The Internet pages of CIC use cookies. Cookies are text files that are stored in a computer system via
an Internet browser.
Many Internet sites 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 dats subject from other
Internet browsers that contain other cookies. A specific Internet browser can be recognized and
identified using the unique cookie ID.
Through the use of cookies, CIC can provide the users of this website with more user-friendly services
that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in
mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this
recognition is to make it easier for users to utilize our website. The website user that uses cookies,
e.g. does not have to enter access data each time the website is accessed, because this is taken over
by the website, and the cookie is thus stored on the user’s computer system. Another example is the
cookie of a shopping cart in an online shop. The online store remembers the articles that a customer
has placed in the virtual shopping cart via a cookie.
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. This is possible in all popular Internet browsers. If the data subject
deactivates the setting of cookies in the Internet browser used, not all functions of our website may
be entirely usable.
Collection of data when visiting the website
The website of CIC collects a series of general data and information when a data subject or
automated system calls up the website. This general data and information are 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
referrers), (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, CIC does not draw any conclusions about the data
subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2)
optimize 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 case of a cyber-attack.
Therefore, the CIC analyzes anonymously collected data and information statistically, with the aim of
increasing the data protection and data security of our enterprise, and to ensure an optimal level of
protection for the personal data we process. The anonymous data of the server log files are stored
separately from all personal data provided by a data subject.
Collection of data when registering to the website
Registration to our website is necessary to (1) receive CIC´s newsletter (2) subscribe to an CIC´s event
(3) view or download content that is marked as “premium”.
To get registered we collect (1) your e-mail address, (2) the topics you are interested into, (3)your
acceptance to our privacy policy and (4) the time stamp when you do so.
The e-mail address and the topic selection are necessary to sending newsletter by e-mail to you. We
are therefore entitled for processing the data in accordance with art. 6.1.a of the GDPR. The
registration process and thus your consent will be logged by storing the time of the order. The legal
basis for processing the aforementioned data is our legitimate interest, along with art. 6.1.a of the
GDPR. Due to a legitimate interest, we also save your confirmation to have taken note of the privacy
policy, as we can document the fulfillment of our data protection obligations.
An additional indication of (5) your first name and surname, (6) salutation, (7) company, is possible on
a voluntary basis. If you provide us with this information, we will use it to personalize our e-mails to
you as well as for the interest-oriented design of our newsletter offer. We are then entitled to do so
on the basis of your consent given voluntarily according to art. 6.1.a. of the GDPR.
Unsubscribing from the newsletter is possible at any time and can either via a dedicated link in the
newsletter or by an e-mail message to the following address: josef.glass@execon-partners.com
If you revoke your consent by unsubscribing from the newsletter, we will delete the data provided by
you in the course of the newsletter registration, as long as there are no statutory storage
requirements or we are not otherwise authorized to store.
What kind of data is collected?
Typical server log information, including:
URL requested on our domain
Referring URL
IP address (anonymized)
Browser, language, and operating system used
Browser cookies on our domain
Time and date
Typical browser information, such as URL, title, and related metadata.
We use HTTP cookies on our domain for analytics, browser identifiers, to store your preferences.
We anonymize an IP address by zeroing the last octet (IPv4) or 80 bits (IPv6) before logging.
We may collect non-personally identifying aggregate usage data.
We do not collect personally identifiable information unless you provide it to us.
For example, when you contact us, you can optionally provide your name and email address.
How long is end user data retained?
We retain server log data for 30 days or less.
We do not retain server log data on static assets provided for use on sites across the web.
What kind of data is shared?
We may share non-personally identifiable information with data partners.
We do not share personally identifiable information.
What options are supported?
Do Not Track (DNT):
When a supported browser’s DNT header is enabled, we disable tracking across sites where
Analytics or AddToAny is used.
NAI Consumer Opt Out:
You can opt out of third party interest-based advertising from NAI members by using the NAI’s
opt-out page.
Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of
personal data. Which personal data are transmitted to the controller is determined by the respective
input mask used for the registration. The personal data entered by the data subject are collected and
stored exclusively for internal use by the controller, and for his own purposes. The controller may
request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an
internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service
provider (ISP) and used by the data subject—date, and time of the registration are also stored. The
storage of this data takes place against the background that this is the only way to prevent the misuse
of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the
storage of this data is necessary to secure the controller. This data is not passed on to third parties
unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal
prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to
enable the controller to offer the data subject contents or services that may only be offered to
registered users due to the nature of the matter in question. Registered persons are free to change
the personal data specified during the registration at any time, or to have them completely deleted
from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to
what personal data are stored about the data subject. In addition, the data controller shall correct or
erase personal data at the request or indication of the data subject, insofar as there are no statutory
storage obligations. The entirety of the controller’s employees are available to the data subject in this
respect as contact persons.
Subscription to our newsletters
On the website of CIC, users are given the opportunity to subscribe to our newsletter. The input mask
used for this purpose determines what personal data are transmitted, as well as when the newsletter
is ordered from the controller.
The CIC informs its customers and business partners regularly by means of a newsletter about
enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data
subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A
confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for
newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is
used to prove whether the owner of the e-mail address as the data subject is authorized to receive
the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system
assigned by the Internet service provider (ISP) and used by the data subject at the time of the
registration, as well as the date and time of the registration. The collection of this data is necessary in
order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and
it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our
newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is
necessary for the operation of the newsletter service or a registration in question, as this could be the
case in the event of modifications to the newsletter offer, or in the event of a change in technical
circumstances. There will be no transfer of personal data collected by the newsletter service to third
parties. The subscription to our newsletter may be terminated by the data subject at any time. The
consent to the storage of personal data, which the data subject has given for shipping the newsletter,
may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found
in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the
website of the controller, or to communicate this to the controller in a different way.
Newsletter-Tracking
The newsletter of the CIC contains so-called tracking pixels. A tracking pixel is a miniature graphic
embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis.
This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the
embedded tracking pixel, the CIC may see if and when an e-mail was opened by a data subject, and
which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and
analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the
content of future newsletters even better to the interests of the data subject. These personal data will
not be passed on to third parties. Data subjects are at any time entitled to revoke the respective
separate declaration of consent issued by means of the double-opt-in procedure. After a revocation,
these personal data will be deleted by the controller. The CIC automatically regards a withdrawal from
the receipt of the newsletter as a revocation.
Contact possibility via the website
The website of the CIC contains information that enables a quick electronic contact to our manager as
well as direct communication with us, which also includes a general address of the so-called
electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact
form, the personal data transmitted by the data subject are automatically stored. Such personal data
transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of
processing or contacting the data subject. There is no transfer of this personal data to third parties.
Comments function
CIC offers users the possibility to leave individual comments on individual blog contributions on some
of the website´s pages, such as „Insights“, which is on the website of the controller. A blog is a web-
based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers
may post articles or write down thoughts in so-called blogposts. Blogposts may usually be
commented by third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the
data subject are also stored and published, as well as information on the date of the commentary
and on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the
Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes
place for security reasons, and in case the data subject violates the rights of third parties, or posts
illegal content through a given comment. The storage of these personal data is, therefore, in the own
interest of the data controller, so that he can exculpate in the event of an infringement. This collected
personal data will not be passed to third parties, unless such a transfer is required by law or serves
the aim of the defense of the data controller.
Subscription to comments
The comments made in the blog of the CIC may be subscribed to by third parties. In particular, there
is the possibility that a commenter subscribes to the comments following his comments on a
particular blog post.
If a data subject decides to subscribe to the option, the controller will send an automatic confirmation
e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address
decided in favor of this option. The option to subscribe to comments may be terminated at any time.
Routine erasure and blocking of personal data
The data 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 to.
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.
Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller
the confirmation as to whether or not personal data concerning him or her are being processed. If a
data subject wishes to avail himself 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)
of the 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 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 to which the processing is based according to point (a) of
Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal
ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no
overriding legitimate grounds for the processing, or the data subject objects to the processing
pursuant to Article 21(2) of the 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) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of
personal data stored by the CIC, he or she may, at any time, contact any employee of the controller.
An employee of CIC shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase
the personal data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other
controllers processing the personal data that the data subject has requested erasure by such
controllers of any links to, or copy or replication of, those personal data, as far as processing is not
required. An employees of the CIC will arrange the necessary measures in individual cases.
e) Right of 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 instead.
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) of the 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 the CIC, he or she may at any time contact any employee of
the controller. The employee of the CIC 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) of the GDPR or point (a) of Article
9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the 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.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR,
the data subject shall have the right to have personal data transmitted directly from one controller to
another, where technically feasible and when doing so does not adversely affect the rights and
freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee
of the CIC.
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 of the GDPR. This also applies to profiling based
on these provisions.
CIC 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 the CIC 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 the CIC to the processing for direct marketing purposes, the CIC will no longer process the personal
data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to
object to processing of personal data concerning him or her by CIC for scientific or historical research
purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is
necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the CIC. In
addition, the data subject is free in the context of the use of information society services, and
notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using
technical specifications.
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 is
necessary for entering into, or the performance of, a contract between the data subject and a data
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 decision (1) is necessary for entering into, or the performance of, a contract between the data
subject and a data controller, or (2) it is based on the data subject’s explicit consent, the CIC shall
implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate
interests, at least the right to obtain human intervention on the part of the controller, to express his
or her point of view and contest the decision.
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 CIC.
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 CIC.
Data protection for job applications
The data controller shall collect and process the personal data of applicants for the purpose of the
processing of the application procedure. The processing may also be carried out electronically. This is
the case, in particular, if an applicant submits corresponding application documents by e-mail or by
means of a web form on the website to the controller. If the data 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 by the controller, the application documents shall be
automatically erased two months after notification of the refusal decision, provided that no other
legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this
relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
Legal basis for the processing
Art. 6(1) lit. 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) lit. b GDPR. The same applies to such processing operations which are necessary
for carrying out pre-contractual measures, for example in the case of inquiries concerning our
products or services. Is our company subject to a legal obligation by which processing of personal
data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c
GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of
the data subject or of another natural person. This would be the case, for example, if a visitor were
injured in our company and his name, age, health insurance data or other vital information would
have to be passed on to a doctor, hospital or other third party. Then the processing would be based
on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. 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 which require protection of personal data. Such
processing operations are particularly permissible because they have been specifically mentioned by
the European legislator. He considered that a legitimate interest could be assumed if the data subject
is a client of the controller (Recital 47 Sentence 2 GDPR).
The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to
carry out our business in favor of the well-being of all our employees and the shareholders.
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 fulfillment of the contract or the initiation of a contract.
Provision of personal data as statutory or contractual requirement; Requirement necessary to
enter into a contract; Obligation of the data subject to provide the personal data; possible
consequences of failure to provide such data
We clarify 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. The non-provision of the personal
data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact any employee.
The employee clarifies to the data subject whether the provision of the personal data is required by
law or contract or is necessary for the conclusion of the contract, whether there is an obligation to
provide the personal data and the consequences of non-provision of the personal data.
Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This Privacy Policy has been generated by the Privacy Policy Generator of the Deutsche Gesellschaft
für Datenschutz that was developed in cooperation with the Media Law Lawyers from WBS-LAW.
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