Data protection

Preface

We, Centroplan GmbH and our subsidiaries (hereinafter jointly:”the company“,”we“or”us“) take the protection of your personal data seriously and would like to take this opportunity to inform you about data protection in our company.

As part of our data protection responsibility as a result of the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) additional obligations have been imposed to protect the personal data of the person affected by processing (as the data subject, we will also refer to you below as the data subject “customer”, “user”, “They”, “You” or”Affected person“on).

Insofar as we decide on the purposes and means of data processing, either alone or together with others, this includes in particular the obligation to inform you transparently about the type, scope, purpose, duration and legal basis of the processing (see Articles 13 and 14 GDPR). With this statement (hereinafter:”Data protection notices“) we will inform you how we process your personal data.

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A. General

(1) Definitions

Following the example of Article 4 GDPR, this data protection notice is based on the following definitions:

— “Personal data” (Art. 4 No. 1 GDPR) is any information relating to an identified or identifiable natural person (“data subject”). An individual is identifiable when they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, an online identifier, location data or using information about their physical, physiological, genetic, psychological, economic, cultural or social identity characteristics. Identifiability can also be provided by combining such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or sound recordings may also contain personal data).

— “Processing” (Art. 4 No. 2 GDPR) is any process involving the handling of personal data, whether with or without the aid of automated (i.e. technology-based) procedures. This includes in particular the collection (i.e. procurement), recording, organization, ordering, storage, adaptation or modification, reading, querying, use, disclosure through transmission, dissemination or other provision, reconciliation, linking, restriction, deletion or destruction of personal data, and changing a goal or purpose that was originally the basis for data processing.

— “Responsible person” (Art. 4 No. 7 GDPR) is the natural or legal person, authority, agency or other body which, alone or together with others, decides on the purposes and means of processing personal data.

— “Third party” (Art. 4 No. 10 GDPR) is any natural or legal person, authority, agency or body other than the person concerned, the controller, the processor and the persons who, under the direct responsibility of the controller or processor, are authorized to process personal data; this also includes other corporate entities.

— “Processor” (Art. 4 No. 8 GDPR) is a natural or legal person, authority, agency or other body which processes personal data on behalf of the person responsible, in particular in accordance with his instructions (e.g. IT service provider). In terms of data protection law, a contract processor is in particular not a third party.

— “Consent” (Art. 4 No. 11 GDPR) of the data subject means any voluntary, informed and unequivocal statement of will made by the data subject in the form of a statement or other unequivocal affirmative act by which the data subject indicates that he or she agrees to the processing of personal data concerning him or her.

(2) Name and address of the person responsible for processing

The body responsible for processing your personal data within the meaning of Article 4 No. 7 of the GDPR is:

Centroplan GmbH
Robert-Koch-Straße 4
52499 Baesweiler

Telephone: +49 (2451) 911 30-0
Email: datenschutz@centroplan.de 

For more information about our company, please see the legal notice on our website https://centroplan.de/impressum .

(3) Contact details of the data protection officer

Our company data protection officer is available at any time if you have any questions and as a point of contact with us regarding data protection. His contact details are:

Centroplan GmbH
Robert-Koch-Straße 4
52499 Baesweiler

Telephone: +49 (2451) 911 30-0
email: datenschutz@centroplan.de 

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(4) Legal basis for data processing

In principle, any processing of personal data is prohibited by law and is only permitted if the data processing falls under one of the following justifications:

— Article 6 (1) (a) of the GDPR (“Consent”): If the person concerned has voluntarily, in an informed and unequivocal manner, by means of a statement or other unequivocal affirmative act, indicated that he agrees to the processing of personal data concerning him for one or more specific purposes;

— Article 6 (1) (1) (b) GDPR: If processing is necessary to fulfill a contract to which the data subject is a party or to carry out pre-contractual measures taken at the request of the person concerned;

— Article 6 (1) (1) (c) GDPR: If processing is necessary to fulfill a legal obligation to which the person responsible is subject (e.g. a legal storage obligation);

— Art. 6 (1) (d) GDPR: If processing is necessary to protect the vital interests of the data subject or of another natural person;

— Article 6 (1) (1) (e) GDPR: If processing is necessary for the performance of a task which is in the public interest or is carried out in the exercise of official authority delegated to the person responsible, or

— Article 6 (1) (1) (f) GDPR (“Legitimate Interests”): If processing is necessary to protect legitimate (in particular legal or economic) interests of the controller or of a third party, unless the conflicting interests or rights of the data subject prevail (in particular if the person concerned is a minor).

The storage of information in the end user's terminal equipment or access to information that is already stored in the terminal device is only permitted if it is covered by one of the following justifications:

— Section 25 (1) TTDSG: If the end user has consented on the basis of clear and comprehensive information. Consent must be given in accordance with Article 6 (1) (a) GDPR;

— Section 25 (2) No. 1 TTDSG: If the sole purpose is to carry out the transmission of a message via a public telecommunications network or

— Section 25 (2) No. 2 TTDSG: When storage or access is absolutely necessary so that the provider of a telemedia service can provide a telemedia service expressly requested by the user.

We provide the applicable legal basis for each of the processing operations carried out by us below. Processing may also be based on several legal bases.

(5) Data deletion and storage period

For the processing operations we carry out, we indicate below how long we store the data and when it will be deleted or blocked. Unless an express storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage ceases to apply. In principle, your data will only be stored on our servers in Germany, subject to any transfer in accordance with the regulations in A. (7) and A. (8).

However, storage may take place beyond the specified time in the event of an (imminent) legal dispute with you or other legal proceedings or if storage is provided for by legal regulations to which we are subject as the person responsible (e.g. § 257 HGB, § 147 AO). When the storage period required by legal regulations expires, the personal data will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for this.

(6) Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction or against unauthorized access by third parties (e.g. TLS encryption for our website), taking into account the state of the art, implementation costs and the nature, scope, context and purpose of processing as well as the existing risks of a data breach (including its probability and effects) for the person concerned. Our security measures are constantly being improved in line with technological developments.

We will be happy to provide you with more detailed information on this subject upon request. To do so, please contact our data protection officer (see A. (3)).

(7) Cooperation with contract processors

As with any larger company, we also use external domestic and foreign service providers to process our business transactions (e.g. Webflow, Inc. as host provider). They only act in accordance with our instructions and have been contractually obliged within the meaning of Article 28 GDPR to comply with data protection regulations.

If personal data from you is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.

(8) Requirements for the transfer of personal data to third countries

As part of our business relationships, your personal data may be passed on or disclosed to third companies. They may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing is carried out exclusively to fulfill contractual and business obligations and to maintain your business relationship with us (the legal basis is Art. 6 para. 1 lit b or lit. f in each case in conjunction with Art. 44 et seq. of the GDPR). We will inform you of the relevant details of the transfer below at the relevant points.

Through so-called adequacy decisions, the European Commission certifies that some third countries have data protection that is comparable to the EEA standard (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, there may be no consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding corporate regulations, European Commission standard contractual clauses for the protection of personal data in accordance with Art. 46 para. 1, 2 lit. c GDPR (the standard contractual clauses of 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates or recognized codes of conduct. Please contact our data protection officer (see A. (3)) if you would like to receive more information about this.

(9) No automated decision-making (including profiling)

We have no intention of using personal data collected from you for an automated decision making process (including profiling).

(10) No obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing us with personal data beforehand. In principle, there is also no legal or contractual obligation for you as a customer to provide us with your personal data; however, we may only be able to provide certain offers to a limited extent or not at all if you do not provide the necessary data. If this is exceptionally the case as part of the products we offer below, you will be notified separately.

(11) Legal obligation to provide certain data

Under certain circumstances, we may be subject to a particular legal or legal obligation to provide the lawfully processed personal data to third parties, in particular public bodies (Art. 6 (1) (c) GDPR).

(12) Your rights

You can assert your rights as a data subject with regard to your processed personal data at any time using the contact details provided under A. (2) above. As a data subject, you have the right to:

— to request information about your data processed by us in accordance with Article 15 of the GDPR. In particular, you can provide information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right of correction, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of their data, unless they were collected by us, as well as the existence of automated decision-making, including profiling and, if applicable, meaningful information about their details demand;

— to immediately request the correction of incorrect data stored by us or the completion of your data stored by us in accordance with Article 16 of the GDPR;

— to request the deletion of your data stored by us in accordance with Article 17 GDPR, unless processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;

— to request the restriction of the processing of your data in accordance with Article 18 of the GDPR, insofar as the accuracy of the data is disputed by you or the processing is unlawful;

— in accordance with Article 20 GDPR, to receive your data that you have provided to us in a structured, common and machine-readable format or to request transmission to another person responsible (“data portability”);

— to object to processing in accordance with Article 21 GDPR, provided that processing is carried out on the basis of Article 6 (1) (e) or (f) GDPR. This is particularly the case if processing is not necessary to fulfill a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the situation and will either stop or adjust data processing or show you our compelling legitimate reasons for continuing processing;

— in accordance with Article 7 (3) of the GDPR, your consent given once (even before the GDPR came into force, i.e. before 25.5.2018) — i.e. your voluntary, informed and unequivocal will to us that you agree to the processing of the relevant personal data for one or more specific purposes — at any time, if you have provided such consent. As a result, we are no longer allowed to continue data processing based on this consent in the future and

— in accordance with Article 77 GDPR, to complain to a data protection supervisory authority about the processing of your personal data in our company, such as the data protection supervisory authority responsible for us: State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia, Kavalleriestrasse 2-4, 40213 Düsseldorf, e-mail: behoerdlicher-dsb@ldi.nrw.de .

(13) Changes to the privacy policy

As part of the further development of data protection law and technological or organizational changes, our data protection information is regularly reviewed for the need for adjustments or additions. In particular, you will be notified of any changes on our German website at https://centroplan.de/ teaches. This privacy policy was last updated on Feb. 19, 2024.

B. Visiting websites

(1) Explanation of the function

Information about our companies and the services we offer can be found in particular at [address of the company's website] including the associated sub-pages (hereinafter collectively: “websites”). When you visit our websites, your personal data may be processed.

(2) Personal data processed

When using the websites for informational purposes, we collect, store and further process the following categories of personal data:

“Log data”: When you visit our websites, a so-called log data set (so-called server log files) is temporarily and anonymously stored on our web server. It consists of:

— the page from which the page was requested (so-called referrer URL)

— the name and URL of the requested page

— the date and time of the call

— the description of the type, language and version of the web browser used

— the IP address of the requesting computer, which is abbreviated so that a personal reference can no longer be established

— the amount of data transferred

— the operating system

— the message as to whether the call was successful (access status/http status code)

— the GMT time zone difference

“Contact form data”: When using contact forms, the data transmitted as a result is processed (e.g. gender, last name and first name, address, company, e-mail address and time of transmission).

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(3) Purpose and legal basis of data processing

We process the personal data described in more detail above in accordance with the provisions of the GDPR, other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Article 6 (1) (f) GDPR, the stated purposes also represent our legitimate interests.

The processing of log data is for statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (the legal basis is Article 6 (1) (a) or (f) GDPR).

Contact form data is processed to process customer inquiries (the legal basis is Art. 6 (1) (b) or (f) GDPR).

If processing the data requires the storage of information in your terminal device or access to information that is already stored in the terminal device, Section 25 (1), 2 TTDSG is the legal basis for this.

(4) Duration of data processing

Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases specified in the context of the processing purposes apply mutatis mutandis. With regard to the use and storage period of cookies, please refer to point A. (5).

Third parties used by us will store your data on their systems for as long as is necessary in connection with the provision of services to us in accordance with the respective order.

You can also find more information about the storage period under A. (5).

(5) Transfer of personal data to third parties; basis of justification

The following categories of recipients, who are usually contract processors (see A. (7)), may have access to your personal data:

— Service providers for operating our website and processing the data stored or transmitted by the systems (e.g. for data center services, payment transactions, IT security). The legal basis for the transfer is then Article 6 (1) (b) or (f) GDPR, unless they are contract processors;

— Government agencies/authorities, insofar as this is necessary to comply with a legal obligation. The legal basis for the transfer is then Article 6 (1) (c) GDPR;

— Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the transfer is then Article 6 (1) (b) or (f) GDPR

For guarantees of an adequate level of data protection when data is transferred to third countries, see A. (8).

In addition, we will only pass on your personal data to third parties if you have given your express consent to do so in accordance with Article 6 (1) (a) of the GDPR.

(6) Use of cookies, plug-ins and other services on our website

a) Cookies

We use cookies on our websites. Cookies are small text files which are assigned and stored on your hard drive to the browser you use using a characteristic string of characters and through which certain information flows to the location that sets the cookie. Cookies cannot run programs or transfer viruses to your computer and therefore do not cause any damage. They serve to make the website more user-friendly and effective overall, i.e. more pleasant for you.

Cookies can contain data that makes it possible to recognize the device used. However, in some cases, cookies only contain information about certain settings that are not personally identifiable. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, cookies in turn differentiate between:

— Technical cookies: These are absolutely necessary to move around the website, use basic functions and ensure the security of the website; they neither collect information about you for marketing purposes nor do they store which websites you have visited;

— Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether website usage errors occur; they do not collect any information that could identify you — all information collected is anonymous and is only used to improve our website and find out what interests our users;

— Advertising cookies, targeting cookies: These are used to offer website users tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;

— Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.

The legal basis for cookies, which are absolutely necessary to provide you with the expressly requested service, is Section 25 (2) No. 2 TTDSG. Any use of cookies that is not necessarily technically necessary for this purpose constitutes data processing that is only permitted with your express and active consent in accordance with Section 25 (1) TTDSG in conjunction with Art. 6 (1) (a) GDPR. This applies in particular to the use of performance, advertising, targeting or sharing cookies. In addition, we will only pass on your personal data processed through cookies to third parties if you have given your express consent to do so in accordance with Article 6 (1) (a) GDPR.

b) Cookies used

In addition to technically necessary cookies, we use cookies and comparable technologies on our websites that are not strictly necessary – in particular for reach measurement and for embedding videos. These are set only after you have given your consent.

An up-to-date overview of all services used, of the data processed in each case and of the storage period of the individual cookies can be found in our consent settings, which you can open via the "Cookie settings" link in the footer of our websites. There you can change or withdraw your selection at any time with effect for the future.

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c) Consent management

To obtain, manage and document your consent, we use the consent management platform "Usercentrics". The provider is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany.

When you access our websites, a connection to the servers of Usercentrics is established in order to display the consent banner to you and to store your selection. In this process, your IP address, information about your browser, device and operating system, the date and time of your visit as well as your consent decision are processed. This information is stored on your device so that your selection is retained on subsequent visits.

The use of Usercentrics is necessary in order to fulfil our statutory obligation to demonstrate the consent granted. The legal basis is Art. 6 (1) sentence 1 lit. c GDPR in conjunction with Art. 7 (1) GDPR. Storing the information required for this purpose on your device is permitted without consent pursuant to Section 25 (2) no. 2 TDDDG, as it is strictly necessary. The consent data is stored for a period of three years.

Further information can be found in the privacy policy of Usercentrics at https://usercentrics.com/de/datenschutzerklaerung/.

d) Google reCAPTCHA

To protect our online forms against misuse and automated entries, we use the reCAPTCHA service. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA checks whether an entry in a form is made by a human being or by an automated program. For this purpose, the service analyses user behaviour on the basis of various characteristics. The data processed includes in particular the IP address, information about the browser and operating system used, the time spent on the page, mouse and keyboard movements, the previously visited page as well as information that Google stores in cookies on your device or reads from it. The data collected is transmitted to Google and evaluated there.

The legal basis for the processing is your consent pursuant to Art. 6 (1) sentence 1 lit. a GDPR. Information is stored on your device and accessed on the basis of Section 25 (1) TDDDG. You may withdraw your consent at any time with effect for the future by changing your selection in the cookie settings.

Without your consent to this service, we are unable to protect the form against misuse; submission is then not possible. In this case you can reach us at any time by e-mail at info@centroplan.de or by telephone at +49 2451 91130-0.

A transfer of your data to the USA cannot be ruled out. Google LLC is certified under the EU-US Data Privacy Framework; an adequacy decision of the European Commission therefore exists for transfers to the USA.

Further information can be found in Google's privacy policy at https://policies.google.com/privacy and in the terms of service at https://policies.google.com/terms.

e) Embedding of YouTube videos

We embed videos from the YouTube platform on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter "Google").

The videos are embedded in extended data protection mode (domain youtube-nocookie.com). In addition, the videos are loaded only after your express consent. As long as you have not given consent, you will see only a preview image that is delivered from our own server. In this state, no connection to Google's servers takes place.

Only when you activate the video by clicking on it is a connection to Google's servers established. Google is thereby informed which of our pages you have accessed. Google may process your IP address as well as further information about your browser and device and store cookies or comparable technologies on your device. If you are logged into your YouTube account at that time, Google can attribute your usage behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account before playback.

The legal basis for storing information on your device and accessing it is your consent pursuant to Section 25 (1) TDDDG. The legal basis for the subsequent processing of personal data is Art. 6 (1) sentence 1 lit. a GDPR. You give your consent via our consent management tool; you may withdraw it at any time with effect for the future via the cookie settings.

A transfer of your data to the USA cannot be ruled out. Further information on the handling of user data can be found in Google's privacy policy at https://policies.google.com/privacy.

f) Google Analytics

We use the web analytics service "Google Analytics 4". The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter "Google").

Google Analytics uses cookies and comparable technologies that enable an analysis of your use of our websites. The data recorded includes in particular the pages accessed, the date and duration of the visit, the previously visited page (referrer URL), information about the browser, device and operating system, the approximate geographical area of your access as well as your truncated IP address. Your IP address is truncated by Google within the member states of the European Union and of the European Economic Area and is not combined with other data held by Google.

The purpose of the processing is to evaluate the use of our websites, to compile reports on website activity as well as to design our offering in line with requirements and improve it continuously. The legal basis is your consent pursuant to Art. 6 (1) sentence 1 lit. a GDPR and Section 25 (1) TDDDG. You may withdraw your consent at any time with effect for the future via the "Cookie settings" link in the footer of our websites. The retention period is 14 months for user data and 2 months for event data.

A transfer of your data to Google LLC in the USA cannot be ruled out. Google LLC is certified under the EU-US Data Privacy Framework, for which the European Commission determined an adequate level of data protection by decision of 10 July 2023 (see A.(8)). A data processing agreement is in place with Google.

You can additionally prevent collection by Google Analytics by installing the browser add-on available at https://tools.google.com/dlpage/gaoptout. Further information on the handling of user data can be found at https://policies.google.com/privacy.

g) Hosting

Our websites are hosted by Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA. On our behalf, Webflow processes the data arising when our websites are accessed, in particular the log data referred to under B.(2), as well as the information submitted via our forms.

The legal basis is Art. 6 (1) sentence 1 lit. f GDPR; our legitimate interest lies in providing our online offering securely, stably and efficiently. A data processing agreement pursuant to Art. 28 GDPR is in place with Webflow. Personal data is transferred to the USA on the basis of the European Commission's standard contractual clauses (see A.(8)).

Further information can be found in Webflow's privacy policy at https://webflow.com/legal/privacy.

h) Contact and appointment requests

You can send us enquiries via the forms on our websites. The data you provide is processed, in particular your name, company, e-mail address, telephone number and the details of your request, as well as the time of submission.

The purpose of the processing is to handle and respond to your enquiry. The legal basis is Art. 6 (1) sentence 1 lit. b GDPR insofar as your enquiry is directed towards the conclusion of a contract, and otherwise Art. 6 (1) sentence 1 lit. f GDPR on the basis of our legitimate interest in responding to enquiries. Your details will be deleted as soon as your enquiry has been dealt with conclusively and no statutory retention obligations conflict with this.

i) Applications via our careers portal

Our job advertisements and the application form are provided via the applicant management software "Personio". The provider is Personio SE & Co. KG, Seidlstraße 3, 80335 Munich, Germany. If you follow a job advertisement on our websites, you will be redirected to a page operated by Personio at the address centroplan-gmbh.jobs.personio.de.

We process the application data handled there (in particular your contact details, your cover letter, CV and references) in order to carry out the application procedure. The legal basis is Section 26 (1) BDSG (German Federal Data Protection Act) in conjunction with Art. 6 (1) sentence 1 lit. b GDPR. Personio acts for us as a processor pursuant to Art. 28 GDPR; the data is stored on servers within the European Union. After the procedure has been completed, your data will be deleted after six months at the latest, unless you have consented to longer storage for our talent pool.