Privacy Notice

1. Introduction

We would like to use the information below to provide you as "data subject" with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent.

Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the "axxessio GmbH". The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process.

As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps so that absolute protection cannot be guaranteed. For this reason, you are free to submit personal data on alternative ways, such as by phone or by post to us.

You too can take simple and easy-to-implement measures to protect yourself against unauthorized access to your data by third parties. Therefore, we would like to give you some tips on how to handle your data securely: 

• Protect your account (login, user or customer account) and your IT system (computer, laptop, tablet or mobile device) with strong passwords.
• Only you should have access to the passwords.
• Make sure you only use your passwords for one account (login, user or customer account) at a time.
• Do not use one password for different websites, applications or online services.
• Especially when using public-access or shared IT systems, be sure to log out each time you log in to a website, application or online service.

Passwords should consist of at least 12 characters and be chosen so that they cannot be easily guessed. Therefore, they should not contain common words from everyday life, your own name or names of relatives, but upper and lower case, numbers and special characters.

2. Data controller

The data controller, as defined by the GDPR, is:

axxessio GmbH

Venusbergweg 1, 53115 Bonn, Germany

Phone: +49 228 - 76 36 31 0

Fax: +49 228 - 76 36 31 3

Email: info@axxessio.com

Data controller’s representative: Dr. Goodarz Mahbobi

3. Data protection officer

You can reach the data protection officer as follows:

Markus Sextro

Phone: +49 (0)6181 618 355 2

Email: markus.sextro@accas-group.com

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

4. Definitions

This Privacy Notice is based on the terminology used by the European legislature and legislature in the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand, both for the public and for our customers and business partners. To ensure this, we would like to explain in advance the terminology used. Among other things, we use the following terms in this privacy policy.

We use the following terms in this Privacy Notice, among others:

1. Personal data

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Data subject

A Data subject is any identified or identifiable natural person whose personal data is processed by the controller (our company).

3. Processing

Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Restriction of processing

 Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

5. Profiling

Profiling is any form of automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

6. Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.

7. Data processor

Data processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

8. Recipient

A recipient is a natural or legal person, public authority, agency, or other body to whom personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

9. Third party

Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or the processor, are authorised to process the personal data.

10. Consent

Consent means any freely given specific and informed indication of the data subject's wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

5. Legal basis for processing

Art. 6 (1) lit. a GDPR (icw § 25 (1) German Telecommunications-Telemedia Data Protection Act (TTDSG)) serves our company as the legal basis for processing operations where we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 (1) lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services.

If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c GDPR.

In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. In this case, the processing would be based on Art. 6 (1) lit. d GDPR.

Finally, processing operations could be based on Art. 6 (1) lit. f GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary for the protection of a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not overweigh. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47, Sentence 2 GDPR)..

6. Technology

6.1 SSL/TLS-encryption

This site uses SSL or TLS encryption to guarantee the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact enquiries that you send to us as the operator. You can recognise an encrypted connection by the fact that the address bar of the browser contains a "https://" instead of a "http://" and by the lock symbol in your browser bar.

We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as "server log files"). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information is stored in the server’s log files. It may be collected:

• the browser types and versions used,
• the operating system used by the accessing system,
• the website from which an accessing system accesses our website (so-called referrer),
• the sub-pages accessed via an accessing system on our website,
• the date and time of access to the website,
• an internet Protocol (IP) address, and
• the internet service provider of the accessing system.

When using this general data and information, we do not draw any conclusions about your person. Rather, this information is required to

• deliver the contents of our website correctly,
• optimise the contents of our website as well as to advertise it,
• to ensure the permanent operability of our IT systems and the technology of our website, and
• to provide law enforcement authorities with the information necessary to prosecute in the event of a cyber-attack.

Therefore, the data and information collected will be used by us for statistical purposes only and for the purpose of increasing the data protection and data security of our enterprise to ensure an optimal level of protection for the personal data we process. The data of the server log files is stored separately from any personal data provided by a data subject.

The legal basis for data processing is Art. 6 (1) lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above.

6.3 Hosting by Hetzner

We host our website at Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (hereinafter referred to as Hetzner).

When you are visiting our website your personal data (e.g. IP addresses in log files) are processed on the servers of Hetzner.

The use of Hetzner is based on Art. 6 (1) lit. f GDPR. Our legitimate interest is the high-performance provision of our website.

We have concluded a corresponding agreement with Hetzner on the basis of GDPR for commissioned processing. This is a contract required by data protection law, which ensures that Hetzner only processes the personal data of our website visitors according to our instructions and in compliance with the GDPR.

Additional information and Hetzner`s privacy policy can be found at https://www.hetzner.com/de/rechtliches/datenschutz

7. Cookies

7.1 General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our website.

Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity.

The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website.

In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a specific period of time. If you visit our site again to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

We also use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimisation. These cookies enable us to automatically recognise that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.

8. Contents of our website

8.1 Contact support / Contact form

Personal data is collected when contacting us (e.g. via contact form or e-mail). Which data is collected in the case of the use of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Art. 6 (1) lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) lit. b GDPR. Your data will be deleted after final processing of your request; this is the case if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and the deletion does not conflict with any legal obligations to retain data.

8.2 Application Management / job exchange

We collect and process the personal data of applicants for the purpose of processing the application procedure. The processing may also take place electronically. This is particularly the case if an applicant submits the relevant application documents to us electronically, for example by e-mail or via a web form on the website. If we conclude an employment or service 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 we do not conclude a contract with the applicant, the application documents are automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests on our part oppose deletion. Another legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the German Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz [AGG]).

The legal basis for processing your data is Art. 88 GDPR icw § 26 (1) German Federal Data Protection Act (Bundesdatenschutzgesetz [BDSG]).

9. Our activities in social networks

To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks. If you visit one of our social media pages, we and the provider of the social media network are joint controllers (Art. 26 GDPR) regarding to the processing operations triggered thereby, which concern personal data.

We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers.

We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behaviour by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behaviour may be assigned directly to your own member profile on the respective social network (if you are logged in).

The processing operations of personal data described are carried out in accordance with Art. 6 (1) lit. f GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Art. 6 (1) lit. a GDPR in conjunction with Art. 7 GDPR.

Since we have no access to these providers’ databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt out) is listed below for each of the social network providers we use:

9.1 Facebook

(Joint) Data controller responsible for data processing in Europe:

Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Privacy Notice (Data Policy):

https://www.facebook.com/about/privacy

9.2 LinkedIn

(Joint) Data controller responsible for data processing in Europe:

LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

Privacy Notice:

https://www.linkedin.com/legal/privacy-policy

9.3 YouTube

(Joint) Controller responsible for data processing in Europe:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Privacy Notice:

https://policies.google.com/privacy

9.4 XING (New Work SE)

(Joint) Data controller responsible for data processing in Germany:

New Work SE, Dammtorstrasse 29?32, 20354 Hamburg, Germany

Privacy Notice:

https://privacy.xing.com/de/datenschutzerklaerung

Requests for information for XING members:

https://www.xing.com/settings/privacy/data/disclosure

10. Plugins and other services

10.1 Microsoft Teams

We use the tool "Microsoft Teams" ("MS-Teams") to conduct our communication both in written form (chat) and in the form of telephone conferences, online meetings and video conferences. The operating company of the service is Microsoft Ireland Operations ("Microsoft"), Ltd., 70 Sir John Rogerson's Quay, Dublin, Ireland. Microsoft Ireland Operations, Ltd. is part of the Microsoft group of companies headquartered at One Microsoft Way, Redmond, Washington, USA.

When using MS Teams, the following personal data are processed:

• Meetings, chats, voicemails, shared files, recordings, and transcriptions.
• Data that is shared about you. Examples include your e-mail address, profile picture and phone number.
• A detailed history of the phone calls you make.
• Call quality data.
• Support/feedback data Information related to troubleshooting tickets or feedback sent to Microsoft.
• Diagnostic and Service Data Diagnostic data related to service usage

To enable the display of video and the playback of audio, data from your end device microphone and from an end device video camera will be processed for the duration of the meeting. You can turn off or mute the camera or microphone yourself at any time using the "Microsoft Teams" applications.

If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR. In the context of an employee relationship, corresponding data processing is carried out on the basis of § 26 German Federal Data Protection Act (Bundesdatenschutzgesetz [BDSG]). The legal basis for the use of the service in the context of existing contractual relationships or contractual relationships to be initiated is Art. 6 (1) lit. b GDPR. In all other cases, the legal basis for processing your personal data is Art. 6 (1) lit. f GDPR. Here, our interest is in the effective implementation of online meetings.

When we record online meetings, we will tell you before we start and, if necessary, ask you to consent to the recording. If you do not wish to do so, you can leave the online meeting.

As a cloud-based service, "MS-Teams" processes the aforementioned data in the course of providing the service. To the extent "MS-Teams" processes personal data in connection with Microsoft's legitimate business operations, Microsoft is an independent data controller for such use and, as such, is responsible for compliance with applicable laws and obligations of a data controller. To the extent you access the MS Teams website, Microsoft is the data controller. Accessing the Internet site is necessary to download the MS-Teams software.

If you do not wish to or are unable to download the software, the service can be provided via your browser and to that extent also via the Microsoft website.

This US company is certified under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.

Additional information on the service can be found at the following link: https://docs.microsoft.com/de-de/microsoftteams/teams-privacy.

10.2 OpenStreetMap

We have integrated map sections of the online mapping tool "OpenStreetMap" on our website. This is a so-called open source mapping, which we can access via an API (interface). This function is offered by the OpenStreetMap Foundation, St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom. By using this service, for example, our location can be displayed to you and a possible journey can be facilitated.

When you access the sub-pages in which OpenStreetMap is integrated, information about your use of our website (such as your IP address, data on your browser, device type, operating system) is transmitted to OpenStreetMap and stored there.

OpenStreetMap uses the Content Delivery Network (CDN) of Fastly, Inc, PO Box 78266, San Francisco, CA 94107, USA (hereinafter referred to as fastly) to accelerate the service. A CDN is a service that helps to deliver the content of our online offer, especially large media files such as graphics or scripts, more quickly with the help of regionally distributed servers connected via the Internet. Your data is processed exclusively for the aforementioned purposes and to maintain the security and functionality of the CDN.

Fastly transfers personal data from the log files (e.g. IP addresses) to the USA for any data processing, as certain servers for processing the log files are only located in the USA. Fastly is therefore committed to compliance with the standards and regulations of European data protection law. Fastly's current Privacy Policy can be found at: https://www.fastly.com/de/privacy/.

If a corresponding consent was requested, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR.

This US company is certified under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.

Additional information on the service can be found at the following link: https://wiki.osmfoundation.org/wiki/Privacy_Policy.

11. Your rights as a data subject

11.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

11.2 Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.

11.3 Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

11.4 Erasure (Article 17 GDPR)

You have the right to demand that we erase the personal data relating to you without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.

11.5 Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

11.6 Data transferability (Article 20 GDPR)

You have the right to obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1(a) GDPR or Article 9 Paragraph 2(a) GDPR or on a contract pursuant to Article 6 Paragraph 1(b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us.

Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

11.7 Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1(e) (data processing in the public interest) or (f) (data processing on the basis of the weighing of legitimate interests) GDPR.

This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR.

Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.

In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose.

In addition, you have the right to object to our processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89 Paragraph 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest.

You are free to exercise your right to lodge an objection in relation to the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

11.8 Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

11.9 Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

12. Routine storage, erasure and blocking of personal data

We process and store your personal data only for the period of time necessary to meet the storage purpose or as required by the legal provisions to which our company is subject.

If the storage purpose no longer applies or if a required retention period expires, personal data will be routinely blocked or erased in accordance with the statutory provisions.

13. Duration of storage of personal data

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

14. Version and amendments to the Privacy Notice

This Privacy Policy is currently valid as of: August, 2023

Due to the further development of our Internet pages and offers or due to changed legal or official requirements, it may become necessary to change this Privacy Policy. You can access and print out the current data protection declaration at any time on the website under "https://www.axxessio.com/de/impressum".

This privacy statement has been prepared with the assistance of the privacy software:  https://www.audatis-manager.de audatis MANAGER.