As of January 2024
Table of contents
I. Identity and contact details of the data controller
II. Contact details of the data protection officer
III. General information on data processing
IV. Rights of the data subject
V. Provision of the CONEXO Portal and creation of log files
VI. Use of cookies
VII. Contact via Email
VIII. Hosting
IX. Registration
X. Amendment of the Privacy Policy
I. Identity and contact details of the data controller
The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:
inevvo solutions GmbH & Co. KG
Fritz-Müller-Platz 1
74676 Niedernhall
Germany
II. Contact details of the data protection officer
The designated data protection officer of the data controller can be reached at .
III. General information on data processing
1. Scope of processing personal data
In general, we only process the personal data of our users to the extent necessary in order to provide a functioning CONEXO Portal with our content and services. The processing of personal data regularly only takes place with the consent of the user. Exceptions include cases where prior consent technically cannot be obtained and where the processing of the data is required by law.
2. Legal basis for data processing
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 para. (1) sen. (1) lit. (a) GDPR serves as the legal basis.
As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 para. (1) sen. (1) lit. (b) GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.
When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 para. (1) sen. (1) lit. (c) GDPR serves as the legal basis.
If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. (1) sen. (1) lit. (d) GDPR serves as the legal basis.
If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 para. (1) sen. (1) lit. (f) GDPR will serve as the legal basis for the processing of data.
3. Data removal and storage duration
The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if it was provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.
IV. Rights of the data subject
When your personal data is processed, you are subsequently a data subject in the sense of the GDPR and have the following rights:
1. Right to information
You may request from the data controller to confirm whether your personal data is processed by them.
If such processing is the case, you can request the following information from the data controller:
- The purpose for which the personal data is processed;
- The categories of personal data being processed;
- The recipients or categories of recipients to whom the personal data relating to you have been disclosed or are still being disclosed;
- The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;
- The existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the data controller or a right to object to such processing;
- The existence of a right of appeal to a supervisory authority;
- All available information on the source of the data if the personal data is not collected from the data subject;
- The existence of automated decision-making including profiling under Article 22 para. (1) and para. (4) GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.
You have the right to request information on whether your personal data will be transmitted to a third country or an international organisation. In this context, you can then request to be informed about the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transfer.
2. Right to rectification
You have a right of rectification and/or completion vis-à-vis the data controller, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.
3. Right to the restriction of processing
You may request the restriction of the processing of your personal data under the following conditions:
- If you challenge the correctness of your personal data for a period of time that enables the data controller to verify the accuracy of your personal data;
- The processing is unlawful, and you refuse the erasure of the personal data and instead demand the restriction of the use of the personal data;
- The representative no longer needs the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
- If you have objected to the processing pursuant to Art. 21 para. (1) GDPR and it is not yet certain whether the legitimate reasons of the data controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest, interest to the Union, or a Member State.
If the processing has been restricted according to the beforementioned conditions, you will be informed by the data controller before the restriction is lifted.
4. Right to erasure
a) Obligation to erase
If you request from the data controller to delete your personal data with immediate effect, they are required to do so immediately given that one of the following applies:
- Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
- You withdraw your consent, to which the processing is allowed pursuant to Art. 6 para. (1) sen. (1) lit. (a) GDPR or Art. 9 para. (2) lit. (a) GDPR and there is no other legal basis for processing the data.
- According to Art. 21 para. (1) GDPR you object to the processing of the data given that the processing of the data is justified by a legitimate interest, or you object pursuant to Art. 21 para. (2) GDPR.
- Your personal data has been processed unlawfully.
- The act of deleting your personal data will invoke a legal obligation under the Union law or the law of the Member States to which the data controller is subject.
- Your personal data was collected in relation to information society services offered pursuant to Art. 8 para. (1) GDPR.
b) Information to third parties
If the data controller has made your personal data public and has to delete the data pursuant to Art. 17 para. (1) GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.
c) Exceptions
The right to deletion does not exist if the processing is necessary
- to exercise the right to freedom of speech and information;
- to fulfil a legal obligation required by the law of the Union or of the Member States to which the representative is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative;
- for reasons of public interest in the field of public health pursuant to Art. 9 para. (2) lit. (h) and (i) and Art. 9 para. (3) GDPR;
- for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. (1) GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
- to enforce, exercise or defend legal claims.
5. Right to information
If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.
You reserve the right to be informed about the recipients of your data by the data controller.
6. Right to data portability
You have the right to receive your personal data given to the data controller in a structured, standard and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, given that
- the processing is based on a consent in accordance with Art. 6 para. (1) sen. (1) lit. (a) GDPR or Art. 9 para. (2) lit. (a) GDPR or on a contract in accordance with Art. 6 para. (1) sen. (1) lit. (b) GDPR and
- the processing is done by automated means.
In exercising this right, you also have the right to maintain that your personal data relating to you are transmitted directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.
7. Right to object
Subjective to your situation, you have, at any time, the right to object against the processing of your personal data pursuant to Art. 6 para. (1) sen. (1) lit. (e) or (f) GDPR; this also applies to profiling based on these provisions.
The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling insofar as it is associated with direct marketing.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.
8. Right to withdraw the data protection consent declaration
You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.
9. Automated decisions on a case-by-case basis, including profiling
You have the right to not be subjected to a decision based solely on automated processing – including profiling – that will have a legal effect or affect you in a similar manner. This does not apply if the decision:
- is required for the conclusion or execution of a contract between you and the data controller,
- is permitted by the Union or Member State legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
- is based on your explicit consent.
However, these decisions must not be based on special categories of personal data under Art. 9 para. (1) GDPR, unless Art. 9 para. (2) lit. (a) or (b) GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in a. and c., the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or their representative, to express your opinion on the matter, and to contest the decision.
10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the GDPR.
The supervisory authority to which the complaint has been submitted shall inform the accused of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
V. Provision of the CONEXO Portal and creation of log files
1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.
The following data is collected:
- Date and time of access
This data is stored in the log files of our system. Not affected by this are the IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.
2. Purpose of data processing
The storage in log files is done to ensure the functionality of the CONEXO Portal. The data is also used to optimize the CONEXO Portal and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.
For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 para. (1) sen. (1) lit. (f) GDPR.
3. Legal basis for data processing
The legal basis for the temporary storage of data is Art. 6 para. (1) sen. (1) lit. (f) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection, the duration of storage of the log files is 15 days.
5. Objection and removal
The collection of data for the provision of the CONEXO Portal as well as the storage of data in log files are essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.
VI. Use of cookies
1. Description and scope of data processing
Our CONEXO Portal uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. When a user calls up the CONEXO Portal, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the CONEXO Portal is called up again.
We use cookies to make our CONEXO Portal more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
The following data is stored and transmitted in the cookies:
- Session information -JSESSIONID and portal-timeout-Cookie
The user data collected in this way is pseudonymised by technical precautions. Therefore, it is no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users.
2. Purpose of data processing
The purpose of using technically necessary cookies is to simplify the use of the CONEXO Portal for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.
We require cookies for the following applications:
- Log-in information
The user data collected through technically necessary cookies are not used to create user profiles.
3. Legal basis for data processing
The legal basis for the use of technically necessary cookies and related data processing is Section 25 para. (2) TTDSG (Federal Act on Regulation of Data Protection and Protection of Privacy in Telecommunications and Telemedia) in conjunction with Art. 6 para. (1) sen. (1) lit. (f) GDPR. The processing serves to facilitate your use of our CONEXO Portal and to be able to offer you our services as desired. Some functions of our CONEXO Portal also do not work without the use of these cookies and could therefore not be offered. Our legitimate interest in processing the cookies results from the aforementioned purposes.
4. Duration of storage, objection and removal
Cookies are stored on the user’s computer and transmitted from it to our site. Therefore, you as a user have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our CONEXO Portal, it may no longer be possible to use all the functions of the CONEXO Portal to their full extent.
If you use a Safari browser as of version 12.1, cookies are automatically deleted after seven days. This also applies to opt-out cookies that are set to prevent tracking measures.
VII. Contact via Email
1. Description and scope of data processing
You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.
The data will be used exclusively for the processing of the conversation.
2. Purpose of data processing
If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.
3. Legal basis for data processing
If the user has given consent, the legal basis for processing the data is Art. 6 para. (1) sen. (1) lit. (a) GDPR.
The legal basis for the processing of data transmitted while sending an email is Art. 6 para. (1) sen. (1) lit. (f) GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 para. (1) sen. (1) lit. (b) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. Objection and removal
The user has the possibility to withdraw the consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
To object to the storage of this data, you can contact us via the email address .
In this case, all personal data stored while establishing contact will be deleted.
VIII. Hosting
The CONEXO Portal is hosted on servers of a service provider commissioned by us.
Our service provider is:
ETES GmbH, Talstraße 106, 70188 Stuttgart, Germany
resp. Netcup GmbH, Daimlerstraße 25, 76185 Karlsruhe, Germany
The processing of personal data is based on Art. 6 para. (1) sen. (1) lit. (f) GDPR.
The server of the CONEXO Portal is geographically located in Germany.
IX. Registration
1. Description and scope of data processing
A user account is required to use the CONEXO Portal. This is created by the administrator of the Portal and then saved in the Portal. The data will not be passed on to third parties. The following data is collected as part of the registration process:
- Username
- Email address
- Cryptographic hash of the password
- Salutation (gender), optional
- Telephone / mobile phone number (optional)
- Language (optional, otherwise the language set in the browser is used)
- User permissions (roles)
As part of the registration process, the user’s consent to the processing of this data is obtained.
2. Purpose of data processing
Registration of the user is necessary for the fulfilment of a contract with the user or for the implementation of pre-contractual measures.
3. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 para. (1) sen. (1) lit. (a) GDPR if the user has given his consent.
If the registration serves the fulfilment of a contract to which the user is a party or the execution of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 para. (1) sen. (1) lit. (b) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.
This is the case for the data collected during the registration process for the fulfilment of a contract or for the execution of pre-contractual measures if the data is no longer required for the implementation of the contract. Even after the conclusion of the contract, it may be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.
5. Objection and removal
As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time.
If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible insofar as contractual or legal obligations do not stand in the way of a deletion.
X. Amendment of the Privacy Policy
We reserve the right to amend the Privacy Policy in order to adapt it to any changes in the legal situation or in the event of changes to the service and data processing.