Privacy Policy - ENTRO Service

Privacy Policy

We appreciate your visit to our website. Protecting and securing your personal information while using our website is very important to us. Below, we provide information about what personal data we collect when you visit our website and for what purposes it is used.
Personal data refers to any information relating to an identified or identifiable natural person (data subject), such as name, address, email address, or user behavior. In other words, this is data that can be used to identify you. Additionally, this policy includes information on data processing activities outside this website (e.g., video conferences or newsletters).

Data Controller

The entity responsible for processing personal data in accordance with the EU General Data Protection Regulation (GDPR) is:

ENTRO Service GmbH
Aurbacherstraße 3
81541 Munich, Germany
Phone: 089-69313213-0
Email: kontakt@entro-service.de

Data Protection Officer

exkulpa gmbh
Waldfeuchterstr. 266
52525 Heinsberg, Germany
Phone: 02452 / 99 33 11
Email: datenschutz@entro-service.de

General Information

In addition to the data you actively provide to us on this site (e.g. via our contact form), we collect certain technical data. This so-called metadata is automatically transmitted from your computer to our servers as soon as you visit our website (including browser, operating system or timestamp). We use this data to ensure our website is displayed correctly. In addition, we may collect data via integrated third-party providers (e.g. for external media such as map services or analytics tools). We will explain the specific purposes and legal bases in the course of this privacy policy.

Retention period

Unless a specific retention period is stated within this privacy policy, we will retain your personal data for as long as the purpose of the data processing at remains valid. If you contact us with a valid request for erasure, or if you withdraw your consent, we will erase your data. Statutory retention obligations remain unaffected.

Legal basis for data processing

If you have consented to data processing, the processing of your personal data is carried out on the basis of Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, if special categories of data are processed in accordance with Article 9(1) of the GDPR. Where you have given your express consent to the transfer of personal data to third countries, the data will also be processed in accordance with Article 49(1)(a) of the GDPR. If you have consented to the storage of cookies or access to information on your device (e.g. through device fingerprinting), data processing will additionally take place on the basis of Section 25(1) of the TDDDG. Your consent may be withdrawn at any time. If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data in accordance with Article 6(1)(b) of the GDPR. Furthermore, we process your data where this is necessary to comply with a legal obligation, on the basis of Article 6(1)(c) of the GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Article 6(1)(f) of the GDPR. The following sections of this privacy policy provide information on the respective legal bases in individual cases.

Note on data transfers to third countries and US companies without DPF certification

Please note that we use tools from companies based in third countries with inadequate data protection standards or in the USA, which are not covered by the EU-US Data Protection Framework (DPF). When using these tools, your personal data may be transferred to and processed in these countries. Please note that in these third countries with inadequate data protection standards, a level of data protection comparable to that of the EU cannot be guaranteed.

We would like to clarify that the US generally offers a level of data protection comparable to that of the EU. The transfer of data to the US is permitted if the recipient holds DPF certification or provides appropriate additional safeguards. Information on data transfers to third countries, including data recipients, can be found in our privacy policy.

Automated decision-making

Your personal data is not processed for the purposes of automated decision-making.

Your rights

As a data subject under the General Data Protection Regulation (GDPR), you have the following rights:

Right of access: You have the right to request confirmation from us as to whether your personal data is being processed and, if so, to receive further information about the processing and copies of the data being processed (Art. 15 GDPR).
Right to rectification: You have the right to request the immediate rectification of inaccurate personal data concerning you and, where applicable, the completion of incomplete personal data (Art. 16 GDPR).
Right to erasure: You have the right to request the immediate erasure of personal data concerning you where the legal requirements are met, in particular where the data is no longer necessary for the purposes for which it was collected and the processing is unlawful (Art. 17 GDPR).
Right to restriction of processing: You have the right to request that we restrict the processing of your personal data if the legal requirements are met, in particular if you contest the accuracy of the data, the processing is unlawful and you object to erasure (Art. 18 GDPR).
Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without hindrance from us, provided this is technically feasible (Art. 20 GDPR).
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, where the processing is based on Article 6(1)(e) or (f) of the GDPR (Article 21 of the GDPR).
Right to withdraw consent: You have the right to withdraw your consent to the processing of personal data at any time with effect for the future. Withdrawing your consent does not affect the lawfulness of processing carried out on the basis of your consent prior to withdrawal (Art. 7(3) GDPR).
Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR (Article 77 of the GDPR).

Further data processing operations

General information obligations

This information is intended for customers, prospective customers, suppliers and employees. We process your personal data for the following purposes:

To fulfil our contractual obligations to you (Art. 6(1)(b) GDPR).
To carry out pre-contractual obligations (Art. 6(1)(b) GDPR).
To respond to enquiries (Art. 6(1)(b) GDPR).
Where you have given us your consent to process your personal data for specific purposes (such as to receive our newsletter), data processing takes place on the basis of your consent (Art. 6(1)(a) GDPR).
To comply with legal obligations to which our company is subject (Art. 6(1)(c) GDPR).
Where necessary, we also process your data to safeguard our legitimate interests, in particular to assert legal claims and defend ourselves in legal disputes, or to ensure IT security, to consult and exchange data with credit reference agencies to assess creditworthiness and default risks, for direct marketing and market research provided you have not objected to the use of your data for this purpose, in connection with measures for business management and the further development of services and products, in connection with measures for product and sales optimisation, in connection with risk management measures, and for the prevention or investigation of criminal offences (Art. 6(1)(f) GDPR).

Categories of recipients of personal data

Within our company, only those employees who absolutely need the data to perform their duties have access to it (need-to-know principle). Individual processes and services are carried out by carefully selected service providers, commissioned in accordance with data protection regulations, who are based within the EEA. Where service providers commissioned by us gain access to personal data whilst performing their services, data processing agreements have been concluded with them in accordance with Article 28(3) of the GDPR.

Duration of data storage

The data we process is stored for the duration of the contractual relationship and its fulfilment, and in compliance with statutory retention periods. These include, in particular, commercial and tax law retention obligations under the German Commercial Code (HGB) and the German Fiscal Code (AO). The standard retention and documentation periods amount to up to ten years. If no contractual relationship is established, we process the data only for as long as the specific purpose requires.

Cookies

Cookies are small text files that are stored by your browser on your device to save certain information whilst you are using the website. Cookies enable us to improve various aspects of our website and make your visit more convenient.

There are various types of cookies, each serving different purposes. Temporary cookies, also known as session cookies, are stored only for the duration of your use of the website and are automatically deleted when you close your browser. Persistent cookies, on the other hand, remain stored on your device for a longer period and enable us to recognise you and your preferences on subsequent visits to the website.

Cookies can also be divided into first-party cookies and third-party cookies. First-party cookies are set by our website, whilst third-party cookies are set by other websites or service providers whose content is integrated into our website, such as plugins or analytics tools.

Cookies are used for various purposes, such as ensuring the website functions properly, storing user settings, compiling anonymous statistics on user behaviour, or displaying personalised content and advertising. The legal basis for the use of cookies varies depending on the purpose of the cookies. In some cases, the setting of cookies is based on your legitimate interest pursuant to Article 6(1)(f) of the GDPR, in order to make our website functional and user-friendly. As the website operator, we have a legitimate interest in storing necessary cookies to ensure the technically flawless and optimised provision of our services. Where we seek your consent for the use of cookies, processing is carried out on the basis of Article 6(1)(a) of the GDPR in conjunction with Section 25(1) of the TDDDG. Your consent may be withdrawn at any time.

Consent via Complianz Cookie Consent

Our website uses Complianz’s consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies, and to document this in accordance with data protection regulations. The provider is Complianz B.V., Kalmarweg 14-5, 9723 JG Groningen, Netherlands (hereinafter “Complianz”).

A cookie is set in your browser to enable us to record and document your consent or withdrawal of consent. This data is stored until you delete the cookie, request that we delete the data, or the purpose for data processing ceases to apply. Statutory retention obligations remain unaffected. This data is not passed on to the provider of Complianz.

The Complianz cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Article 6(1)(c) of the GDPR.

Details regarding data processing by Complianz can be found at: https://complianz.io/legal/privacy-statement/

Data processing in detail

Below, we provide information on the individual processing operations, the scope and purpose of data processing, the legal basis, the obligation to provide your data, and the respective retention period. No automated decision-making, including profiling, takes place in individual cases.

Provision of the website

When you access and use our website, we collect the personal data that your browser automatically transmits to our server. The following information is temporarily stored in a so-called log file: IP address of the requesting computer Date and time of access Name and URL of the file accessed Website from which the access originates (referrer URL) Browser used and, where applicable, your computer’s operating system, as well as the name of your internet service provider

Our website is not hosted by us directly, but by a service provider who processes the aforementioned data on our behalf for the purpose of providing the website, in accordance with Article 28 of the GDPR.

The use of the hosting provider is for the purpose of fulfilling our contractual obligations towards our potential and existing customers (Article 6(1)(b) of the GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Article 6(1)(f) of the GDPR).

Contact form

Nature and scope of processing

When you send us enquiries (e.g. via the contact form, email or telephone), we store all the data provided (e.g. name, email address, subject of the enquiry, etc.). We require this data to process your enquiry and to be able to answer any follow-up questions via . We will not pass on this data without your consent.

Purpose and legal basis

The processing of this data is based on Article 6(1)(b) of the GDPR, provided that your enquiry relates to the performance of a contract or is necessary for the implementation of pre-contractual measures. Otherwise, the processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR) if you have previously given it.

Retention period

The data you enter in the contact form will remain with us until you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your enquiry has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

Communication via WhatsApp Business

To communicate with our customers and other third parties, we use, amongst other things, the instant messaging service WhatsApp Business, provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

When you communicate with us via WhatsApp, the chats are end-to-end encrypted. This is designed to prevent WhatsApp or third parties from accessing the content of the chat. However, WhatsApp does have access to metadata generated during the communication process (e.g. sender, recipient and time). WhatsApp shares the personal data collected with its parent company, Meta, which is based in the USA. Further details on data processing can be found in WhatsApp’s Privacy Policy at: https://www.whatsapp.com/legal/#privacy-policy.

The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as possible with customers, prospective customers and other business and contractual partners (Art. 6(1)(f) GDPR). If you have previously given your consent to data processing, the processing of your data takes place solely on the basis of Art. 6(1)(a) GDPR; consent may be withdrawn at any time.

The content of communications exchanged between us and on WhatsApp remains with us until you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your enquiry has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF), an agreement between the European Union and the USA which aims to ensure compliance with European data protection standards when processing data in the USA. Certification under the DPF obliges companies to observe these data protection standards.

We have configured our WhatsApp accounts so that there is no automatic data synchronisation with the address book on the smartphones in use.

To ensure that personal data is processed in accordance with our guidelines and in compliance with the GDPR, we have entered into a Data Processing Agreement (DPA) with the provider.

Contact form for applicants

Nature and scope of processing

We collect and process the personal data of applicants. Such data processing may also take place electronically, for example, when applicants submit application documents to us by email or via a web form on our website. On our website, we offer you the option of submitting applications for advertised vacancies to us by email.

Purpose and legal basis

We process the personal data of applicants in accordance with legal requirements for the purpose of establishing an employment relationship (Art. 6(1)(b) GDPR). You are not obliged to provide us with this data. However, without this data, we cannot conduct an application process with you.

If your application is successful, the data you have submitted will be stored in our data processing systems on the basis of Article 6(1)(b) of the GDPR and, insofar as you provide us with special categories of personal data such as health information, on the basis of Article 9(2)(b) for the purpose of carrying out the employment relationship.

We also use the professional networking services LinkedIn and XING to approach potential applicants. In this regard, the operators of these networks act as data processors on our behalf in accordance with our instructions. The legal basis for data processing when approaching potential applicants on our behalf is Article 6(1)(f) of the GDPR (our legitimate interests). If, following such contact, you send us your application, we process your data for the purpose of establishing an employment relationship as described above on the basis of Article 6(1)(b) of the GDPR.

Retention period

In the event of a rejection, your data will be stored for a period of 6 months beyond the conclusion of the application process. This is done to safeguard our legitimate interests, to assess whether we require the data to defend against any claims arising in connection with the application process. We are then obliged to delete or anonymise your data. In this case, the data will only be available to us as so-called metadata without any direct personal reference for statistical analysis (for example, the proportion of female and male applicants, the number of applications per period, etc.).

If it becomes apparent that further storage of the data is necessary after the expiry of the 6-month period to safeguard our legitimate interests (e.g. due to an impending or pending legal dispute), deletion will only take place once the purpose for the continued storage no longer applies. The legal basis for this further data storage is our legitimate interest in the assertion, exercise or defence of civil law claims (Art. 6(1)(f) GDPR in conjunction with Section 24(1)(2) BDSG or, where special categories of personal data are stored, Art. 9(2)(f) GDPR in conjunction with Section 24(2) BDSG).

Inclusion in the applicant pool

As part of the application process, we offer applicants the opportunity to be included in our “talent pool” for a period of 24 months on the basis of consent within the meaning of Article 6(1)(a) and Article 9(2)(a) of the GDPR. If you have provided special categories of personal data in your application, such as health information, your consent also extends to this data. You are not obliged to provide us with your application data for our talent pool. However, without this data, we cannot consider you for future vacancies unless you submit a new application.

Consent to the inclusion of application data in the Talent Pool is voluntary and may be withdrawn at any time with future effect. Withdrawal of consent does not affect the lawfulness of data processing carried out on the basis of consent prior to withdrawal.

Your application documents will be deleted from the talent pool at the latest upon expiry of the retention period, or in the event of a withdrawal of consent, or upon acceptance of a job offer from one of the companies responsible for the talent pool.

If, as part of the application process, you receive an offer of employment from us and accept it, we or that company will store the personal data collected during the application process for the purpose of implementing the employment relationship. The legal basis for this data processing is Article 6(1)(b) of the GDPR or, insofar as you provide us with special categories of personal data such as health information, Article 9(2)(b).

onlyfy one

We use the e-recruiting system onlyfy one, which allows us to post job advertisements and receive and manage applications. The provider is New Work SE, Strandkai 1, 20457 Hamburg (hereinafter referred to as ‘onlyfy one’). onlyfy one is the central platform for our applicant tracking system. When you use our online application form, your personal data is recorded directly in onlyfy one. Even if you apply by post or email, your data may be transferred to the e-recruiting system. In this context, New Work SE is our data processor within the meaning of Article 4(8) of the GDPR. The basis for this processing is a data processing agreement within the meaning of Article 28 of the GDPR between us, as the data controller, and the provider. Further information on data processing by onlyfy can be found in the onlyfy one privacy policy at https://onlyfy.com/de/datenschutz/.

Use of Personio

Nature and scope of processing

We have integrated components from Personio into our website. Personio is a service provided by Personio GmbH, Rundfunkplatz 4, 80335 Munich, Germany, which offers applicant tracking and HR management software.

Personio is used in connection with recruitment processes to optimise applicant management, for example through the automated analysis of employment references. Furthermore, Personio enables us to create and evaluate job advertisements.

If you apply to us electronically, i.e. by email or via our web form, we collect and process your personal data for the purpose of handling the application process and carrying out pre-contractual measures.

By submitting an application via our recruitment page, you are expressing your interest in taking up employment with us. In this context, you provide us with personal data, which we use and store exclusively for the purpose of your job search/application.

In particular, the following data is collected:

Name (first name and surname)
Email address
Telephone number
LinkedIn profile (optional)
How you found out about us
Salary expectations
Gender

You also have the option to upload relevant documents such as a cover letter, your CV and references. These may contain further personal data such as your date of birth, address, etc.

Only authorised staff from the HR department or staff involved in the recruitment process have access to your data.

Purpose and legal basis

The use of the service is based on our legitimate interests, i.e. our interest in optimising our recruitment processes in accordance with Article 6(1)(f) of the GDPR. The legal basis for data processing is Section 26 of the German Federal Data Protection Act (BDSG).

Retention period

We have no influence over the specific retention period of the processed data; this is determined by Personio GmbH. Further information can be found in Personio’s privacy policy: https://www.personio.de/datenschutz/.

Data processing

The data submitted as part of your application is transmitted via TLS encryptionand stored in a database. This database is operated by Personio GmbH, which provides HR and applicant management software (https://www.personio.de/impressum/). In this context, Personio is our data processor in accordance with Article 28 of the GDPR. The basis for this processing is a data processing agreement between us, as the data controller, and Personio.

Social media presence

We maintain public profiles on various social media platforms via our website. You can find more detailed information about the social media platforms we use in the relevant sections of our privacy policy.

Social networks such as Facebook, Twitter and others can comprehensively analyse your user behaviour when you visit their websites or a website with integrated social media content (e.g. ‘Like’ buttons or advertising banners). Visiting our social media pages triggers numerous data processing operations relevant to data protection:

If you are logged into your social media account and visit our social media presence, the operator of the social media portal can link this visit to your user account. However, your personal data may also be collected even if you are not logged in or do not have an account with the relevant social media portal. In this case, data collection takes place, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the social media platforms can create user profiles containing your preferences and interests. This enables interest-based advertising to be displayed to you both within and outside the respective social media platform. If you have an account with the relevant social network, interest-based advertising may be displayed on all devices on which you are logged in or have been logged in.

Please note that we cannot track all processing activities on social media platforms. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media platforms. For details, please refer to the terms of use and privacy policies of the respective social media platforms.

Legal basis for data processing

Our social media presence is intended to ensure the widest possible online presence. This constitutes a legitimate interest within the meaning of Article 6(1)(f) of the GDPR. The analysis processes initiated by the social networks may be based on different legal grounds, which must be specified by the operators of the social networks (e.g. consent within the meaning of Article 6(1)(a) of the GDPR).

Data controller and exercising of rights

When you visit our social media profiles (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered by that visit. You may, in principle, exercise your rights (right of access, rectification, erasure, restriction of processing, data portability and the right to lodge a complaint) both against us and against the operator of the relevant social media portal (e.g. against Facebook).

Despite our joint responsibility with the social media portal operators, we do not have full control over the data processing operations of the social media portals. Our options depend largely on the corporate policy of the respective provider.

Duration of data storage

Data collected directly by us via our social media presence will be deleted from our systems as soon as you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory legal provisions – in particular retention periods – remain unaffected.

We have no influence over the duration of storage of your data that is stored by the operators of social networks for their own purposes. For further details, please contact the operators of the social networks directly (e.g. via their privacy policy, see below).

Instagram page

Our company has a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Data transfers to the US are based on the EU Commission’s Standard Contractual Clauses. Further details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381.

For further information on how your personal data is handled, please refer to Instagram’s privacy policy: https://help.instagram.com/519522125107875.

LinkedIn page

Our company has a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you wish to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Data transfers to the US are based on the EU Commission’s Standard Contractual Clauses. Further details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

For further information on how your personal data is handled, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.

XING page

We have a profile on XING. The provider is New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany. For details on how they handle your personal data, please refer to XING’s privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Video conferencing

Data processing

We use online conferencing tools to communicate with our customers. The specific tools we use are listed below. When you communicate with us via video or audio conference, your personal data is collected and processed by us and the provider of the relevant tool.

The tools collect the data you provide, including your email address and telephone number. They also process the duration of the conference, when you joined the conference, the number of participants and other metadata.

In addition, the tool provider processes all technical data required to facilitate the conference. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.

If you share content via this service, it is stored on the providers’ servers. This includes cloud recordings, chat messages, voice messages, as well as photos and videos that you have shared whilst using this service.

Please note that we do not have full control over the data processing operations of the tools used. For further details on data processing by the conference tools, please refer to the privacy policies of the respective tools used.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer specific services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and expedite communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) GDPR). If you have previously given your consent to data processing, the processing of your data takes place solely on the basis of Article 6(1)(a) of the GDPR; consent may be withdrawn at any time.

Retention period

Data collected directly by us via the video and conferencing tools will be deleted from our systems as soon as you request deletion, withdraw your consent to storage, or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence over the storage period of your data that is stored by the operators of the conference tools for their own purposes. For further details, please contact the operators of the conference tools directly.

Services and tools used

Vimeo

Our company has a profile on Vimeo. The provider is Vimeo, Inc., 555 West 18th Street, New York 10011, USA.

Data transfers to the USA are based on the EU Commission’s Standard Contractual Clauses and, according to Vimeo, on ‘legitimate business interests’. Further details can be found here: https://vimeo.com/privacy.

For further information on the handling of your personal data, please refer to Vimeo’s privacy policy: https://vimeo.com/privacy.

Vimeo Video

This website uses plugins from the video portal Vimeo. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA. When you play a Vimeo video on this website, a connection is established with their servers. The Vimeo server is informed which of our pages you have visited. Vimeo also obtains your IP address. However, we have configured the settings so that Vimeo cannot track your user activity and will not set any cookies.

Legal basis

The use of Vimeo is based on our legitimate interest in presenting our online services in an appealing manner (Art. 6(1)(f) GDPR). If consent has been requested, the processing of data is carried out exclusively on the basis of your consent in accordance with Art. 6(1)(a) GDPR and Section 25(1) TDDDG. This consent may be withdrawn at any time. The transfer of data to the USA is based on the EU Commission’s Standard Contractual Clauses. Vimeo’s privacy policy can be found here: https://vimeo.com/privacy.