for documentation purposes for a period of up to three years and, in individual cases, even longer for the assertion, exercise or defense of legal claims. The legal basis is Art. 6 (1) p. 1 lit. f DSGVO, based on our interest in defending against any civil claims under Art. 82 DSGVO, avoiding fines under Art. 83 DSGVO and fulfilling our accountability obligations under Art. 5 (2) DSGVO.

You have the right to revoke your consent at any time. This has the consequence that we no longer continue the data processing based on this consent for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

In so far as we process your data on the basis of legitimate interests, you have the right to object to the processing of your data at any time on grounds relating to your particular situation. If it concerns an objection to data processing for direct marketing purposes, you have a general right of objection, which will also be implemented by us without giving reasons.

If you wish to exercise your right of revocation or objection, it is sufficient to send an informal message to the above contact details.

Finally, you have the right to complain to a data protection supervisory authority. You can assert this right at a supervisory authority in the member state of your residence, your place of work or the place of the alleged infringement. In Berlin, our headquarters, the competent supervisory authority is: Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin.

9. changes to the privacy policy

We occasionally update this privacy policy, for example when we adapt our website or when legal or regulatory requirements change.

Version: 1.1 / Status: June 2021