Privacy Policy / Datenschutzerklärung

We are delighted by your interest in our company. Data protection is of paramount importance to the management of Si2 Partners|Si2 GmbH (Si2). Generally, it is possible to use the websites of Si2 without providing any personal data. However, if an individual wishes to avail themselves of specific services offered by our company through our website, processing of personal data may become necessary. If the processing of personal data is required and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, will always be in compliance with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Si2. Through this data protection statement, our company aims to inform the public about the type, scope, and purpose of the personal data we collect, use, and process. Moreover, through this data protection statement, data subjects are informed of the rights to which they are entitled.

Si2, as the controller, has implemented numerous technical and organizational measures to ensure the most comprehensive protection possible for personal data processed through this website. However, Internet-based data transmissions may inherently have security gaps, so absolute protection cannot be guaranteed. Therefore, every data subject is free to transfer personal data to us via alternative means, such as by telephone.

1. Definitions

The data protection declaration of Si2 GmbH is based on the terminology used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration is intended to be legible and understandable for the general public, as well as for our customers and business partners. To ensure this, we would like to clarify the terminology used.

In this data protection declaration, we use, among others, the following terms:

• a)    Personal Data

Personal data are 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, particularly 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.

• b)    Data Subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

• c)    Processing

Processing encompasses any operation or set of operations performed on personal data or on sets of personal data, with or without the aid of automated processes, 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.

• d)    Restriction of Processing

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

• e)    Profiling

Profiling refers to any form of automated processing of personal data consisting of using these personal data to evaluate certain personal aspects relating to a natural person, in particular, aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

• f)     Pseudonymization

Pseudonymisation is 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 ensuring that the personal data are not attributed to an identified or identifiable natural person.

• g)  Controller or Controller responsible for the Processing

The controller or controller responsible for the processing is 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.

• h)    Processor

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

• i)      Recipient

A recipient is 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 that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

• j)      Third Party

A third party refers to any natural or legal person, public authority, agency, or other body, other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

• k)    Consent

Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, by a statement or by a clear affirmative action, whereby the data subject signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller responsible for the processing:

The controller, for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union, and other provisions related to data protection is:

Si2 GmbH

Bruchhaeuser Weg 22

69124 Heidelberg

Baden-Württemberg

E-Mail: [email protected]

Website: www.si2partners.com

3. Cookies

The websites of Si2 use cookies. Cookies are text files that are stored and saved on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID, a unique identifier of the cookie. It consists of a string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual’s browser from other internet browsers that contain different cookies. A specific internet browser can be recognized and identified through the unique cookie ID.

The use of cookies enables Si2 to provide more user-friendly services to the users of this website, which would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. As mentioned, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. For example, a website user that employs cookies does not have to enter access data each time the website is accessed because this information is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies by our website through a corresponding setting of the internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be entirely usable.

4. Collection of General Data and Information

The website of Si2 Partners|Si2 GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. These general data and information are stored in the server’s log files. The data collected may include (1) the types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

In using these general data and information, Si2 GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) correctly deliver the content of our website, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Si2 GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

1. Registration on our Website 

The data subject has the opportunity to register on the website of the controller with the indication of personal data. The personal data transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for the controller’s own purposes. The controller may request transfer to one or more processors (e.g., a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

Furthermore, by registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) to the data subject, as well as the date and time of registration, are stored. The storage of this data takes place against the background that this is the only way to prevent misuse of our services, and, if necessary, to make it possible to investigate committed offenses. In this respect, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during registration at any time, or to have them completely deleted from the data stock of the controller.

The controller shall provide information upon request to each data subject as to what personal data are stored about the data subject. Furthermore, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

6. Subscription to our Newsletter

On the website of Si2, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the controller when ordering the newsletter is determined by the input mask used for this purpose.

Si2 periodically informs its customers and business partners about company offers through a newsletter. Our company’s newsletter can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter shipping. For legal reasons, a confirmation email will be sent to the email address initially provided by the data subject for newsletter shipping using the double opt-in procedure. This confirmation email serves to verify whether the owner of the email address as the data subject is authorized to receive the newsletter.

When registering for the newsletter, we also store the IP address of the computer system assigned by the Internet Service Provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the (possible) misuse of the email address of a data subject at a later date, and it, therefore, serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. Furthermore, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

7. Newsletter-Tracking

The newsletters of Si2 contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails that are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Si2 may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. Si2  automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact Options via the Website

Due to statutory requirements, the website of Si2 includes information enabling rapid electronic contact with our company, as well as direct communication with us, which also encompasses a general address of the so-called electronic mail (email address). If an affected person contacts the controller responsible for processing via email or through a contact form, the personal data transmitted by the affected person are automatically stored. Such personal data transmitted on a voluntary basis by an affected person to the controller responsible for processing are stored for the purpose of processing or contacting the affected person. No transfer of these personal data to third parties takes place.

9. Comment Function on the Blog on the Website

Si2 offers users the opportunity to leave individual comments on blog posts located on the website of the controller responsible for processing. A blog is a portal, usually publicly accessible on a website, where one or more people, referred to as bloggers or web bloggers, can post articles or write down thoughts in so-called blog posts. These blog posts can typically be commented on by third parties.

If an affected person leaves a comment on the blog published on this website, in addition to the comments left by the affected person, information on the time of the comment entry as well as the user name (pseudonym) chosen by the affected person are stored and published. Furthermore, the IP address assigned by the Internet Service Provider (ISP) of the affected person is logged. This storage of the IP address occurs for security reasons and in the event that the affected person infringes upon the rights of third parties or posts illegal content through a comment. Hence, the storage of these personal data is in the own interest of the controller responsible for processing, so as to potentially exculpate in case of a legal infringement. There is no transfer of these collected personal data to third parties, unless such a transfer is legally required or serves the defense rights of the controller responsible for processing.

10. Subscription to Comments on the Blog on the Website

Comments made in the blog of Si2 Partners|Si2 GmbH can generally be subscribed to by third parties. In particular, there is an option for a commentator to subscribe to subsequent comments on a specific blog post.

If an affected person opts for the subscription of comments, the controller responsible for processing sends an automatic confirmation email to double-check via the Double-Opt-In procedure whether the owner of the specified email address has chosen this option. The subscription to comments can be terminated at any time.

11. Routine Deletion and Blocking of Personal Data

The controller responsible for processing processes and stores personal data of the affected person only for the period necessary to achieve the purpose of storage or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

12. Rights of the Data Subject

• a)    Right to Confirmation

Every data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail themselves of this right of confirmation, they may, at any time, contact any representative of the controller.

• b)    Right of Access

Every data subject affected by the processing of personal data shall have the right granted by the European legislator to obtain at any time and free of charge from the controller, information about his or her stored personal data and a copy of this information. Furthermore, the European legislator has provided the data subject with access to the following information

• the purposes of the processing;

• the categories of personal data being processed;

• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

• the existence of the right to lodge a complaint with a supervisory authority;

• where the personal data are not collected from the data subject, any available information as to their source;

• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail themselves of this right of access, they may at any time contact any representative of the controller.

• c)  Right to Rectification

• Every data subject affected by the processing of personal data shall have the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  If a data subject wishes to exercise this right to rectification, they may at any time contact any employee of the controller.

  d)  Right to Erasure (Right to be Forgotten)

Every data subject affected by the processing of personal data shall have the right granted by the European legislator to require the controller to erase personal data concerning him or her without undue delay where one of the following grounds applies and insofar as the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

• The data subject withdraws consent on which the processing is based according to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing.

• The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

• The personal data have been unlawfully processed.

• The erasure of personal data is necessary for compliance with a legal obligation in Union or Member State law to which the controller is subject.

• The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

Where one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Si2, they may at any time contact any representative of the controller. The representative of Si2 will promptly ensure that the erasure request is complied with immediately.

Where the personal data have been made public by Si2 and Si2 is the controller pursuant to Article 17(1) of the GDPR to erase the personal data, Si2, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. A representative of Si2 shall arrange the necessary measures in individual cases.

• e)  Right to Restriction of Processing

Every data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.

• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.

• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored at Si2, they may at any time contact any representative of the controller. The representative of Si2 shall arrange the restriction of processing.

• f)    Right to Data Portability

Every data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. They shall also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may at any time contact any representative of Si2.

g)    Right to Object

Every data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Si2 shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

If Si2 processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Si2 to the processing for direct marketing purposes, Si2 will no longer process the personal data for these purposes.

Moreover, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Si2 for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may directly contact any representative of Si2. Furthermore, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is free to exercise his or her right to object by automated means using technical specifications.

h)  Automated Individual Decision-Making, Including Profiling

Every data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Si2 shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact any employee of the controller.

• i)    Right to Withdraw Consent under Data Protection Law

Every data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of the controller.

13. Data Protection in Applications and the Application Process

The controller responsible for processing shall collect and process the personal data of applicants for the purpose of handling the application process. The processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to the controller responsible for processing by electronic means, for example, by email or via a web form on the website. If the controller responsible for processing concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded between the controller responsible for processing and the applicant, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller responsible for processing oppose such erasure. Another legitimate interest in this respect could be a burden of proof in a procedure under the General Equal Treatment Act (Algemeines Gleichbehandlungsgesetz – AGG).

14. Legal Basis for Processing

Article 6(1)(a) of the GDPR serves as the legal basis for processing operations for which our company obtains consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of any other service or consideration, then processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, such as inquiries concerning our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, then processing is based on Article 6(1)(c) of the GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and his or her name, age, health insurance details, or other vital information had to be passed on to a doctor, hospital, or other third party. Then, processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations could be based on Article 6(1)(f) of the GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal grounds, when processing is necessary for the purposes of the legitimate interests pursued by our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not prevail. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. The legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

15. Legitimate Interests Pursued by the Controller or a Third Party

Where the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is to carry out our business activities in favor of the well-being of all our employees and shareholders.

16. Duration for which personal data will be stored

The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data are routinely deleted, provided they are no longer necessary for the fulfillment of the contract or the initiation of a contract.

17. Legal or Contractual Requirements for the Provision of Personal Data; Necessity for the Conclusion of a Contract; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Failure to Provide Such Data

We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of failing to provide the personal data.

18. Existence of Automated Decision-Making

As a responsible company, we do not use automated decision-making or profiling.

This privacy statement was created by the privacy statement generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external Data Protection Officer in the Upper Palatinate, in cooperation with the attorney for data protection law Christian Solmecke.