Data Protection Notice and Cookies

The following information shall inform users of our website about how we process personal data. These information serve us to comply with our duties imposed under the General Data Protection Regulation (GDPR). Personal data means any information relating to you by which you can be identified, directly or indirectly.

Data protection information dated: June 2018

1. Who is accountable for the use of my data?

Bertelsmann SE & Co. KGaA
Carl-Bertelsmann-Straße 270
33311 Gütersloh
benet@bertelsmann.de
Phone: +49 (0) 52 41 / 80-23 68
Fax: +49 (0) 52 41 / 80-96 52

The above indicated company is accountable for the use of personal data on this website. Every processing of personal data on this website is conducted in compliance with the GDPR as well as possibly applicable other legislation.

You can contact the company by the means indicated above and by reference of your query. Where you want to contact the responsible data protection officer directly, add “Attention Data Protection Officer” to the address, or send an email to datenschutz@bertelsmann.de.

2. What data are concerned?

If you browse our websites by your PC certain information are collected simply for technical reasons of data flows (technical data). These technical data contain server log files, information about your browser (type, version and information of access status – success or fail), operating system, your internet service provider and your IP address, date and time of the access and from where you accessed the website (prior website or search engine). Save the IP address these information do not allow an identification of you. Where the IP address is used, we comply with the provisions of the GDPR.

Some services require the provision of personal data. In these situations the respective service requested by you will be the leading purpose of our use of your data. Our website offers the following features, where you can request actions from us, where we will need information by you (e.g. user data such as email address and password, address details, search terms, form data and clicking data).

3. Which cookies are used?

This website uses cookies. Cookies are small text files which are stored on your computer when you browse our website. The stored cookies are assigned to the browser you are using. If a given website is re-visited, the web browser transmits the content of the cookies back, allowing the site to recognize the user. Certain cookies are deleted when you log out or end the browser session (“transient cookies”). Other cookies are stored for a specified time or permanently (“temporary cookies,” “persistent cookies”). These cookies are automatically deleted after the specified time has elapsed. You can also delete cookies at any time in the security settings of your browser, and configure the use of cookies according to your wishes. However, we wish to point out that this may result in you not being able to use all functions of the website.

Cookies are always only an online identification without personal reference. Cookies become personalized – traceable to a specific person – when the information generated by the cookies is combined with other data. A distinction can be made between cookies that are necessary for providing the website, and cookies that are needed for further purposes such as analyzing user behavior or advertising.

Cookies that are necessary for the provision of our website include the following in particular:

  • Cookies used to identify or authenticate users;
  • Cookies that temporarily store certain user inputs (e.g. the content of an online form);
  • Cookies that store certain user preferences (e.g. search or language settings);
  • Cookies that store data to ensure interference-free playback of video or audio content.

Cookies that are needed for further purposes include analysis cookies for recording and statistically evaluating the usage behavior of our users (e.g. sub-pages visited, searches performed).

4. Which data are used for which purpose?

The purposes for processing personal data can be found in technical, contractual, and obligations by law, as well as your consent.

We use the data listed above in sec. 2 for the following purposes:

  • to provide the website and ensure technical security, in particular to correct technical errors and to ensure that unauthorized persons do not gain access to the website's systems;
  • to transmit information;
  • to send newsletters via e-mail;
  • to run prize draws;
  • to register and create a user account.

The following sections contain further information on these purposes underlying the processing of your data. 

4.1 Technical provision

4.1.1 Description and extent of the processing

For the provision of our website, including regular performance and security checks, server log files are stored as part of the information when our website is accessed. These log files contain the information and possibly personal data as indicated in section 2 above. Log files are used for the purposes of technical provision only and they are not merged with any other data. Part of the technical provision is a regular reviewing procedure that is designed to detect fraud, hacking and other forms of disruptive behavior.

4.1.2 Purposes and legal basis for the use of personal data

The legal basis for the use of server log files is to be found in Art. 6 sec. 1 lit. f GDPR. Our interest is the undisturbed, resilient and performant operation of our website.

4.1.3 Duration of storage

After accessing our website we store the server log files on the web server, and your IP address is deleted after a maximum of seven days.  Any analyses of these data are conducted only in case of a disruptive event involving these data.

4.1.4 Right to object

You are entitled to object the use of your personal data pursuant to Art. 21 GDPR on grounds that relate to your particular situation. If you want to exercise that right contact the Data Protection Officer via the means of contact indicated in section 1 above.

4.2  Email or phone contact  

4.2.1 Description and extent of the processing

On our website you are given the means of getting in touch with us using an email address or a phone number. If you use one of them, the data you enter, your email address and/or your phone number and your request will be transmitted to us. Depending on your request (e.g. questions about this website and its contents, assertion of your rights as a data subject e.g. right of access). Where this is necessary, some or all of the data collected under this clause can be transmitted to other entities, provided we need their support to answer your request. In that situation we ensure that the recipient has implemented a proper level of protection as well.

4.2.2 Purposes and legal basis for the use of personal data

The legal basis for using data in this regard is to be found in Art. 6 sec. 1 lit. f GDPR. Our shared interest is that you receive an adequate answer. Our legitimate interest  lie in the transmission of information, communicating with you, and processing your request.

4.2.3 Duration of storage / Criteria that determine the duration of storage

After responding to your request and the end of possibly further communication, your information provided for the purpose of the query will be erased unless there are legal retention periods to the contrary. These may result, for example, from the exercise of rights of affected persons

4.2.4 Right to object

You are entitled to object the use of your personal data pursuant to Art. 21 GDPR on grounds that relate to your particular situation. If you want to exercise that right contact the Data Protection Officer via the means of contact indicated in section 1 above. If you object, we can no longer communicate with you. Other rules apply if the storage of your contact data is necessary for the assertion of your rights as an affected party.

4.3  Newsletter mailings

4.3.1 Description and extent of the processing

Our website offers you the option of subscribing to free newsletters and company news alerts via email or SMS. For this purpose, your data will either be forwarded to us by your HR department, or transmitted to us from the website’s registration form and (with the help of service providers) processed further for the dispatch of news alerts and newsletters. The user data is updated daily from the SAP payroll and administration system, among other things, and user data for individual companies is imported manually on an irregular basis. Users can also register independently via the website. When registering, you will be asked for your consent and referred to this data protection information. We will not forward your data to companies outside the Group. Mandatory data for receiving alerts and newsletters is your email address or your mobile phone number. The processing of your access data is also required so that we can prove that you have given your consent. Further data can be given voluntarily, so that we can address you personally.

4.3.2 Purposes and legal basis for the use of personal data

It is necessary for us to process your data in connection with sending a newsletter in order to transmit information to and communicate with you. The legal basis for the HR department's transmission [of your data] to us upon your joining the company is Art. 6 Para. 1 lit. f - entitled interests - of the GDPR. Our legitimate interest lies in the fact that you always receive the company's news first-hand and from a verified source. If you yourself subscribe to the newsletter , Art. 6 Para. 1 lit. a - Consent - GDPR is the legal basis.

4.3.3 Duration of storage

The data is stored for the duration of your subscription to the news alerts and newsletters. After you unsubscribe,, your data will only be stored in order to prove that the company had obtained your consent to send communications and newsletters. The same applies if you have revoked your consent.

4.3.4 Right to object

You have the following options to oppose our use of your data for the purpose of sending the newsletter: You can object to the transmission by your personnel department and the subsequent use of the data. Your data will then no longer be used for this purpose and the newsletter will no longer be delivered to you. If you have given your consent to receive news alerts and newsletters, you can revoke your consent at any time with effect for the future by informing the company of your revocation via the email address benet@bertelsmann.de with the subject "Revoke Consent Newsletter."

4.4  Contests and prize drawings (Online lottery)

4.4.1 Description and extent of the processing

Our website offers you the opportunity to participate in our competitions and prize drawings. We collect your data via the application form as a part of the terms of use. We need to process your data in order to determine and announce a winner as well as demonstrate compliance that we have collected your data validly. Participation is completely voluntary.

If you win, your participation data ([INSERT data, like „Name, ZIP Code”] will be processed and published on our website. We will also contact you to let you know you have won, and deliver your reward, possibly by involvement of Processors. As part of the distribution of prizes, your data may also be forwarded to third parties (the prize sponsor). 

4.4.2 Purposes and legal basis for the use of personal data

The processing of participant data is required for participation in the competition or prize drawing. The legal basis is the fulfilment of a contract in accordance with Art. 6 Para. 1 lit. b GDPR.

4.4.3 Duration of storage

After the winner is drawn, the participant data will be deleted after six months at the latest, unless its retention is mandated by law.

4.4.4 Right to object

Given that we need your data for you to participate in the competition or prize draw, there is no possibility for you to object.

4.5. Use of Data in the Context of BENET Reporting

4.5.1. Description of the data processing

The BENET is used for group-wide communication as well as information from employees and interested external parties. To this end, new articles on relevant topics, people and products from the Group are produced daily and published on BENET. In addition, the headlines and brief descriptions of these articles are sent out in a daily newsletter, to employees and external subscribers to the newsletter. If the data in Benet is processed in the form of a video contribution, both the video and the teaser for the contribution are also published in the BENET Clips App as well as in the newsletter. The data processing associated with this reporting varies according to the content of the report; first and last names, a picture or video, and other personal information (e.g. work/collaboration on a specific project, participation in a conference, assumption of responsibilities, CV information, etc.) that is thematically relevant are regularly included and published in articles. Where appropriate, further information relating to the person covered in the article will be processed. The data subject is notified of these prior to publication.

4.5.2. Purposes and legal basis of the data processing

Data processing in the context of BENET reporting/coverage is carried out on the basis of a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR; the legitimate interest on our part is to create identification with the Group among our readers, to create a corporate identity in the global community, and an attractive, collegial environment. As a rule, the interest of the parties concerned does not outweigh this legitimate interest until a right of objection is exercised. 

4.5.3. Duration of storage or criteria for determining such duration

Generally, the data processed in the context of reporting is available in BENET for a period of three years after publication. The contributions are then removed from the freely accessible part of BENET and can only be viewed in the archive by members of the public relations department (ZÖ). The data is stored there for as long as the legitimate interest in retrievability is valid.   

4.5.4. Objection and deletion options 

In accordance with Art. 21 GDPR, you always have the right to object to the use of your data for the purposes specified under 4.5.1. You can assert this right informally vis-à-vis the body specified in Section 1 by referring to the data processing you no longer wish to be carried out in the future. If the conditions are met, your data will be blocked for this type of processing in the future and deleted in accordance with Art.17 GDPR.

4.6. Use of data in connection with the BENET Clips app

4.6.1. Description of the data processing 

The BENET Clips app processes personal data only for purposes of providing the technology. So the data referred to in Section 2 may also be processed in connection with the BENET Clips app. In particular this includes data such as the Mac address of your device, information about the version and system, and technical information such as transmission rate, success, and time of access. After downloading the app, you will need to complete a one-time login with your BENET access information. The app establishes a secure connection to the BENET backend, where it is verified that this access is authorized. After successful registration, the app has permanent access to the BENET clips via a cookie on your smartphone. In addition, an evaluation tool collects anonymous information about which clips and articles are clicked on, when, and how often. For this purpose, it is technically ensured that only numerical values are collected for statistical evaluation. 

4.6.2. Purposes and legal basis of the data processing

The processing of data in connection with the BENET Clips-App serves two purposes, both based on Section 6 para 1 letter f of the GDPR: the mobile and handy (technical) provision of the videos also available on BENET (with links to the corresponding BENET article), and the evaluation of the utilization (click rates) of the articles.. 

4.6.3. Duration of storage or criteria for determining such duration

The data processed for the purpose of providing the technology will generally be deleted after 14 days. Deviations from this rule will only be made if the data is required for further processing due to technical incidents as defined in Section 2. 

4.6.4. Objection and deletion options

In principle, in accordance with Art. 21 GDPR you have the right to object to the use of your contact data for the purposes specified under 4.7.1. You can claim this informally vis-à-vis the body specified in Section 1 by referring to the data processing no longer desired in the future. If the conditions are met, your data will be blocked for this type of processing in the future. Please note that we do not use the data on a personalized basis and therefore cannot exclude data processing in the event that you continue to use the BENET Clips app.

4.7 Web tracking

Our website uses features to measure and evaluate user behavior and interaction. These features will utilize your access data (see section 2 above) and analyze your interactions with our website by means of tracking cookies (see section 3 above). The information collected will not be combined with other data, so no identifiable user profiles are created.

Web tracking is usually conducted by external providers (Processors). We have concluded data-processing agreements with these Processors; contracts that strictly bind them to our instructions and oblige them to process the collected data on our behalf and not for their own purposes. The website’s Processor is described in greater detail in the following.

4.7.1 Webtrends

This website uses the Webtrends service. The address of the German representation of this American provider is An der Welle 4, 60322 Frankfurt a. M, Germany. If you use the website, your access data (see section 2 above) is collected and stored for evaluation purposes with the help of analysis cookies using technologies of the provider. A pseudonymized user profile can be created from this data. This service is an on-premise solution, so there is no transfer of personal data to the service provider.

The data collected with the Webtrends technologies will not be used to personally identify the visitor of this website and will not be combined with personal data about the bearer of the pseudonym without the separately granted consent of the person concerned.

4.7.2 Purposes and legal basis:

The legal basis for the creation and utilization of pseudonymous user profiles Art. 6 sec. 1 lit. f GDPR – legitimate interest. Our legitimate interest is to maximize our website’s user-friendliness and measure its reach.

4.7.3 Duration of storage or criteria for determining the duration:

Data collected and evaluated by use of web tracking tools are usually stored until you object to their use. If the data processing is based on your consent, your data will be stored until you revoke your consent.

4.7.4 Right to objectand options for deletion:

Since data processing is based on a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, there is no possibility of objection to this type of evaluation.

4.8 External services and content on our website

We integrate external services and content on our website. If you use such a service or if third-party content is displayed to you, communication data (access data, see section 2 above) will be exchanged between you and the respective provider for technical reasons. This access data is not personalized due to the type of technical integration.

For further information about the purpose and scope of the collection and processing of your data (by these service providers), please refer to the data protection notices of the providers responsible under data protection law of the services or content integrated by us:

 

Youtube (videos) https://policies.google.com/privacy?hl=en

5. Who obtains my data?

Within our company only those departments will have access to your data who need them in order to fulfil the purposes (see section 4 above). Service providers used by the company can also have access to your data (“Processors,” e.g. data centers , newsletter dispatch, processing of competitions and prize drawings, web tracking, video service providers). Our contracts with Processors ensure compliance with instructions, data security and a confidential treatment of your data by these service providers.

Data is not forwarded to other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”).

6. Are my data transferred outside of the EU (Third country transfer)?

Where any of the providers indicated in section 5 above are located outside the EU/EEA this might lead to the result that your data are processed in a country that does not maintain a level of data protection similar or equal to the one within the EU. However, such a level of data protection can be ensured with an appropriate guarantee. Suitable guarantees include standard contractual clauses provided by the EU Commission. You can request a copy of these guarantees on request, under the contact details provided in section 1. In exceptional cases, any guarantees may be waived if you give your consent or if the transfer to a third country is necessary for the performance of your contract with the company. The EU Commission has also recognized certain third countries as safe third countries, so that appropriate guarantees from our company can also be dispensed with in these cases.

7. What are my rights?

You have the right to information about your personal data stored by us at any time. If any information about you is incorrect or no longer current, you have the right to request that it be corrected. You also have the right to request the deletion or limitation of the processing of your data in accordance with Art. 17 or Art. 18 DSGVO. You may also have a right to the publication of the data you have provided in a common and machine-readable format (right to data transferability).

If you have given your consent to the processing of personal data for specific purposes, you can revoke your consent at any time with effect for the future. The revocation is to be addressed to the company at the contact address specified under item 1. Consents that you have given on the website can also be revoked by e-mail to benet@bertelsmann.de

In accordance with Art. 21 DSGVO, you have the right to object at any time for reasons arising from your particular situation to the processing of your data in accordance with the legal basis of Art. 6 para. 1 lit. f DSGVO.

You also have the option of contacting a data protection authority and lodging a complaint there. The authority responsible for the company is the: 

State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Phone: +49 (0) 211/38 424-0
Fax: +49 (0) 211/38 424-10
Email: poststelle@ldi.nrw.de

You can also contact the data protection authority responsible for your place of residence.

8. From where are my data collected?

All data collected on our website are directly collected from you. We do not merge these data with any information we might possibly hold from other instances.

9. Is there any automated decision-making (including profiling)?

We do not use fully automated decision-making for the purposes mentioned under point 4. No profiling takes place on the basis of this data

Data protection information dated: June 2018

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