Privacy Policy Website (eyeo.com)

Privacy Notice (short version)

The following privacy notice shall provide you with a general overview about the collection, processing and use (hereinafter together referred to as “processing”) of your personal data. For more information regarding our processing activities, please view our complete Privacy Policy.

What kind of data do we process?

  1. While using the eyeo.com website (by default):
  2. When applying for a job:
    • Name
    • Email address
    • CV and all other data voluntarily uploaded / shared by you
  3. When subscribing to a newsletter (voluntarily):
    • Name
    • Email address
  4. On eyeo.com/2018-ad-blocking-report and on eyeo.com/2019-uk-ad-blocking-usage-report
    • Contact Data
  5. On our social media pages
    • Usage profiles

How do we collect data?

  • Log files
  • Data provided by user in a form
  • Newsletter sign up form
  • Data you provide to us with via social media
  • In connection with our social media pages: Cookies

How and why do we process your data?

  • For technical purposes, such as, but not limited to, preventing security attacks
  • Evaluating your application for recruitment purposes
  • If requested by you, to inform you about or contact you in connection with our products and/or sending you reports or other information
  • In connection with our social media pages, social networks use the data for market research and advertising purposes

How long do we keep data?

  • Website logs for 30 days.
  • Application data for six (6) months after rejection of a candidate.
  • Email addresses for newsletter services for no more than two (2) months after unsubscription.
  • Contact data in connection with eyeo.com/2018-ad-blocking-report and eyeo.com/2019-uk-ad-blocking-usage-report until you have withdrawn your consent or if no longer necessary, whichever period is shorter

What is the legal basis of data processing?

We process your personal data in compliance with the European General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the applicable EU laws and German national data protection laws.

Our values

We collect as little data as possible. As far as anonymous or pseudonymous use is possible we anonymize or pseudonymize your data.

What rights do you have?

  • Receive and access information about the personal data stored by us about you.
  • Rectify inaccurate personal data and restrictive details.
  • Receive all your personal data in a structured, commonly used and machine-readable format, as well as having such data transmitted to another controller.
  • Request erasure of your data, unless such data needs to be retained for legal purposes.
  • Object to the processing of your data.
  • Withdraw your consent at any time, when you have provided us with your consent to the processing of your personal data.
  • Lodge a complaint with the respective supervisory authority.

Questions?

Contact our Data Protection Officer, Dr. Judith Nink, at  or phone +49 (0) 221 / 65028 598.

Privacy Policy

(long version)

Your protection and data confidentiality is of utmost importance to us (“eyeo” “we” “our”). We take the protection of your personal data very seriously and collect as little data as possible. Nevertheless, some personal data are necessary to provide our website and/or our application tools for candidates. This privacy policy shall inform you about the personal data we collect and how exactly that data is processed. We gather and use personal data firmly within the provisions of the European General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the applicable EU Laws and German national data protection laws. In the following text we will inform you about the specific data, the scope and purpose of the collection and use of personal data by us when using eyeo.com, the legal basis for such collection and processing as well as your rights to protect your personal data.

Who is responsible for the data collection and processing (contacts)?

The legal person responsible for the collection, processing and/or use of personal data in connection with eyeo.com (“Controller”) is:

eyeo GmbH
Lichtstraße 25
50825 Cologne
Germany

Data Protection Officer

If you have any queries relating your personal data, please do not hesitate to contact our Data Protection Officer:

Dr. Judith Nink

Phone: +49 (0) 221 / 65028 598

Email:

Fax: +49 (0) 221 / 65028 599

What is personal data?

The purpose of data protection is to protect personal data. Personal data means any information relating to an identified or identifiable natural person (“data subject”); 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. This information includes, for example, details such as name, postal address, email address or telephone number but also nicknames, certificates and information about your interests.

What kind of Data do we collect and process and how?

Automatically collected and processed information:

Website logs

While using eyeo.com website, we are automatically recording website logs and thereby collecting the following data for technical and for security reasons:

  • IP address (stored separately)
  • Date and time of access
  • Browser name/version [1]
  • URL of previously visited webpage [2]
  • Amount of data sent

This data is stored purely for technical reasons and cannot be linked to any individual person. We do not combine website log data with any other information about you.

[1] For more information, please refer to https://tools.ietf.org/html/rfc7231#section-5.5.3.

[2] For more information, please refer to https://tools.ietf.org/html/rfc7231#section-5.5.2.

Analytics data at eyeo.com/2018-ad-blocking-report and eyeo.com/2019-uk-ad-blocking-usage-report

We use Google Analytics on our website, a web analysis service of Google Inc. (“Google”). Google Analytics uses so-called “cookies” (text files which are stored on your computer and which enable you to analyze your use of our website). The information generated by the cookie on your use of our website (including your abbreviated IP address) is transmitted to a Google server in the United States and are stored there. Google will use this information to assess your use of our Website, to compile reports on the activities for us and to provide more services connected with use of our website and the internet. It is also possible that Google may transmit this information to third parties if this is required by law, or if third parties process this information on behalf of Google.

You can deactivate Google Analytics by means of a browser add-on if you do not want to participate in Website analysis. You can download this here:

https://tools.google.com/dlpage/gaoptout

Information you give us on a voluntary basis:

Application Data

If you are applying online for a job at eyeo you need to fulfil our online application form. In order to evaluate your application properly we need at least your name, email address and a CV. On a voluntary basis you may further add a telephone number, a cover letter, additional documents, such as, but not limited to certificates, a website and additional information about you.

We collect and process those data for the sole purpose of managing eyeo’s recruitment related activities as well as for organizational planning purposes. Consequently, eyeo may use your personal data in relation to the evaluation and selection of applicants including for example setting up and conducting interviews and tests, evaluating and assessing the results thereto and as is otherwise needed in the recruitment processes including the final recruitment.

Newsletter

We provide you with a newsletter service free of charge. We use the newsletter to inform you about new products, updates on our products and to send you general information about eyeo. We need your email address in order to send you the newsletter. You can enter your email address at eyeo.com. We will store and use your email address solely to send you the newsletter.

Each newsletter contains information on how to unsubscribe (‘right to withdraw your consent’) from your subscription at any time with immediate effect.

Ad blocking report

You can download our ad-blocking report for free by submitting the following information: name, email address and organization and allowing us to contact you regarding our products and services. We will never pass on your information to a third party for any purpose.

Our social media presence

In order to be able to communicate with our customers and interested parties, and to inform them about our activities and offers on social networks, we are active on Facebook, Instagram, Twitter and LinkedIn. In terms of Facebook, both Facebook and eyeo are jointly responsible for the processing of your personal data (“joint controller”, GDPR Art. 26), even if it is stored exclusively by the respective social network. Therefore, we still inform you about the data processing processes in connection with our presence on the respective social network as follows.

If you follow our respective online presence on one or more of the social networks used by us, please note that your data may be processed outside the European Union / the European Economic Area. However, all the networks we use have agreed to comply with EU data protection standards within the framework of the EU-US Privacy Shields.

The social networks we use also process your data regularly for market research and advertising purposes. Based on your usage behavior and interests, the networks may create usage profiles which are used, for example, to place advertisements corresponding to your potential interests within and outside the networks. For these purposes, cookies, which store your usage behavior and interests, as well as possibly also the devices you use, are regularly stored on your computer.

For a detailed overview of the respective processing operations and opt-out options, please visit the website of each social network, listed below. For the assertion of your rights and requests for information, we also refer you to the respective social networks, where you can exercise your rights most effectively. This is because the social networks have access to your data and can therefore directly take appropriate measures and provide you with the respective information:

What is the legal basis?

We process personal data in compliance with the European General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the applicable German national data protection laws:

Processing is necessary for taking steps prior to enter into a contract (Art. 6 (1) b GDPR)
All data you provide us with in connection with your application (more information about the purposes you will find here>) is necessary for the sole purpose of hiring new employees and therefore evaluating and selecting applicants including for example setting up and conducting interviews and tests, evaluating and assessing the results thereto and as is otherwise needed in the recruitment processes including the final recruitment (meaning taking steps prior to enter into an employment contract). If you don’t send us your application data your application cannot be taken into account.

Collection and processing is necessary for compliance with a legal obligation to which the controller is subject – Art. 6 (1) c GDPR
Collection and processing of your personal data may be necessary for compliance with a legal obligation to which we are subject under EU laws or the laws of a EU Member State.

Processing is necessary for the purposes of eyeo’s legitimate interests (Art. 6 (1) f GDPR)
The collection and processing may be necessary for the purposes of our legitimate interests.

  • We collect and process website logs for technical reasons, such as, but not limited to, preventing denial of service attacks. Denial of service is typically accomplished by flooding the targeted machine or resource with superfluous requests in an attempt to overload systems and prevent some or all legitimate requests from being fulfilled. Preventing such overloads of our systems and any security issues by denial of service attacks is in your and our vital interest and therefore we use the website logs.

We use website log data (with anonymized IP addresses) for analyzing purposes to help us improve our website.

  • The processing of your personal data in connection with our presence in social networks is also based on our legitimate interests in effective information and communication with you.

Processing is based on your consent (Art. 6 (1) a, Art. 7 GDPR)

  • When subscribing for our newsletter (more information on purposes), you provide us with your consent, which legitimizes the use of your email address in accordance and to the extent of your consent.
  • If you have given your consent to the respective social network in terms of data processing as described above, the legal basis for the processing is your consent (GDPR Art. 6 para. 1 lit. a, Art. 7).

Do we disclose any personal data?

We will not transfer your personal data to third parties as a matter of course without letting you know in advance or asking for your prior permission. We may only transfer your personal data to third parties without informing you separately beforehand in the following exceptional cases as explained below:

  • If required for legal proceedings/investigations, personal data will be transferred to the criminal investigation authorities and, if appropriate, to injured third parties. We will only do this if there are concrete indications of illegal and/or abusive behaviour. We are also legally obliged to give certain public authorities information. These are criminal investigation authorities, public authorities which prosecute administrative offences entailing fines and the German finance authorities.
  • As part of the further development of our business it may happen that the structure of eyeo GmbH changes. The legal structure may be adapted, subsidiaries, business units or components may be created, bought or sold. In such transactions customer information may be shared with the transmitted part of the company. In the event of a transfer of personal information eyeo GmbH will ensure that it is done in accordance to this Privacy Policy and the German data protection laws.
  • For support purposes we are working with a service provider, PlatinPower.com GmbH, Mündender Straße 31, 34123 Kassel, Germany (“PlatinPower”). PlatinPower will only access and process any of your personal data to the extent required for support purposes and only under our instructions. This is safeguarded by a data processing agreement.

International data transfers
For the following services we are using non-EU/EEA service providers. We have carefully selected these external service providers and review regularly to ensure that your privacy is preserved. The service providers provide sufficient guarantees to ensure an adequate level of data protection and may only use the personal data for the purposes stipulated by us and in accordance with our instructions. We also contractually require the service providers to treat your personal data solely in accordance with this Privacy Policy and the European data protection laws:

For job applications we use external service providers to host the online application for you. Greenhouse collects some information on its website, such as anonymous usage statistics, by using cookies, server logs, and other similar technology. For more information, please refer to Greenhouse’s Privacy Policy. When clicking on the “Apply now” button you will be automatically forwarded to the job application tool, which is provided and hosted by Greenhouse Software, Inc., 110 Fifth Avenue, 3rd Floor, New York, NY 10011 (“Greenhouse”). Your job application information, including all documents provided by you, is stored at Greenhouse, in order to enable them to fulfil their contractual obligations. In order to ensure an adequate level of data protection, we have entered into the EU Standard Contractual Clauses (processors) – Commission Decision C(2010)593. You can request a copy by contacting .

Data Retention

Detailed website logs are retained for a period of 30 days, after which only the aggregated usage statistics that cannot be connected to a single user remain. Everything else is deleted.

Application data will be deleted six (6) months after rejection of a candidate. Data of hired candidates will be kept until the end of the employmentship.

Email addresses for newsletter services will be deleted at least two (2) months after you have unsubscribed.

What rights do you have?

In compliance with the GDPR and the applicable EU laws and German national data protection laws and to the extent legally permitted, you have the following rights to protect your personal data collected and processed by us:

Information, access, rectification and restriction rights
You have the right to receive, upon request, information about the personal data stored by us about you and information about how we collect and process your personal data. Where that is the case, you have the right to gain access to such personal data stored by us. You have the right to request from us the rectification of inaccurate personal data, if any. Taking into account the purposes of collecting and processing your data, you have the right to have incomplete personal data completed. You also have the right to request restriction of processing.

Data portability
You also have the right (1) to receive all personal data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format and (2) to transmit those data to another controller.

Erasure of your data
You have the right to demand from us the erasure of your personal data, where – inter alia – one of the following grounds applies:

  • If we no longer need your personal data for the aforementioned purposes.
  • If you withdraw your consent on which the collection and processing is based on Article 6 (1) a GDPR and where there are no other legal grounds for collection and processing.
  • If you object to the collection and processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for collection and processing.

Please note, if data needs to be retained for legal purposes we will restrict the respective data.

Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the collection and processing of personal data relating to you infringes the GDPR.

Right to object to the processing of your data
You have the right to object at any time to the collection and/or processing of your personal data on grounds relating to your particular situation, where collection and processing is based on our legitimate interest (Art. 6 (1) f GDPR).

Right to withdraw your consent at any time
You have the right to withdraw your consent at any time, if you have provided us with your consent to the collection and processing of your personal data for one or more specific purposes. The withdrawal of your consent does not affect the lawfulness of processing based on the consent before its withdrawal.

How to exercise your rights
To exercise your rights, please contact us via or mail to:

eyeo GmbH
Lichtstraße 25
50825 Cologne
Germany

Changes to this Privacy Policy

This Privacy Policy can be changed from time to time.
The respective current version is available at: https://eyeo.com/privacy

March 2019

Privacy Information Business Partner

Information on how we, at eyeo, process your personal data and your information rights in accordance with Articles 13, 14, and 21 of the General Data Protection Regulation (“GDPR”).

We hereby inform you about the processing of your personal data by us and the claims and rights to which you are entitled under the data protection regulations.

1. General Information

Who is responsible for data processing and who can I contact?

Controller

The legal person responsible for the collection, processing and / or use of personal data in connection with our websites and products (“Controller”) is:

eyeo GmbH
Lichtstraße 25
50825 Cologne
Germany

Data Protection Officer

Dr. Judith Nink

Phone: +49 (0) 221 / 65028 598

Email:

Fax: +49 (0) 221 / 65028 599

What sources and data categories do we use for processing your personal data?

Sources

Data you provided directly to us or indirectly through our PR agency Rocket Science, who may have initiated our first contact; business cards; emails; professional social networks; your company website.

Categories of Personal Data

Contact data, contact person, communication data, bank details.

The purposes for processing data

This data is collected and processed:

  • to identify you as our partner;
  • to communicate with you; and
  • for invoicing purposes.

Legal Basis to Process Data

Collection and processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract (GDPR Art. 6(1)(b))

The personal data will be processed if required for (i) entering into a contract, (ii) the appropriate processing of our contract, or (iii) for the mutual fulfilment of obligations arising from the contract in accordance with Article 6(1)(b) of the GDPR.

Processing is necessary for our legitimate interests (GDPR Art. 6(1)(f))

If necessary, we process your data beyond the actual scope of performance of our contract to protect our legitimate interests and those of third parties, e.g. newsletters about our products sent by our service providers.

Processing is based on your consent (GDPR Arts. 6(1)(a), 7)

Please note that withdrawing your consent will only affect processing of personal information that would have occurred after the time of the withdrawal. Processing that took place before your withdrawal will remain unaffected by such withdrawal.

By giving us your consent to process personal data for specific purposes (e.g. to send you newsletters), our processing your personal data for those purposes is permitted. Consent that has been given can be withdrawn at any time. This also applies to withdrawing declarations of consent which may have been given to us before the GDPR became enforceable, i.e. before 25 May 2018.

Processing is necessary for compliance with a legal obligation (GDPR Art. 6(1)(c))

As a company, we are also subject to various additional legal obligations, i.e. legal requirements. These additional obligations may include, but are not limited to:

  • complying with legal requirements (e.g. tax matters, notifications to the financial supervisory authorities),
  • fulfilling legal obligations to provide information (court orders, investigations, etc.).

What Happens to Your Data

Who may access your data?

Within eyeo GmbH, certain departments (e.g. respective executives) may receive the data as needed to fulfill our contractual and legal obligations (e.g. accounting receives invoicing data).

In addition, we make use of various service providers and freelancers to fulfill our contractual and legal obligations. We may also transfer your personal data to other recipients outside of eyeo GmbH if this is necessary to fulfill any contractual and legal obligations. These other recipients may include, but are not limited to:

  • authorities (e.g. tax authorities, courts, data protection supervisory authorities)
  • bank details (SEPA payment medium)

Contractors that we use, which include but are not limited to service providers and freelancers, may also receive personal data for these purposes (GDPR Art. 28). Such contractors include companies that provide banking services, accounting services, marketing services, IT services, software tools, logistics, printing services, telecommunications, debt collection, consulting, and sales and marketing.

How long do we store personal data?

Any personal data which we collect for the purposes of our contractual relationship will be stored until the end of the legal obligation to retain contract data (6 or 10 years after the end of the calendar year in which the contractual relationship was terminated). After this term, the data will be deleted, unless we can prove that continued retention is necessary for compliance with any obligation in accordance with GDPR Art. 6(1)(c). Such obligations may include, but are not limited to, tax and commercial-legal storage and documentation obligations under the German Commercial Code (HGB), the German Criminal Act (StGB), or the German Revenue Code (AO). Storage terms exceeding 6 or 10 years after the termination of a contract may also apply if agreed to in writing (GDPR Art. 6(1)(a)).

Do we transfer personal data to a third party seated in a non-EU/EEA country?

We transfer personal data to the following companies:

Rights of Data Subjects

What rights do you have?

In compliance with the GDPR and applicable EU and German national data protection laws, and to the extent legally permitted, you have the following rights to protect your personal data collected and processed by us:

Information, access, rectification and restriction rights

Upon request, you have the right to receive information about the personal data stored by us about you and information describing how we collect, process, and store your personal data. Further, you have the right to gain access to any of your personal data stored by us. You have the right to request from us the rectification of inaccurate personal data about you that we store. Taking into account the purposes of collecting and processing your data, you have the right to have incomplete personal data completed. You have the right to request restrictions on the processing of your personal data.

Information, access, rectification and restriction rights

You also have the right (1) to receive in a structured, commonly used, and machine-readable format all personal data about you that you have provided to us, and (2) to transmit that data to another controller.

Right to erasure of your data

You have the right to demand from us the erasure of your personal data, where – inter alia – one of the following grounds applies:

  • If we no longer need your personal data for any of the aforementioned purposes;
  • If you withdraw your consent on which the collection and processing of your personal data is based on and where there are no other legal grounds for the collection and processing of your personal data; or
  • If you object to the collection and processing and there are no overriding legitimate grounds for continuing collection and processing of your personal data

Please note, if data needs to be retained pursuant to the erasure exemptions provided in Article 17(3) of the GDPR, we will restrict the use of the respective data.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, your place of work, or the place of the alleged infringement if you believe that the collection and processing of your personal data infringes the protections provided by the GDPR.

Right to object to the processing of your data

You have the right to object at any time to the collection and processing of your personal data on grounds relating to your particular situation when collection and processing of such data was based on our pursuing legitimate business interests (GDPR Art. 6(1)(f)).

Right to withdraw your consent at any time

You have the right to withdraw your consent at any time, when you have provided us with your consent for the collection and processing of your personal data for one or more specific purposes.

How to exercise your rights

To exercise your rights, please contact us via email or mail to:

eyeo GmbH
Lichtstraße 25
50825 Cologne
Germany

Are you obliged to provide personal data to us?

In connection with our contractual relationship, you are only obligated to provide us with personal data that is necessary for the performance of our contract or in order to take those steps that are necessary for you voluntarily entering into a contract, e.g. contact data, contact person, and bank details.

2. Your right to object

You have the right to object at any time to the collection and processing of your personal data on grounds relating to your particular situation when collection and processing of such data was based on our legitimate business interests (GDPR Art. 6(1)(f)). This also applies to any profiling (GDPR Art. 4) that was based on our legitimate business interests (GDPR Art. 6(1)(f) GDPR).

If you object, we will no longer process your personal data, unless (1) we can prove compelling reasons to continue processing your personal data that outweigh your interests, rights, and freedoms; or (2) the processing serves to assert, exercise, or defend legal claims.

To object, please contact us via email or mail to:

eyeo GmbH
Lichtstraße 25
50825 Cologne
Germany

3. Subcontractors / processors

eyeo GmbH is currently using the following categories of subcontractors in connection with the processing of your personal data. These subcontractors have entered into data processing agreements with us and will only process your personal data under our instructions:

Category of subcontractors

Software service provider

Main subject of subcontracted services

Customer Relation Management (CRM) tool, office tool for communication and filing, synchronisation between email and CRM, collecting electronic signatures, invoicing, newsletter

Freelancer

Technical account management, contract support service

March 2019