1. Who is accountable for processing my personal data?
Bertelsmann SE & Co. KGaA
Telefon: +49 (0) 5241-80-0
Fax: +49 (0) 5241-80-62321
is responsible for processing your personal data on this website (hereinafter referred to as “we”). We process personally identifiable information (“personal data”) in accordance with GDPR provisions and the German Federal Data Protection Act (BDSG).
This website has sub-sites (subdomains), which belong to subsidiary companies. These sub-domains are
- https://scm.arvato.com, Arvato Supply Change Management (Arvato SCM)
- https://crm.arvato.com, Arvato Customer Relationship Management (Arvato CRM)
- https://finance.arvato.com, Arvato Financial Services (Arvato FS)
- https://it.arvato.com, Arvato Systems
The subsidiary companies are responsible for the processing of your personal data on these subdomains. Detailled information on the subsidiary companies can be found in the website credits.
You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: email@example.com.
2. What data is collected?
When you visit our website, the data of the computer you use to access our website is auto-matically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating sys-tem, your internet service provider (ISP), the date and time you used the website, the web-sites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information con-tained in the server log files is not personally identifiable. An IP address is personally identifia-ble when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.
Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click data).
3. What cookies are used?
As a general principle, cookies enable online recognition without reference to a specific per-son. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves. Here a distinction is made between cookies that are necessary for the provision of website features, and cookies that are required for other purposes, e.g. analysis of user behaviour or displaying advertising-related content.
The cookies that are required for the provision of website features include the following in par-ticular:
- Cookies that are used to identify or authenticate the user;
- Cookies used to temporarily store user input (e.g. the content of a shopping cart or online form);
- Cookies used to store user preferences (e.g. search or language settings);
- Cookies that store data to enable the trouble-free rendering of video or audio content.
Cookies that are needed for other purposes of the website include analytics cookies to record the usage behaviour of our users and evaluate it in the form of statistics (e.g. advertising ban-ners clicked, sub-pages visited, search queries conducted).
4. What personal data is collected and for what purpose?
The purpose of data processing may be based on technical, contractual or statutory require-ments or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:
- To provide website features and content and ensure technical security in trouble-shooting technical issues and also to ensure that unauthorized persons do not gain access to our website systems;
- To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
- For communication, completion of precontractual procedures, and customer care pur-poses;
- To send out newsletters via email;
- For event registration and participation; and
4.1 Provision of the website
4.1.1 Description and scope of data processing
In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the serv-er log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper func-tioning of our website.
4.1.2 Purpose and legal basis of data processing
The legal basis for the creation of server log files follows from Art. 6(1)(f) GDPR. Our legiti-mate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.
4.1.3 Duration of storage or criteria applied in defining this period
When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.
4.1.4 Options for lodging an objection and having your data removed
You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.
4.2 Contact form, email and telephone contact information
4.2.1 Description and scope of data processing
On our website you have the option of contacting us by way of a contact form, by email, by telephone or by chat using the designated email address and phone number. If you take ad-vantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).
4.2.2 Purpose and legal basis of data processing
The legal basis for processing your contact details follows from Art. 6(1)(f) GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6(1)(b) GDPR.
4.2.3 Duration of storage or criteria applied in defining this period
Your contact details are deleted once your request has been processed and further commu-nication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 to 10 years) do not prevent this information from being deleted.
4.2.4 Options for lodging an objection and having your data removed
You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exer-cise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, ful-filling a contract or exercising your rights as a data subject.
4.3 Newsletter (Arvato Systems and Arvato SCM)
4.3.1 Description and scope of data processing
4.3.2 Purpose and legal basis of data processing
Processing the information entered by you in the registration form is necessary for advertising pertaining to products and/or services provided by us. The legal basis for this is your consent pursuant to Art. 6(1)(a) GDPR.
4.3.3 Duration of storage or criteria applied in defining this period
Your information is stored for the duration of your subscription to Arvato Systems’s and Arva-to SCM’s newsletter. When cancelling your subscription your details are stored exclusively to show proof that we obtained your consent for sending you Arvato Systems’s and Arvato SCM’s newsletter. The same applies if you have revoked your consent.
4.3.4 Options for lodging an objection and having your data removed
You can revoke your consent to receiving press releases at any time by writing to:
- Newsletter of Arvato SCM, Arvato Distribution GmbH via E-Mail: firstname.lastname@example.org or via mail to „An der Autobahn 22, 33333 Gütersloh, Germany“;
- Newsletter of Arvato Systems, Arvato Systems GmbH via E-Mail: email@example.com or via mail to „An der Autobahn 200, 33333 Gütersloh, Germany“.
4.4 Events (Arvato Systems)
4.4.1 Description and scope of data processing
4.4.2 Purpose and legal basis of data processing
Processing the information entered by you in the registration form is necessary for participat-ing at the respective event. The legal basis for this is your consent pursuant to Art. 6(1)(a) GDPR.
4.4.3 Duration of storage or criteria applied in defining this period
Your information is stored until the end of the event. This does not apply, if during the event contract negotiations were initiated and your data needs to be stored for the creation of a cus-tomer record.
4.4.4 Options for lodging an objection and having your data removed:
You can revoke your consent to receiving press releases at any time by writing to Arvato Systems GmbH via E-Mail: firstname.lastname@example.org or via mail to „An der Autobahn 200, 33333 Gütersloh, Germany“.
4.5.1 Adobe Tag Manager
This website uses Adobe Tag Manager. Adobe Tag Manager is a service provided by Adobe Systems Software Irland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Tag Manager managers „tags“ (placeholder for website code). Adobe Tag Manager does not collect data and data collected by the tags cannot be accessed by the Adobe Tool Manager.
4.5.2 Google Analytics
This website uses Google Analytics. Google Analytics is a service provided by Google Inc. Google Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as described in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Google Inc., meaning no information can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Google Inc. We ensure that Google Inc. only uses this data as instructed by us under a contract data processing contract we have concluded with Google Inc.
4.5.3 Adobe Analytics (Omniture)
This website uses Adobe Analytics. Adobe Analytics is a service provided by Adobe Systems Software Irland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as de-scribed in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Adobe meaning no in-formation can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with oth-er data by Adobe. We ensure that Adobe only uses this data as instructed by us under a con-tract data processing contract we have concluded with Adobe.
For more information on data processing related to Adobe Analytics, refer to the Adobe priva-cy policy:
4.5.4 Purpose and legal basis of data processing
The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6(1)(f) GDPR / Section 15(3) German Telemedia Act (TMG). We have a legitimate interest in optimiz-ing the user-friendliness of our website and performing marketing reach measurements.
4.5.5 Duration of storage or criteria applied in defining this period
As a general rule, the data that is collected and analyzed in association with Google and Ado-be Analytics remains stored until you raise an objection to it being used in this manner. Analyt-ics cookies are stored for a maximum of 24 months.
4.5.6 Options for lodging an objection and having your data removed
You can raise an objection to the use of Google Analytics by changing your browser settings and/or clicking on the following links to download and install the browser plug-ins and/or opt-out:
- Google Analytics: https://tools.google.com/dlpage/gaoptout
- Adobe Analytics: http://bertelsarvatoprod.d3.sc.omtrdc.net/optout.html
4.6 Links to other websites
This website contains links to the website of other website operators. Clicking on the links takes you to the respective websites (e.g. Facebook, YouTube). With the exception of your access data to make the other website available, no data of yours is transmitted to these website operators.
4.7 External services and content on our website
We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.
That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.
- YouTube: https://support.google.com/youtube/answer/7671399
- Google Maps: https://maps.google.com/help/terms_maps.html
5. Who comes into possession of my personal data?
Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.
No sharing of information with other recipients such as advertising partners, providers of so-cial media services or credit institutions (“third parties”) takes place.
6. Is my personal data processed outside of the EU or EEA (‘transfer to a third coun-try’)?
The use of Google Analytics as described in section 4.4 above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA. However, by being certified under the EU-US Privacy Shield, Google Inc. ensures that a level of data protection comparable to that in the EU/EEA is ensured. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.
7. What data privacy rights do I have?
You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data port-ability).
If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.
Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situa-tion to raise an objection to the processing of your data that is done on the basis of Art. 6(1)(f) GDPR. You also have the right to lodge an objection to the processing of your personal infor-mation for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.
You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
40213 Düsseldorf, Germany
You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.
8. To what extent does automated decision-making take place?
We do not use any fully automated decision-making processes for any of the purposes set out in section 4.
9. Is profiling done?
No profiling takes place for any of the purposes set out in section 4.