Privacy Policy

Welcome to the website of Circle Unlimited AG. Circle Unlimited is highly committed to protect your personal data.

The information below provides details on the collection of personal data while you are using our services. Personal data includes details related to you, e.g. your name, your address, your email addresses, your user behavior. We have taken elaborate technical and operational safety precautions to protect your data against accidental or deliberate manipulation, loss, destruction or the access of unauthorized parties. Our safety procedures are regularly reviewed and updated in line with the latest technological developments.

1. Party responsible for data protection

The company responsible according to article 4, paragraph 7 of the EU General Data Protection Regulation (GDPR) is Circle Unlimited AG, Südportal 5, 22848 Norderstedt (see our imprint).

2. Contacting the data protection officer

You can contact our data protection officer via datenschutz(at)cuag.de or via our postal address with the addition “data protection officer”.

3. Your rights

You have the following rights towards us regarding your personal data:

3.1 General rights

You are entitled to access, rectify, delete, restrict the processing of your personal data, object to the processing of your personal data and are entitled to the right to data portability. If the processing is based on your consent, you can revoke your consent with effect for the future.

3.2 Rights in data processing due to justified interest

According to article 21, paragraph 1 GDPR and on the grounds relating to your particular situation you are entitled to the right to object to the processing of personal data that occurs due to article 6, paragraph 1e GDPR (data processing for public interest) or due to article 6, paragraph 1f GDPR (data processing for the purposes of the legitimate interests pursued by the controller or by a third party) at any time; this also applies to a profiling based on these regulations. In the case of your objection we will no longer process your personal data, except if we can show that there are compelling legitimate grounds for the processing that outweigh your interests, rights and liberties, or the processing enables the enforcement, exercise or defense of legal claims.

3.3 Rights in direct advertising

Given that we process your personal data for direct advertising, according to article 21, paragraph 2 GDPR you have the right to object to the processing of your personal data for the purposes of advertising. This also applies to profiling if it is relatable to the direct advertising activity.

In the case of your objection to the processing for the purpose of direct advertising we will no longer process your personal data for these purposes.

3.4 Right to file a complaint with a supervisory authority

In addition, you have the right to file a complaint with the relevant supervisory authority regarding our processing of your personal data.

4. Collection of personal data when visiting our website

When using our website for the purpose of information only, i.e. when you are not a registered user or transmit data to us by any other means, we collect only the personal data that your browser transmits to our server. If you would like to view our website, we will collect the following data necessary for technical reasons in order to display the website to you and to ensure stability and security. The legal basis for this is article 6, paragraph 1f GDPR.

IP address, date and time of inquiry, called-up site, protocol, access status/http status code, website from which the inquiry was made (referrer), user agent and called-up domain.

5. Contact via email or contact form

When contacting us via email or via a contact form the personal data you provide us with (your email address, and optionally your name and your telephone number) will be saved by us in order to process your request. Where data is requested via our contact form that is not compulsory, we have marked this clearly as optional. These specifications will be used by us to clarify your request and to improve the processing of your request. Providing this data is expressly on a voluntary basis on the part of the user and subject to your consent, article 6, paragraph 1a GDPR. By providing data that refers to communication channels (for example email address, telephone number) you consent to us using these communication channels for contacting you with regards to your request. Of course, you can revoke your consent at any time.

We will delete the data provided in this matter as soon as their retention is no longer required, or we will restrict their processing if legal retention periods apply.

6. Newsletter

6.1 General information

With your consent in line with article 6, paragraph 1a GDPR you can subscribe to our newsletter in which we inform you about our latest offers and services.

For the subscription of the newsletter we use the so-called double opt-in method. This means that after your subscription we will send an email to the specified email address in which we ask you to confirm the subscription of the newsletter. If you do not confirm your subscription within 24 hours, your information will be locked and deleted automatically after one month.

In addition, we will save your respective used IP addresses and times of subscription and confirmation. Purpose of the procedure is to provide proof of your subscription and to resolve potential misuse of your data.

The sole compulsory information required for the transmission of the newsletter is your email address. The specification of company, form of address, first name and last name is voluntary and will be used to address you personally. After your confirmation we will save your email address for the purpose of sending you newsletters. Legal basis is article 6, paragraph 1a GDPR.

You can revoke your consent for receiving newsletters at any time and unsubscribe from the newsletter. You can revoke your consent by clicking the link provided in every newsletter email or via contacting the aforementioned data protection officer.

6.2 Newsletter Tracking

We inform you that we analyze your user behavior on dispatch of the newsletter. For the purposes of this analysis the dispatched emails contain so-called web beacons or tracking pixels that are saved on our website. For the analyses we will link the mentioned data and the web beacons with your email address and a unique ID. Links received via the newsletter also contain this ID.

Data will only be collected in a pseudonymous way, i.e. the IDs will not be connected to other personal data of you to prohibit direct personal reference.

You can object to the tracking at any time by clicking the unsubscribe link separately provided in every email and thus by opting out of receiving our newsletter. The information will be stored for as long as you have subscribed to the newsletter. After you have unsubscribed, we save the data only for statistical purposes and only in an anonymized form.

Moreover, such tracking is not possible if you prohibit the display of images in your email application by default. In this case the newsletter will not be displayed to you in full and you may not use all functions. If you display images manually, the stated tracking will be carried out.

7. Applications

You can apply to our company by electronic means, especially via email or web forms. The information that you provide will be used only for processing your application and will not be shared with third parties. Please be aware that unencrypted emails will not be transmitted in an access-protected manner.

If you have applied for a particular position and it has been filled in the meantime or if we consider you equally or more suitable for a different position, we would forward your application within the company. Please let us know if you do not consent to forwarding your application.

After the application process your personal data will be deleted immediately or after a maximum of 6 months, given that you have not given us your express permission for processing your data for a longer period of time or if a contract was concluded. Legal basis are article 6, paragraph 1a, b, and f GDPR as well as § 26 BDSG (Bundesdatenschutzgesetz, German privacy law).

8. Use of social plug-ins

This website uses social plug-ins by the following providers:

  • Facebook (operator: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA)
  • Twitter (operator: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA)
  • Google+ (operator: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
  • YouTube (operator: YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA)
  • kununu (operator: kununu GmbH, Neutorgasse 4-8, Top 3.02, 1010 Wien, Österreich)
  • XING (operator: XING SE, Dammtorstraße 30, 20354 Hamburg, Deutschland).

Usually, these plug-ins collect data from you by default and transmit it to the servers of the respective providers. To safeguard the protection of your privacy we have taken technical precautions that ensure that your data cannot be collected by the provider of the respective plug-in without your prior consent. When calling up a site that uses plug-ins, they will be inactive at first. Only when clicking the respective symbol the plug-ins will be activated and through this action you consent that your data will be transmitted to the respective provider. Legal basis for the use of the plug-in are article 6, paragraph 1a and f GDPR.

After activation, the plug-ins will collect personal data such as your IP address and send this to the server of the respective provider, where they will be stored. In addition, the active social plug-ins will place a cookie with a unique identification number when calling up the respective website. In this way providers can compile profiles of your user behavior. This also happens if you are not a member of the social network of the respective provider. If you are a member of the social network of the provider and you are logged in to the social network while using this website, your data and information on your visit on this site can be connected to the profile of the social network. We have no influence on the scope of the data collected about you through the respective provider. More information on the scope, nature and purpose of the data processing and on your rights and setting options with regards to the protection of your privacy can be found in the privacy policy of the respective provider of the social network. These can be accessed via the following addresses:

9. Use of cookies

When using our website, cookies will be saved on your computer. Cookies are small text files that, on your hard drive, are allocated to the browser used by you and then saved on the hard drive, and through which the entity that has placed the cookie can collect certain data. Cookies do not run programs or transfer viruses to your computer. They assist in improving the internet services, their effectiveness and user friendliness as a whole. This website uses the following types of cookies, the functions of which will be explained below:

9.1 Transient cookies

These cookies will be deleted automatically when you close the browser. These include session cookies. These save a so-called session ID, with which different inquiries of your browser can be allocated to the joint browser session. In this way your computer can be recognized when you return to our website. The session cookies will be deleted when you log out or close the browser.

9.2 Persistent cookies

These cookies will be deleted automatically after a defined period of time, the length of which is subject to the respective cookie. You can delete cookies at any time via the security settings of your browser.

9.3 Prevention of cookies

You can configure your browser settings according to your requirement and, for example, prevent the placement of third-party cookies or of all cookies. We would like to point out that you then might not be able to use this website’s full range of functions.

9.4 Legal basis and retention times

The legal basis for the possible processing of personal data and the duration of their storage vary and are outlined in the following sections.

10. Website analytics

For purposes of analyzing and optimizing our websites we use different services, which are outlined in the following. In this way we can analyze, for instance, how many users have visited our site, which information are most sought after or how users find our offer. We collect data among others on the website from which a user comes to another website (so-called referrer), the sub-sites the user accessed or how often and for how long a sub-site was looked at. This helps us in improving our services and making them more user friendly. The data collected therein are not used to identify individual persons. Data will be collected in an anonymized or at least pseudonymized form. The legal basis is article 6, paragraph 1f GDPR.

10.1 Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Use includes the operating mode Universal Analytics. This makes it possible to allocate data, sessions and interactions on several devices to one pseudonym user ID and thus to analyze the activities of a user across devices.

Google Analytics uses cookies that enable an analysis of the website. The information about your use of this website collected by the cookie will usually be transmitted to a server in the USA and stored there. In case that IP anonymization is activated on this website, your IP address will be truncated within the area of member states of the European Union or other parties to the agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing them other services relating to website activity and internet usage. In these purposes lies also our justified interest in data processing. The legal basis for the use of Google Analytics is § 15 paragraph 3 TMG (German Telemedia Act) or article 6, paragraph 1 f GDPR. The data sent by us that is connected to cookies, user IDs or advertising IDs will be deleted automatically after 14 months. The deletion of data whose storage period has ended is executed once a month. More information on the terms of use and data protection can be found at https://www.google.com/analytics/terms/de.html or at https://policies.google.com/?hl=de.

You may object to the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full range of functionalities of this website. You can also prevent your data with regards to the use of the website (incl. your IP address) being collected and processed by Google with effect for the future by downloading and installing the following browser plug-in available under following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Opt-out cookies prevent the future collection of your data when visiting this website. To prevent the collection of data by Universal Analytics across different devices, you have to run the opt-out cookie on all used systems. If you click here, the opt-out cookie will be placed:

11. Advertising

We use cookies for marketing purposes to approach users with interests-based advertising. In addition, we use cookies to restrict the probability of the broadcasting of an advertisement and to measure the effectiveness of our advertising. This information may be shared with third parties such as ad networks. Legal basis for this is article 6, paragraph 1 a or f GDPR. There is a justified interest of direct marketing in the purposes pursued by the data processing. 

You are entitled to the right to object to the processing of your data for purposes of such advertising. In the following, we provide opt-out options for the respective services. Alternatively, you can prevent the placing of cookies through your browser settings.

12. Data transfer

Your personal data will not be transmitted to third parties, except if we are obliged to do so by law or the transfer of data is necessary for implementing the contract or you have priorly expressly consented to the transfer of your data.

External service providers and partners such as online payment providers or the shipping company charged with the delivery will receive your data only in the scope of processing your order. In these cases the extent of the transferred data is limited to the necessary minimum.  Where our service providers might come into contact with your personal data, we will ensure in line with the data processing on behalf according to article 28 GDPR that these adhere to the same level of provisions of the data protection. Please also note the respective data protection guidelines of the respective service provider. The respective service provider is responsible for the contents of foreign services, but we review the services for the adherence to the legal requirements within reasonable limits.

We attach great significance to processing your data within the EU / EEA. Nonetheless, it might be the case that we use service providers who process data outside of the EU / EEA. In these cases we ensure that there is an adequate level of data protection at the receiving institution. This means that via EU standard contracts or an adequacy decision such as the EU Privacy Shield a data protection level can be achieved that is comparable to the standards within the EU.

13. Data protection

We have taken elaborate technical and operational safety precautions to protect your data against accidental or deliberate manipulation, loss, destruction or the access of unauthorized parties. Our safety procedures are regularly reviewed and updated in line with the latest technological developments.

May 2018

Do you have questions about the privacy policy?

datenschutz(at)cuag.de