Privacy

We are very pleased about your interest in our company. Data protection is of particular importance to the management of Bitbrew GmbH. Use of the Bitbrew GmbH website is generally possible without providing any personal data. If a data subject wishes to use special services of our company via our website, processing of personal data may become necessary. If processing of personal data is required and there is no statutory basis for such processing, we generally obtain the data subject's consent.

The processing of personal data, for example the name, address, email address or telephone number of a data subject, always takes place in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Bitbrew GmbH. By means of this privacy policy our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Data subjects are also informed of their rights by means of this privacy policy.

As the controller, Bitbrew GmbH has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed via this website. Nevertheless, internet-based data transmissions may in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of Bitbrew GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms in this privacy policy, among others:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller

Controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

The controller within the meaning of the GDPR and other data protection provisions applicable in the Member States of the European Union is:

Bitbrew GmbH
Am Zollhafen 5
41460 Neuss
Germany
Phone: +49 21317769670
Email: support@bitbrew.de
Website: www.bitbrew.de

3. Cookies

The websites of Bitbrew GmbH may use cookies. Insofar as we use tracking technologies, the following applies:

Cookies are text files that are stored in a computer system via an internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited internet sites and servers to differentiate the individual browser of the data subject from other internet browsers that contain other cookies.

Through the use of cookies, Bitbrew GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting. Cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to utilise our website.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the internet browser used and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an internet browser or other software programs. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information

The website of Bitbrew GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites, (5) the date and time of access to the internet site, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Bitbrew GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Contact via the website

The website of Bitbrew GmbH contains information required by law that enables rapid electronic contact with our company as well as direct communication with us, which also includes a general email address. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are processed for the purpose of handling the enquiry. The contact and workshop enquiry forms open the data subject's local email program (mailto) and do not store the details on our web server. The careers application form is described in section 7.

6. Memory game on the homepage

Visitors to the homepage can play a memory game and then provide their name and email address in order to claim a benefit. The details are collected via the POST /api/memory-claims interface and stored in a JSON file on our server (name, email address, email domain, timestamp). The legal basis is Article 6(1)(a) GDPR (consent) and Article 6(1)(f) GDPR for the prevention of abuse (no duplicate claims). The data are not disclosed to third parties and are deleted when the purpose ceases to apply or the data subject requests erasure.

7. Data protection for applications and the application procedure

Via the careers application form (POST /api/applications), applicants can submit details (name, email, optional phone, message, subject/role) and PDF documents. PDF files are briefly stored on the server in a non-public cache directory only so they can be sent to Bitbrew as email attachments; the cache folder is removed immediately after sending (whether or not delivery succeeded). There is no long-term storage of application documents on the web server. Applicants receive a confirmation email. The legal basis is Article 6(1)(b) GDPR (pre-contractual steps) or, for speculative applications, Article 6(1)(a) GDPR (consent via the privacy checkbox). We use an SMTP provider for email delivery, which may process personal data.

The controller collects and processes the personal data of applicants for the purpose of processing the application procedure. Processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to the controller by electronic means, for example by email. If the controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant, the application documents shall be automatically deleted two months after notification of the refusal decision, provided that no other legitimate interests of the controller oppose deletion. Other legitimate interest in this sense is, for example, a burden of proof in a procedure under the General Equal Treatment Act (AGG).

8. Routine erasure and blocking of personal data

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

9. Rights of the data subject

a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself or herself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

the purposes of the processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
the existence of the right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject: any available information as to their source
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself or herself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Bitbrew GmbH, he or she may, at any time, contact any employee of the controller. An employee of Bitbrew GmbH shall promptly ensure that the erasure request is complied with immediately.

e) Right to restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Bitbrew GmbH, he or she may at any time contact any employee of the controller. The employee of Bitbrew GmbH will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, or on a contract pursuant to point (b) of Article 6(1) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

In order to assert the right to data portability, the data subject may at any time contact any employee of Bitbrew GmbH.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) GDPR. This also applies to profiling based on these provisions.

Bitbrew GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If Bitbrew GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Bitbrew GmbH to the processing for direct marketing purposes, Bitbrew GmbH will no longer process the personal data for these purposes.

In order to exercise the right to object, the data subject may contact any employee of Bitbrew GmbH.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller.

10. Use of Google Analytics

Insofar as we use Google Analytics (with anonymisation function) on this website, the following applies:

Google Analytics is a web analytics service. Web analytics is the collection, gathering and analysis of data about the behaviour of visitors to websites. A web analytics service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Insofar as we use Google Analytics, we use the “_gat._anonymizeIp” addition for web analysis. By means of this addition, the IP address of the internet connection of the data subject is shortened and anonymised by Google if access to our websites takes place from a Member State of the European Union or from another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website, to compile online reports which show the activities on our websites, and to provide other services concerning the use of our internet site.

Google Analytics places a cookie on the information technology system of the data subject. With the setting of the cookie, Google is enabled to analyse the use of our website. The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used. It is also possible to object to the collection of data generated by Google Analytics. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/ and under http://www.google.com/analytics/terms/de.html. Google Analytics is further explained under https://www.google.com/intl/de_de/analytics/.

11. Use of Google AdWords (insofar as we use tracking)

Insofar as we use Google AdWords on this website, the following applies:

Google AdWords is an internet advertising service that allows advertisers to display ads in Google search engine results and the Google advertising network. The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the Google search engine.

If a data subject reaches our website via a Google ad, a conversion cookie may be placed on the information technology system of the data subject by Google. The conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not expired, it is used to check whether certain sub-pages on our website were accessed.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used. It is also possible to object to interest-based advertising by Google. To do this, the data subject must call up the link https://www.google.de/settings/ads from each of the internet browsers used by them and make the desired settings there.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/.

12. Legal basis for the processing

Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

13. Legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1)(f) GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

15. Legal or contractual provisions regarding the provision of personal data

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. Failure to provide the personal data would have the consequence that the contract with the data subject could not be concluded.

16. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

This privacy policy was created using the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as external data protection officer, in cooperation with the IT and data protection lawyer Christian Solmecke.