Privacy Policy

1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Smart Letter of Credit GmbH, Zur grünen Brücke 18, 23843 Bad Oldesloe, Deutschland, Tel.: +49 1520 7135 402, E-Mail: contact@smartloc.link. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection When You Visit Our Website

2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

• Our visited website
• Date and time at the moment of access
• Amount of data sent in bytes
• Source/reference from which you came to the page
• Browser used
• Operating system used
• IP address used (if applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) Cookies

In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be limited if cookies are not accepted.

4) Contacting Us

4.1 Calendly

For the provision of an online appointment booking function, we use the services of the following provider: Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA

For the purpose of making an appointment, your first name, surname and e-mail address (and telephone number, if a telephone appointment is requested) are collected in accordance with Art. 6 (1) point b GDPR and transferred to the provider in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the purpose of organising the appointments.

After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by the provider.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

4.2 Hubspot

Responso.com

We use the e-mail ticketing system of the following provider to process customer requests: HubSpot Ireland Ltd., 2nd Floor 30 North Wall Quay, Dublin 1, Irland

If you make contact requests by e-mail via our website, these are stored and organised in the ticketing system to enable chronological processing and to improve the service experience. You can always view the current status of the processing of your request via the individually assigned ticket number.

For the organisation and processing of requests, personal data is collected according to the scope of its provision, but in any case surname, first name and e-mail address, transferred to the provider, stored there and processed.

The legal basis for the processing of this data is our legitimate interest in the efficient design of our customer service, in answering your request as quickly as possible and in optimising our service offer in accordance with Art. 6 (1) point f GDPR.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

4.3 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

5) Registration at the portal or forum

You can register on our website by entering your personal data. The personal data processed for registration is determined by the input mask used for registration. We use the so-called double opt-in procedure for registration, i.e. your registration is not complete until you have previously confirmed your registration via a confirmation e-mail sent to you for this purpose by clicking on the link contained therein. If you do not receive confirmation within 24 hours, your registration will automatically be deleted from our database. You are obliged to provide the aforementioned data; all further information can be provided voluntarily by using our portal.

If you use our portal, we store your data necessary for the fulfillment of the contract as well as, if necessary, information on the method of payment, until you finally delete your access. Furthermore, we store the data provided voluntarily by you for the duration of your use of the portal, unless you delete it beforehand. You can manage and change all information in the protected customer area. The legal basis can be found in Art. 6 (1) point f GDPR.

In addition, we store all content published by you (such as public contributions, bulletin board entries, guestbook entries, etc.) to operate the website. We have a legitimate interest in providing the website and the complete user-generated content. The legal basis can be found in Art. 6 (1) point f GDPR. If you delete your account, your public statements, especially in the forum, will remain visible to all readers. However, your account is no longer accessible. All other data will be deleted in this case.

6) Use of Client Data for Direct Advertising

Subscribe to our e-mail newsletter

If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.

By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.

7) Web Analysis Services

Matomo
This website uses a web analytics service provided by the following provider: InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, ("Matomo").
Pseudonymised usage profiles can be created and evaluated from this data for the same purpose. Cookies may be used for this purpose. Cookies are small text files that are stored locally in the cache of the site visitor's Internet browser. Among other things, the cookies enable the recognition of the Internet browser. If data collected using Matomo technology (including your pseudonymised IP address) is transferred to Matomo servers in New Zealand and processed for usage analysis purposes, we inform you that the European Commission has issued a so-called adequacy decision for New Zealand, which certifies compliance with European data protection standards for international data transfers.
The pseudonymised information generated by the cookie is not used to personally identify the visitor to this website and is not merged with personal data about the bearer of the pseudonym.
All processing described above, in particular the setting of cookies for reading out information on the end device used, will only be carried out if you have given us your express consent to do so in accordance with Art. 6 Para. 1 letter a GDPR. Without this consent, Matomo will not be used during your visit to the website.
You can revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the "Cookie Consent Tool" provided on the website.

8) Site functionalities

8.1 LinkedIn plugins

Plugins of the social network of the following provider are used on our website: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

These plugins allow direct interaction with content on the social network.

In order to increase the protection of your data when visiting our website, the plugins are initially deactivated and integrated into the page by means of a so-called "2-click" or "Shariff" solution. This integration ensures that when you access a page of our website that contains such plugins, no connection is yet established with the servers of the provider.

Your browser only establishes a direct connection to the servers of the provider when you activate the plugins and thereby give your consent to the data transfer in accordance with Art. 6 (1) point a GDPR. In this process, regardless of whether you log into an existing user profile, a certain amount of information about your end device used (including your IP address), your browser and your page history is transferred to the provider and may be further processed there.

If you are logged into an existing user profile on the provider's social network, information about interactions carried out via the plugins will also be published there and displayed to your contacts.

You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no influence on the data that has already been transferred to the provider.

Data can also be transferred to: LinkedIn Inc., USA

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorised disclosure to third parties.

For the transfer of data to the USA, the provider relies on standard contractual clauses of the European Commission, which are meant to ensure compliance with the European level of data protection.

8.2 YouTube Videos

This website uses plugins to display and play videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland

Data may also be transmitted to: Google LLC., USA.

When you call up a page of our website that contains such a plugin, your browser establishes a direct connection to the provider's servers to load the plugin. This involves certain information, including your IP address, being transmitted to the provider.

If the playback of embedded videos is started via the plugin, the provider also uses cookies to collect information about user behavior, to create playback statistics and to prevent abusive behavior.

If you are logged into a user account maintained by the provider during your visit to the site, your data will be directly assigned to your account when you click on a video. If you do not wish to have your data assigned to your account, you must log out before clicking on the play button.

All the above-mentioned processing, in particular the setting of cookies for reading out information on the end device used, only takes place if you have given us your express consent in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the "cookie consent tool" provided on the website.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8.3 OpenStreetMap

This website uses an online map service provided by the following provider: OpenStreetMap Foundation, St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, UK

The online map service is a tool for displaying interactive maps in order to visually present geographical information. By using this service, our location is displayed to you and any geolocation is made easier.

Already when accessing those sub-pages in which the map of the provider is integrated, information about your use of our website (such as your IP address) is transferred to servers of the provider and stored there.

The processing of your personal data is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in the demand-oriented design of our website. If you do not agree to the future transfer of your data to the provider, it is possible to completely deactivate the provider's online map service by deactivating the JavaScript application in your browser. The online map service on this website can then no longer be used.

To the extent legally required, we have obtained your consent for the processing of your data as described above in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future. In order to exercise your revocation, please follow the option described above for making an objection.

For a data transfer to the provider location, an adequate level of data protection is guaranteed by an adequacy decision of the European Commission.

8.4 Microsoft Teams

We use this provider to conduct online meetings, video conferences and/or webinars: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA

The provider processes different data, whereby the scope of the processed data depends on the data you provide before or during the participation in an online meeting, video conference or webinar. Your data as a communication participant is processed and stored on servers of the provider. This may include, in particular, your registration data (name, e-mail address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)). In addition, participants' image and sound contributions as well as voice input in chats may be processed.

For the processing of personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) point b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing is based on Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future.
In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 (1) point f GDPR in the effective conduct of the online meeting, webinar or video conference.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8.5 Applications for job advertisements
On our website, we advertise current vacancies in a separate section, for which interested parties can apply by e-mail using the contact address provided.
If applicants want to be included in the application process, they must provide us with all personal details required for a well-founded and informed assessment and selection in conjunction with their application by e-mail.
The required data should include general personal information (name, address, telephone or electronic contact) as well as performance-specific evidence showing the qualifications required for the advertised position. In addition, health-related information may be required, which in the interest of social protection must be given special attention to regarding the applicant's person according to labor and social law.
The components an application must contain to be considered and the form in which these components must be sent by e-mail can be found in the respective job advertisement.
After receipt of the application sent using the e-mail contact address supplied, the applicant data will be stored by us and evaluated exclusively for the purpose of processing the application. In the event of queries arising in the course of processing the application, we will use either the e-mail address supplied by the applicant with his application or a telephone number supplied, at our discretion.
The legal basis for such processing, including the contacting of applicants for queries, is basically Art. 6 (1) point b GDPR in conjunction with Art. 26 (1) Federal Data Protection Act. According to these provisions, the completion of the application procedure is deemed to be the initiation of an employment contract.
If special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data such as information on severely disabled status) are requested from applicants as part of the application procedure, processing will take place in accordance with Art. 9 (2) point b GDPR, so as to enable us to exercise the rights arising from labor law, social security and social protection law and to fulfil our obligations in this regard.
The processing of special categories of data may also be based cumulatively or alternatively on Art. 9 (1) point h GDPR if it is used for the purposes of health care or occupational medicine, for the assessment of the applicant's ability to work, for medical diagnostics, health or social care or for the management of systems and services in the health or social sector.
If, in the course of the evaluation described above, the applicant is not selected or if an applicant withdraws his application prematurely, his data transmitted by e-mail as well as all electronic correspondence including the original application e-mail will be deleted at the latest after 6 months following a corresponding notification. This period shall be determined on the basis of our legitimate interest in being able to answer any follow-up questions regarding the application and, if necessary, to comply with our obligation to provide evidence under the regulations governing the equal treatment of applicants.
In the event of a successful application, the data provided will be processed on the basis of Art. 6 (1) point b GDPR in conjunction with Art. 26 (2) Federal Data Protection Act for the purposes of implementing the employment relationship.

8.6 Applications for job advertisements using a form
On our website, we offer those interested in a job the possibility to apply online using an appropriate form. In order to be included in the application process, applicants must provide us with all personal data required for a well-founded and informed assessment and selection.
The required data includes general personal information (name, address, telephone or electronic contact details) as well as performance-specific evidence of the qualifications required for a position. Where appropriate, health-related information may also be required, which, in the interests of social protection, must be given special consideration in the applicant's own person under labour and social law.
In the course of sending the form, the applicant's data will be encrypted according to the state of the art, transmitted to us, stored by us and evaluated exclusively for the purpose of processing the application.
The legal basis for these processing operations is generally Art. 6 Para. 1 lit. b, in the sense of which passing through the application procedure is considered to be the initiation of an employment contract.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data such as information on the status of severely disabled persons) are requested from applicants in the context of the application procedure, processing is carried out in accordance with Art. Art. 9 para. 2 lit. b. GDPR so that we can exercise the rights arising from labour law and social security and social protection law and fulfil our obligations in this respect.
Cumulatively or alternatively, the processing of the special categories of data may also be based on Art. 9 para. 1 lit. h GDPR, if it is carried out for purposes of preventive health care or occupational medicine, for the assessment of the applicant's ability to work, for medical diagnosis, care or treatment in the health or social field or for the management of systems and services in the health or social field.
If, in the course of the evaluation described above, the applicant is not selected, or if an applicant withdraws his or her application prematurely, the data submitted on the application form will be deleted after 6 months at the latest after notification. This period is calculated on the basis of our legitimate interest in being able to answer any follow-up questions about the application and, if necessary, to comply with our obligation to provide evidence in accordance with the regulations on the equal treatment of applicants.
In the event of a successful application, the data provided will be further processed on the basis of Art. 6 para. 1 lit. b GDPR for the purposes of the employment relationship.

9) Tools and Miscellaneous

This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. Through the use of the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.

Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

10) Rights of the Data Subject

10.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

• Right of access by the data subject pursuant to Art. 15 GDPR;
• Right to rectification pursuant to Art. 16 GDPR;
• Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
• Right to restriction of processing pursuant to Art. 18 GDPR;
• Right to be informed pursuant to Art. 19 GDPR;
• Right to data portability pursuant to Art. 20 GDPR;
• Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
• Right to lodge a complaint pursuant to Art. 77 GDPR.

10.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

11) Duration of Storage of Personal Data

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.