I. General information
The protection of your personal data is an important concern for us. In the following, we would therefore like to inform you in detail about which data we collect from you, on the one hand, within the framework of current business relationships and, on the other hand, when you visit our website and use our offers there, and how this data is processed or used by us in the following and which rights you are entitled to in this respect.
Your personal data will only be processed by us on the basis of the statutory data protection law, i.e. the EU Data Protection Basic Regulation (GDPR), the German Federal Data Protection Act (BDSG-neu) and the German Telemedia Act (TMG).
The scope of the data collected and processed by us differs according to whether you only visit our website to call up information or also make use of services offered by us via our website.
Our data protection declaration uses the terms of the EU Data Protection Basic Regulation (GDPR), which we would like to explain briefly for your convenience. You will find these and other definitions in Art. 4 GDPR.
1. 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;
2. Data subject
‘data subject’ means any identified or identifiable natural person whose personal data are processed by the controller.
‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, 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’ means the marking of stored personal data with the aim of limiting their processing in the future;
‘pseudonymisation’ means the processing of personal data in such a manner 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 to ensure that the personal data are not attributed to an identified or identifiable natural person;
‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the 4.5.2016 EN Official Journal of the European Union L 119/33 framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
9. Third party
‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
III. Name and address of the comntroller
Controller within the meaning of the General Data Protection Regulation is:
Pyrum Innovations AG,– www.pyrum.net -
Pascal Klein (CEO)
Phone: +49 6831 959 48 0
Fax: +49 6831 959 48 30
IV. Name and contact details of the data protection officer
The data protection officer of the controller is:
Herr Oliver Pikolleck
externer Datenschutzbeauftragter (TÜV-cert.)
V. General information on data processing
1. Categories of personal data
We process the following categories of personal data:
• Existing data (e.g. names, addresses, functions, organisational affiliation etc.);
• contact data (e.g. e-mail, telephone/fax numbers etc.);
· Content data (e.g. text entries, image files, videos etc.);
· usage data (e.g. access data);
· meta/communication data (e.g. IP addresses).
2. recipients or categories of recipients of personal data
If, in the course of our processing, we disclose data to other persons and companies such as web hosters, contract processors or third parties, transfer it to them or otherwise grant them access to the data, this is done on the basis of a legal authorisation (e.g. if transfer of the data to third parties is required in accordance with Art. 6 para. 1 lit. b GDPR for the fulfilment of a contract), if the persons concerned have consented or a legal obligation provides for this.
3. Duration of storage of personal data
The criterion for the duration of the storage of personal data is the respective legal retention period. After expiry of the period, the corresponding data will be deleted if they are no longer required for achieving the purpose, fulfilling the contract or initiating a contract.
4. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or if we disclose or transfer data to third parties, this only takes place if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special conditions of Art. 44 ff. GDPR, i.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection equivalent to that in the EU or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").
VI. Data processing within the scope of visiting our website
1. Log files
Every time a data subject accesses our website, general data and information are stored in the log files of our system:
• Date and time of the retrieval (time stamp);
• request details and destination address (protocol version, HTTP method, referrer, UserAgent string);
· Name of the retrieved file and transferred data volume (requested URL incl. query string, size in bytes);
· message whether the retrieval was successful (HTTP status code).
When using this general data and information, we do not draw any conclusions about the data subject. There is no personal evaluation or an evaluation of the data for marketing purposes or a profile formation. The IP address is not saved in this context.
The legal basis for the temporary storage of data is Art. 6 Para. 1 lit. f GDPR. The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the secure operation of our website. There is therefore no possibility for the person concerned to object.
2. Malware detection and protocol data evaluation
We collect protocol data that is generated during the operation of our company's communication technology and evaluate it automatically, insofar as this is necessary to detect, limit or eliminate faults or errors in the communication technology or to defend against attacks on our information technology or to detect and defend against malware.
The legal basis for the temporary storage and evaluation of data is Art. 6 para. 1 lit. f GDPR. The storage and evaluation of the data is absolutely necessary for the provision of the website and for its secure operation. There is therefore no possibility for the person concerned to object.
The legal basis for the processing of personal data using Coo-kies is Art. 6 para. 1 lit. f GDPR.
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services which we use for the purpose of operating our website.
For this purpose, we or our contract processor process inventory data, contact data, content data, contract data, usage data, meta and communication data of users of our website on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for contract processing).
VII. data processing at the time of contact
1. Contact by e-mail
You can contact our company by e-mail using the e-mail addresses published on our website.
If you use this method of contact, the data transmitted by you (e.g. name, first name, address), at least however the e-mail address, as well as the information contained in the e-mail together with any personal data transmitted by you will be stored for the purpose of establishing contact and processing your request. In addition, the following data is collected by our system:
• IP address of the calling computer;
• date and time of the e-mail.
The legal basis for the processing of personal data in the context of e-mails sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.
2. Contact via website contact form
If you use the contact form provided on our website for communication purposes, it is necessary to enter your name and surname and your e-mail address. Without these data, your request transmitted via the contact form cannot be processed. Entering your address is optional and enables us to process your request by post if you so wish.
In addition, the following data is collected by our system:
• IP address of the calling computer;
• date and time of registration.
The legal basis for the processing of personal data in the context of e-mails sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.
3. Contact by letter
If you send us a letter, the data transmitted by you (e.g. name, first name, address) and the information contained in the letter or fax, together with any personal data you may have transmitted, will be stored for the purpose of establishing contact and processing your request.
The legal basis for the processing of personal data in the context of letters and faxes sent to us is Art. 6 para. 1 lit. b or lit. f GDPR.
4. data processing during videoconferences
We use the tools "Zoom", "Microsoft Teams", "Jitsi", and "Whereby" to conduct video conferences, teleconferences, online meetings, and/or web seminars (hereinafter: "video conferences"). The providers of the aforementioned tools are mostly located in the USA. When using the above-mentioned tools, the following types of data are processed. The scope of the data processing depends, among other things, on the personal data you provide before or during participation in a video conference.
The following personal data may be the subject of processing:
User details: first name, last name, telephone, e-mail address, password, image.
Conference data: Subject, description, participant IP addresses, hardware information.
In case of recordings (optional): MP4 file of all video, audio and content recordings, M4A file of all audio recordings, text file of the online meeting chat.
For dial-in via telephone: information on incoming and outgoing phone number, country name, start and end time. If necessary, further connection data such as the IP address of the device can be stored.
Video, audio and text data: You may have the opportunity to use the chat, inquiry or survey functions in a video conference. To this extent, the entries you make are processed in order to display them in the video conference and, if necessary, to log them. In order to enable the display of video and the playback of audio, the data of the microphone of your terminal device as well as any video recording via camera will be processed accordingly for the duration of the meeting. You can turn off or mute the camera or microphone yourself at any time using the appropriate buttons.
In order to participate in a video conference or to enter the "meeting room", you must at least provide information about your name.
Scope of Processing:
If we want to record videoconferences, we will notify you in advance and - if necessary - ask for your consent. The fact of the recording will also be displayed to you in the conferencing tool. If it is necessary for the purposes of logging the results of an online meeting, we will log the chat content. However, this will generally not be the case. In the case of web seminars, we may also process the questions asked by seminar participants for the purposes of recording and following up on webinars. If you are registered as a user with the providers of the above-mentioned tools, then reports on video conferences (metadata, data on telephone dial-in, questions and answers in webinars, survey function in webinars) may be stored for up to one month with the respective provider. Automated decision-making within the meaning of Art. 22 DSGVO does not take place.
The aforementioned tools are services of providers that may be provided from the USA. A processing of personal data may therefore also take place in a third country (USA). We have concluded EU standard contractual clauses and order processing agreements with the providers of the above-mentioned tools, which comply with the requirements of Art. 28 DSGVO.
The legal basis for data processing when conducting video conferences is Art. 6 (1) (b) DSGVO, insofar as the video conferences are conducted in the context of contractual relationships. If there is no contractual relationship, the legal basis is Art. 6 (1) (f) DSGVO. Here, our interest is in the effective implementation of video conferences.
VIII. data processing when receiving our newsletter
If you subscribe to our newsletter distribution list, your e-mail address and the newsletter you have chosen will be stored on a server by us.
In addition, the following data is collected by the system when you register:
• IP address of the calling computer;
• date and time of registration.
For the processing of the data, your consent will be obtained during the registration process and reference will be made to this data protection declaration. The data will be processed on the basis of your consent in accordance with Art. 6 para. 1 letter a GDPR and within the scope of the legitimate interest in accordance with Art. 6 para. 1 letter f GDPR.
We use this data exclusively for sending the newsletter. The registration system with an additional confirmation message containing a link to the final registration (double opt-in) ensures that the newsletter was requested by you and not by a third party. During registration your data is stored on our servers and a confirmation message with a link to the final registration is generated to the specified e-mail address. Only after confirmation of the link in the e-mail will your data for sending the newsletter be stored for the duration of your use of our offer.
If you no longer agree with the storage of your data for this purpose and thus no longer wish to use our offer, you can unsubscribe from our newsletter at any time. For this purpose you will find a corresponding link in every newsletter. The personal data provided by you to subscribe to our newsletter will then be deleted.
Use of the service provider "EQS Group AG ".
Our newsletter is sent using "EQS", an application of EQS Group AG, Karlstraße 47, D-80333 Munich. The e-mail addresses of the recipients of our newsletter, as well as their other data described in this data protection notice, are stored on the servers of EQS Group AG. EQS uses this information to send and evaluate the newsletters on our behalf. We have concluded an order processing agreement with EQS Group AG, in which EQS Group AG undertakes to protect the data of our users, to process it on our behalf in accordance with its data protection provisions and, in particular, not to pass it on to third parties.
Statistical collection and analyses
Our newsletters contain a so-called "web beacon", i.e. a file that is retrieved from the MailChimp server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser you are using and your system, as well as your IP address and retrieval time are collected. This information is used for the technical improvement of the services. The statistical surveys also include the determination of whether and when the newsletter is opened and which links are activated.
Unsubscribing from the newsletter
You can unsubscribe from our newsletter at any time. At the same time, your consent to the sending of the newsletter via EQS and the statistical analyses will expire. A separate cancellation of the dispatch via EQS or the statistical analysis is unfortunately not possible.
You will find a link to cancel the newsletter at the end of each newsletter.
The legal basis for the processing of personal data in the context of the newsletter dispatch via EQS is Art. 6 para. 1 lit. a DSGVO.
IX. Your rights
As a data subject, you have the following rights in connection with the processing of your personal data:
1. Right of access to information
(1) The data subject shall have the right to obtain confirmation from the controller as to whether personal data relating to him/her are being processed; if this is the case, he/she shall have the right to be informed of such personal data and to receive the following information:
a) the processing purposes;
b) the categories of personal data processed;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations;
d) if possible, the envisaged period for which the personal data will be stored or, if that is not possible, the criteria for determining that period;
e) the existence of a right of rectification or erasure of personal data relating to them or of a right of objection to their processing by the controller;
f) the existence of a right of appeal to a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;
h) h) the existence of automated decision-making, including profiling, in accordance with Art. 22, para. 1 and para. 4 GDPR, and, at least in these cases, meaningful information on the logic involved and the scope and intended effects of such processing on the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR in connection with the transfer.
2. Right of rectification
The data subject has the right to ask the data controller to rectify incorrect personal data concerning him/her without delay. Having regard to the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration.
3. Right of deletion
(1) The data subject has the right to request the controller to delete personal data relating to him/her without delay and the controller is obliged to delete personal data without delay if one of the following reasons applies:
a) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed
b) b) The data subject withdraws the consent on which the processing was based pursuant to Art. 6 para. 1 letter a) or Art. 9 para. 2 letter a) GDPR and there is no other legal basis for the processing.
c) The data subject lodges an objection to the processing pursuant to Art. 21 Para. 1 GDPR and there are no overriding legitimate reasons for the processing, or the data subject lodges an objection to the processing pursuant to Art. 21 Para. 2 GDPR.
d) The personal data have been processed unlawfully.
e) (e) erasure of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject
f) The personal data was collected in relation to services offered by the information society in accordance with Art. 8, Paragraph 1 of the GDPR.
(2) Where the controller has made personal data public and is obliged to delete them pursuant to paragraph 1, he shall take reasonable measures, including technical measures, taking into account available technology and implementation costs, to inform controllers who process personal data that a data subject has requested them to delete all links to such personal data or to delete copies or replications of such personal data.
(3) Paragraphs 1 and 2 shall not apply insofar as the processing is necessary:
a) to exercise the right to freedom of expression and information;
b) to comply with a legal obligation requiring processing under Union or national law to which the controller is subject or in the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
c) c) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 letters h) and i) and Art. 9 para. 3 GDPR;
d) d) for archiving, scientific or historical research purposes in the public interest or for statistical purposes in accordance with Art. 89 para. 1, insofar as the law referred to in para. 1 is likely to render impossible or seriously prejudice the attainment of the objectives of such processing, or
e) (e) to assert, exercise or defend legal claims.
4. Right to restrict processing
(1) The data subject has the right to ask the person responsible to restrict processing if one of the following conditions is met:
a) the accuracy of the personal data is disputed by the data subject, for a period enabling the controller to verify the accuracy of the personal data
b) the processing is unlawful and the data subject refuses to have the personal data deleted and instead requests that the use of the personal data be restricted;
c) the controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to exercise or defend his rights; or
d) d) the data subject has lodged an objection to the processing in accordance with Art. 21 para. 1 GDPR as long as it has not yet been established whether the legitimate reasons of the controller outweigh those of the data subject.
(2) Where processing has been restricted in accordance with paragraph 1, such personal data may be processed, with the exception of storage, only with the consent of the data subject or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or of a Member State.
5. Right to data transferability
(1) The data subject shall have the right to obtain the personal data concerning him which he has supplied to a controller in a structured, standard and machine-readable format and the right to have such data communicated to another controller without interference by the controller to whom the personal data has been supplied, provided that
a) the processing is based on a consent pursuant to Article 6 paragraph 1 letter a) or Article 9 paragraph 2 letter a) GDPR or on a contract pursuant to Article 6 paragraph 1 letter b) GDPR and
b) (b) the processing is carried out by means of automated procedures.
In exercising his or her right to transfer data in accordance with paragraph 1, the data subject shall have the right to obtain that personal data be transferred directly from one controller to another controller, in so far as this is technically feasible.
The right referred to in paragraph 1 must not prejudice the rights and freedoms of other persons.
This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
6. Right of objection
The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out pursuant to Article 6, paragraph 1, letters e) or f) of the GDPR, including profiling based on these provisions. The controller no longer processes the personal data unless he can demonstrate compelling reasons for processing which are justified on grounds of protection and which outweigh the interests, rights and freedoms of the data subject, or unless the processing serves to assert, exercise or defend legal claims.
In the context of the use of Information Society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his right of objection by means of automated procedures involving technical specifications.
7. Right of withdrawal
The data subject has the right to revoke his/her declaration of consent under data protection law at any time. Revocation of consent does not affect the lawfulness of the processing carried out on the basis of consent up to the point of revocation.
8. Right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to complain to a supervisory authority, in particular in the Member State in which he/she is resident, at his/her place of work or at the place where the alleged infringement occurred, if he/she considers that the processing of personal data relating to him/her is being carried out in breach of this Regulation.
We reserve the right to change these data protection provisions at any time with effect for the future. A current version is available on the website. Please visit the website regularly and inform yourself about the applicable data protection regulations.