introduction
We recognize our responsibility as the person responsible for the processing of personal data and as a data processor. The security of personal data and compliance with the applicable telecommunications and data protection regulations in the countries in which we operate are our top priorities.
By visiting our site, you agree to our privacy policy, which means that you agree to our terms and conditions. If you do not agree to our privacy policy, we recommend that you do not interact with us in any way.
Read more about how and why we collect data and how we handle our data below.
LINK Mobility Austria GmbH and LINK Mobility GmbH, hereinafter referred to as "LINK DACH", are part of the Norwegian LINK Mobility Group AS (Org. No. 984 066 910), hereinafter referred to as "LINK". "LINK DACH" is responsible for the processing of personal data. LINK DACH processes personal data within the framework of the applicable laws and regulations. LINK consists of many subsidiaries and personal data can be shared and transferred between LINK and the subsidiaries listed in the following list:A list of all LINK subsidiaries can be found here.Each subsidiary is responsible for the processing of personal data in accordance with this privacy policy.
terminology
We will use some terms that are common within this privacy policy and as they are to be understood in Article 4 of the GDPR.
A data subject is an identifiable natural person.
The person responsible is the legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.
A data processor is the legal person who processes personal data on behalf of the person responsible.
Personal data are all data that are directly or indirectly related to a natural person (data subject).
Data processing of personal data is any use of personal data, including the collection, storage, modification, transfer or deletion.
Traffic data is data that is generated over a network. For example, when a person uses the cellular network, information is generated about who is sending and receiving a message or call, as well as the start and end time and location of the cell phone. If traffic data can be directly or indirectly associated with you as a person, it is classified as personal data. The traffic data can be used e.g. for billing purposes.
Anonymous data is data from which all identifying elements have been removed, making it impossible to assign the data to a person.
LINK - LINK Mobility Group AS (Org. No. 984 066 910 with subsidiaries)
LINK DACH- LINK Mobility Austria GmbH (F.N .: 222236v) and LINK Mobility GmbH
Data protection and processing of personal data at LINK Germany
If you use products and services from LINK or LINK DACH, we process these general types of personal data:
If you have already signed a contract with us to use one or more of our services, we will use your personal data as a customer or supplier.
If you have not already signed a contract with us and you contact us via one of the channels - such as visiting this website - we will use your data as a potential customer or potential supplier.
Personal data of the end users that our LINK DACH customers pass on to LINK DACH and that are processed during processing with LINK DACH Services are referred to as end user data.
LINK DACH as the person responsible
How LINK DACH, as the person responsible for data processing, processes personal data is defined and described in this data protection declaration and, if applicable, in the data processing contract or in the terms and conditions between LINK DACH and our customer / supplier, or is based on the legitimate legal interest of LINK DACH instead of.
Business contacts, including supplier and customer representatives and employees
LINK DACH can receive your data as a business contact, e.g. if you contact our sales team. When you register on our website or sign up for our web or email services, we may ask you to provide personal information. This can include your name, address / post code / city / country, telephone number and / or email address.
We can also collect and process other personal data or information that you provide to us if you contact us with specific inquiries and / or to apply for vacancies, questions about job advertisements or unsolicited applications.
Site visitors
If you only use the website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you want to view our website, we collect the following data, which is technically necessary for us to display our website to you and to guarantee stability and security (legal basis is Art. 6 Para. 1 S. 1 lit.f GDPR):
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status / HTTP status code
Amount of data transferred in each case
Website from which the request came
Browser, operating system and its interface
Language and version of the browser software.
This data is stored for a period of one month in order to protect us against unauthorized access by third parties and then deleted.
In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive and assigned to the browser you are using and through which certain information flows to the place that sets the cookie (in this case us). Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and more effective overall. This website uses the following types of cookies, the scope and functionality of which are explained below:
Persistent cookies (see a).
a) Persistent cookies are automatically deleted after a specified period, which can differ depending on the cookie. You can delete cookies at any time in the security settings of your browser.
b) You can configure your browser settings according to your wishes and e.g. B. reject the acceptance of third-party cookies or all cookies. We would like to point out that you may not be able to use all functions of this website.
Use of Google Analytics and Google Ads
On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Paragraph 1 lit. f. GDPR), we use Google Analytics, a web analysis service from Google LLC, hereinafter referred to as "Google", a. Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and internet usage. In doing so, pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address will only be sent to a Google server in the USA and shortened there in exceptional cases.
The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly. Users can also prevent Google from collecting the data generated by the cookie and relating to their use of the website (including their IP address) and from processing this data by Google by downloading the browser plug-in available under the following link and install:http://tools.google.com/dlpage/gaoptout?hl=de.
For more information on the use of data by Google, setting and objection options, please refer to Google's data protection declaration (https://policies.google.com/?hl=de&gl=de) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The data collected will be deleted after 14 months.
We use Google Ads Conversion for our website www.linkmobility.de to draw attention to our services with the help of advertising materials (so-called Google Ads) on external websites. This enables us to determine how successful the individual advertising measures are. In doing so, we are pursuing the interest of only showing advertisements that are of interest to the user, of making our website more targeted and of analyzing the effectiveness and efficiency of this advertising.
The data is processed on the basis of Art. 6 (1) lit. f GDPR from the legitimate interest in targeted advertising and the analysis of the effectiveness and efficiency of this advertising. For reasons that arise from your particular situation, you have the right to object to this processing of personal data relating to you based on Art. 6 (1) f GDPR at any time. To do this, you can prevent the storage of cookies by selecting the appropriate technical settings in your browser software. You will then not be included in the conversion tracking statistics.
You can also deactivate personalized advertising for you in the advertising settings on Google. Instructions can be found athttps://support.google.com/ads/answer/2662922?hl=de.
You can find more information and Google's privacy policy at:https://www.google.de/policies/privacy/.
The aforementioned advertising material is delivered by Google via so-called "ad servers". Ad server cookies are used for this, through which certain parameters for measuring success, such as the insertion of advertisements or clicks by the user, can be measured. If you access our website via a Google ad, Google Ads will store a cookie on your device. These cookies usually lose their validity after 30 days and are not used to identify you personally. As a rule, only the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wants to be addressed) is saved. These cookies enable Google to recognize your internet browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their computer has not yet expired, Google and the customer can see that the user clicked on the ad and was redirected to this page. A different cookie is assigned to each Ads customer. This means that cookies cannot be tracked via the website of Ads customers. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can see which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify the users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data that is collected by Google through the use of this tool and therefore inform you according to our level of knowledge: By integrating Ads Conversion, Google receives the information that you are viewing the corresponding part of our website have accessed or clicked on one of our advertisements. If you are registered with a Google service, Google could assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that the provider will find out your IP address and save it.
LINK DACH employees
The employees of LINK DACH are familiar with the applicable data protection regulations. LINK DACH employees should consult the internal documentation on data processing.
Examples of processing activities when LINK DACH acts as the controller
Notification of customers / suppliers as well as their representatives and employees about:
Changes to the terms and conditions, other regulations or the data protection declaration.
Changes that are directly related to the provision of services within the LINK DACH services, such as service updates, updates to the technical conditions and the documentation.
The payment status for the implemented services (invoicing and the status of payments), including the discount codes for services.
Answering inquiries:
or questions about services, terms and conditions or this privacy policy.
for the operation of the services of LINK GERMANY.
Information about the quality of the service.
Other use:
Establishing contact or informing visitors to our website about matters which LINK DACH thinks might be of interest to the visitor (marketing) after a visitor has submitted a web form on our website or in another way (opt-in).
Sending messages such as SMS / MMS or e-mail from our customer (person responsible) to the end user (person concerned).
Customer satisfaction surveys
The management of memberships and membership offers.
Improve and evaluate our website and services.
Exercising Individual Rights.
Comply with laws and regulations.
Categories of personal data
Depending on the service and the use of the service in question by the customer, we, as the person responsible for data processing, can process personal data within the following categories
Inventory data (such as name), contact details (such as email, phone number, etc.).
Location data, such as GPS, Wi-Fi location data, and location data derived from the processor's network (i.e. not traffic data as defined below).
Traffic data: data that is collected, processed or used in the provision of a telecommunications service (such as IP address, sender, recipient).
Telecommunication content data: data relating to the content of the communication, such as e-mails, voice mails, SMS / MMS, browsing data, etc.
For information about visits to this website through the use and placement of cookies, see the section "Visitors to the website" of this data protection declaration.
In some cases, LINK DACH is able to link the personal data collected by several different services if the data is collected for the same purpose.
Your data will not be used in an automated decision-making system, including the creation of profiles.
The legal basis for processing by LINK DACH are:
To fulfill the contract for the use of a LINK DACH product or service.
To pursue the legitimate interests of LINK DACH (always provided that the interests of those concerned do not outweigh them), e.g. in relation to improving the services or the user experience, to justify, exercise or defend a legal claim, to prevent loss or damage LINK DACH or third parties or to prevent actions that could endanger the property of LINK DACH or a third party or the personal data of other users of the services.
Consent, e.g. in relation to the marketing of LINK GERMANY's services.
To fulfill a legal obligation to which LINK DACH is subject, e.g. due to statutory retention requirements for billing purposes.
LINK DACH as a data processor
How LINK DACH processes personal data as a data processor is defined and described in the agreement between LINK DACH and our customer, the person responsible, and in the description of the respective services. The data about a person (data subject) that we process as a data processor depend on which of our services are used by the customer.
Processing by LINK DACH on behalf of the customer is regulated by an order processing contract (GCU), and LINK DACH processes personal data only to provide our services to the customer and in accordance with the GCU and the customer's instructions. After termination of the contract or at the instruction of the customer, we will delete or return the personal data processed within the framework of the contract, unless there are compelling statutory provisions to the contrary.
Examples of processing activities
Creation of itemized reports, statistics and reports.
Enrichment of personal data with data from third-party sources (e.g. economic and demographic data from publicly available sources) before anonymization and segmentation for use in analysis for marketing and reporting purposes. Please note that LINK DACH or the customer of LINK DACH will only use enriched data if it has been anonymized.
Monitor traffic to ensure message delivery and system stability.
Manage the consent of the data subjects.
Storage and management of information about data subjects on behalf of the person responsible.
Categories of personal data
Depending on the service and the use of the service in question by the customer, we as data processors can process personal data within the following categories:
Inventory data (such as names), contact details (such as email, phone number, etc.).
Location data, such as GPS, Wi-Fi location data, and location data derived from the processor's network (i.e. not traffic data as defined below).
Traffic data: data that is collected, processed or used in the provision of a telecommunications service (such as IP address, sender, recipient).
Telecommunication content data: data relating to the content of the communication, such as e-mails, voice mails, SMS / MMS, browsing data, etc.
Special categories of personal data, such as data showing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or health data.
Legal basis for the processing:
Data protection agreement with the customer.
Affected persons can at any time:
Withdraw your consent to processing activity based on consent.
Change and view your personal data.
Request the export or deletion of personal data.
Obtain restriction of processing or object to processing.
Terminate the agreement.
Right of appeal to a supervisory authority
If you are of the opinion that the processing of personal data by LINK DACH violates relevant data protection regulations, you can lodge a complaint with the supervisory authority of your place of residence, your place of work or the place of the alleged infringement, or with another competent supervisory authority.
Retention of data
LINK DACH stores personal data for as long as it is necessary for the fulfillment of the purposes of the processing, and generally stores it until the end of the contract or until the end user is requested to delete it. Please note that legal obligations, e.g. legal regulations on storage for accounting purposes or anti-terrorism laws, may make it necessary to store personal data after the contract has ended. Further storage can also take place if this is necessary to safeguard LINK GERMANY's legitimate interests, in particular to establish, exercise or defend legal claims.
How do we protect personal data?
The protection of personal data is of the utmost importance to LINK DACH. We are therefore continuously working on securing personal data. Our information security and data protection policy includes the protection of personnel, data, IT infrastructure, internal and public networks as well as office buildings and technical facilities. Specific technical and organizational measures can be found in our order processing contract. Particular attention is paid to the protection of personal data.
Our information security management aims to strike a balance between threats, company values, available technology, vulnerabilities and threats in order to comply with applicable laws and regulations as well as contractual requirements.
LINK DACH endeavors to implement security measures by establishing an appropriate level of protection for personal data and thus preventing the disclosure of personal data to unauthorized persons, both internally and externally.
Who do we share data with?
LINK DACH can pass on personal data to third party providers and hosting partners who provide services for LINK DACH in order to be able to provide their services.
These third-party providers only use the personal data for the purposes for which they were collected and to provide their services to LINK DACH. The relationship with these third-party providers is regulated by an order processing contract.
LINK DACH can pass on the personal data of business contacts and website visitors between all companies that are listed as subsidiaries of LINK. LINK also has subsidiaries that are located outside the EU / EEA area. Access to the personal data of the subsidiaries is protected by EU standard contractual clauses that have been signed between LINK and all subsidiaries.
The transfer of personal data to public institutions can take place if and to the extent that this is required by law and by applicable regulations.
Your personal data (website visitors) can be transmitted to a third country (USA) on the basis of your explicit consent.
How does LINK ensure the transfer to third countries in accordance with the new requirements?
According to the judgment of the Court of Justice of the European Union ("ECJ") of July 16, 2020 data protection officer against Facebook Ireland LTD, Maximillian Schrems, C-311/18 ("Schrems II") and in the recommendations 01 / 2020 by the European Data Protection Board ("EDPB"), the measures required for transfers of personal data outside the European Economic Area ("EEA") require a higher level of specification and care on the part of those responsible for such transfers in order to comply with the GDPR to be observed.
LINK DACH implements the stated requirements according to the steps below:
Step 1: At LINK DACH we know our transmissions
Through its contracts with third parties and its internal processes, LINK DACH ensures that transfers to countries outside the EEA are not made without the knowledge of LINK DACH and without documentation of such transfers.Step 2: LINK DACH verifies the security on which our transfer is based
LINK DACH does not rely on existing protective measures (Privacy Shield and Safe Harbor) for the transmission. If a transfer is required, only the adequacy decisions of the European Commission and the current safeguards as set out in Article 46 of the GDPR will be chosen.Step 3: Transfer according to the law of the respective country
The transfer will only be carried out if the laws of the country concerned, including any additional measures, do not prevent processing in accordance with the requirements for the applicable transfer.
Social networking
LINK DACH can collect information about data subjects in connection with social networking sites in various ways:
If a person concerned decides to join (or "like") a LINK DACH page on a social networking site (such as the LINK DACH page on Facebook), the social networking site LINK DACH can provide some information in these situations about the data subject. Further information can be found in the data protection provisions for the social networking site.
If a data subject interacts with a LINK DACH social networking page or content, LINK DACH may use cookies to find out which links have been clicked on.
If information is made publicly available on the social networking site of a data subject, LINK DACH can collect this information.
When the social sign-in function is used to access content instead of submitting a web form. The social sign-in function enables visitors to web forms to connect to their online programs via their social network identity. Visitors can use their existing social networks such as Facebook, LinkedIn, Twitter or Salesforce to bypass a registration or login form. Social Sign-In records the current contact details of the visitors and saves the information directly in the database.
To find out more about the data protection practices of a social networking site on which you as a data subject interact with LINK DACH, please read the data protection declaration of the respective social network site.
The contact details
If you are a direct customer of LINK DACH, please contact our Customer Support:support.at@linkmobility.com
Our customer support can also help you to get in touch with the LINK data protection officer (DPO) - Jan Wieczorkiewicz. Or you can use the DPO overgdpr.de@linkmobility.com or contact our postal address with the addition of "the data protection officer".
Changes to this data protection declaration
LINK DACH reserves the right to change this data protection declaration. The latest revision replaces all previous versions. The current version of the data protection declaration is always made available on the LINK DACH website or upon request. We advise you to check the data protection regulations from time to time to find out about the current status. We will notify you of any changes to the privacy policy that you are entitled to receive information about or that require your consent.
Last update of the privacy policy: 24.09.2021.