Privacy Policy

September 2024

We (i.e., the company providing you with this privacy policy or named in the legal notice as the operator of this site) take the protection of your personal data seriously. This privacy policy explains how we collect, use, disclose, transfer, and store your personal data (“process”). The personal data collected depends on the context of your interactions with us, the products, services, and features you use, your location, and the applicable law.

1. Processing of Personal Data in Connection with Your Use of Our Websites, Applications, and Online Services

Data Categories and Purpose of Processing

In the course of your use of our internal and external websites, applications, or online services (each an “Online Offering”), we process the following categories of personal data:

- Your contact information, such as first and last name, business address, business telephone number, business mobile number, and business email address,

- Organizational information, including position and company name,

- Further personal data you provide in contact forms and other forms on an Online Offering,

- Information you provide as part of a support inquiry, survey, comment, or forum post,

- Information that is automatically collected during the use of an Online Offering, such as your device and user ID, information about your operating system, pages and services you have used and visited during your visit, as well as the date and time of a user request.

We process your personal data for the following purposes:

- To enable you to use the functions and features of the Online Offerings, including creating and managing your online account, as part of updates, security, and troubleshooting measures,

- To provide customer support and to improve and further develop our Online Offerings,

- To bill for the use of an Online Offering, to verify your identity, and to enable user authentication,

- To process your request or instruction,

- To fulfill your order and provide you with related information and offers,

- To contact you with information and offers about our products and services and to send you further marketing information or to contact you as part of customer satisfaction surveys, as described in section 3,

- To enforce our terms of use, assert or defend legal claims, and prevent and combat fraudulent and similar actions, including attacks on our IT infrastructure.

Online Offerings Provided by Your Company

In some cases, our Online Offerings are provided to you by the company at which you are employed. If you use an Online Offering provided by your company, the processing of personal data provided by you or your company in the content of the Online Offering is carried out on behalf and according to the instructions of your company and within the framework of a data processing agreement between your company and us. In this case, your company is data controller under data protection law. If you have questions about personal data processed by us as a data processor for your company, please contact your company.

2. Processing of Personal Data in Connection with Your Use of Our Marketplaces

Data Categories and Purpose of Processing

In the course of your use of our marketplaces (each a “Marketplace”), we process the following categories of personal data:

- Your contact information, such as first and last name, business address, business telephone number, business mobile number, and business email address,

- Organizational information, including position and company name,

- Payment data such as information required for processing transactions or fraud prevention, including credit card information and card verification numbers,

- Further personal data you provide in contact forms and other forms on a Marketplace,

- Information you provide as part of a support inquiry, survey, comment, or forum post,

- Information that is required by law in the context of compliance and export control screenings, such as date of birth, nationality, residence, identification numbers, information on relevant legal proceedings and other legal disputes, and

- Information that is automatically collected during the use of a Marketplace, such as your device and user ID, information about your operating system, pages and services you have used and visited during your visit, as well as the date and time of a user request.

We process your personal data for the following purposes:

- Communication with you about our services and products, e.g., to process your requests or provide technical information about products,

- Planning, execution, and management of the (contractual) business relationship, e.g., to process orders of products and services, collect payments, for accounting and billing purposes, and for implementation of deliveries, maintenance activities or repairs,

- Contact you for information and offers related to our products and services and conducting further marketing activities and customer satisfaction surveys as described in section 4,

- Maintain and protect the security of our products, services, and websites, prevent and detect security risks, fraudulent practices, or other criminal or malicious activities,

- Comply with legal obligations (e.g., tax and commercial law retention obligations), existing obligations to conduct compliance screenings (to prevent economic crime or money laundering), and our policies and industry standards, and

- Settle legal disputes, enforce existing contracts, and assert, exercise and defend legal claims.

3. Processing of Personal Data from Business Partners

Data Categories and Purpose of Processing

In the course of collaborating with business partners, we process personal data from end consumers and contacts at customers, prospects, distributors, suppliers, and partners (each a “Business Partner”):

- Contact information, such as first and last name, business address, business phone number, business mobile number, and business email address,

- Organizational information, including position and company name,

- Payment data, such as the data required for processing payment transactions or fraud prevention, including credit card information and card verification numbers,

- Additional information whose processing is required in the context of a project or contract relationship with us, or that is voluntarily provided by business partners, e.g., in the context of orders placed, requests, or project details,

- Personal data retrieved from publicly available sources (including corporate or professional social networks and websites), information databases, or credit agencies, and

- Information legally required as part of compliance and export control screenings, such as date of birth, nationality, residence, identification numbers, information about relevant legal proceedings and other legal disputes, involving business partners.

We process personal data for the following purposes:

- Communication with business partners about products, services, and projects, e.g., to handle a business partner's request or provide technical information about products,

- Planning, execution, and management of the (contractual) business relationship between the business partner and us, e.g., to fulfil product and service orders, collect payments, for purposes of accounting and billing and for the implementation of deliveries, maintenance, or repairs,

- Develop a personal profile with business-related information about interactions between you and us to offer you and the company you work for relevant information and appropriate offers on services and products and improve our personal communication with you,

- Conduct market analysis, sweepstakes, competitions, or similar promotions and events,

- Contact you for information and offers related to our products and services and conduct other marketing activities and customer satisfaction surveys, as described in section 4,

- Maintain and protect the security of our products, services, and websites, prevent and detect security risks, fraudulent practices, or other criminal or malicious activities,

- Comply with legal obligations (e.g., tax and commercial law retention demands), existing obligations to conduct compliance screenings (to prevent economic crime or money laundering), and our policies and industry standards, and

- Settle legal disputes, enforce existing contracts, and assert, exercise, and defend legal claims.

4. Processing of Personal Data for Customer Satisfaction Surveys and Direct Marketing

Within applicable laws, we may use your contact information for the purposes of direct marketing (e.g., trade fair invitations, newsletters with information and offers about our products and services) and to conduct customer satisfaction surveys, also by email. You have the right to object to the use of your contact information for these purposes at any time by sending an email to info@GoTuro.de or by using the objection option in the message you have received.

5. Processing of Personal Data in Connection with Your Application

If you apply for a position with us, we process your personal data as described in the privacy policy of the GoTuro Recruiting Portal or the application platform you use.

6. Transfer and Disclosure of Personal Data

We transfer your personal data only as described below:

Companies and Sales Partners

For the purpose and to the extent necessary to conduct our business relationship with you, we transfer your personal data to our companies and other third parties (e.g., sales partners and representatives). For instance, we distribute certain products and services exclusively through local business relations, and in this case, we transfer your personal data to our respective local entities or other sales partners who handle the business relationship with you.

Transactions on Our Marketplaces

Through our marketplaces, we also provide products, services, and offers from our companies and other third parties. We transfer the personal data of our customers in connection with these transactions to the respective company and/or other third parties.

Service Providers

We commission companies and other businesses to perform tasks on our behalf, such as manufacturers, service providers, IT services, or payment processing. These companies and other businesses process personal data only for the purpose of the commissioned products and services.

Other Third Parties

We transfer personal data in connection with the fulfilment of legal obligations or the establishment, exercise, or defence of rights or claims to other third parties (e.g., for court and arbitration proceedings, to regulatory, law enforcement, and government authorities, to lawyers and consultants).

Recipients of your personal data may be located outside of the country where you reside. Personal data that you publish through online offerings (e.g., in chatrooms or forums) may be accessible globally to other registered users of the respective online offering.

7. Retention Periods

If no explicit retention period is specified at the time of collection (e.g., within a consent declaration), your personal data will be deleted when it is no longer required to fulfil the purpose of its storage, unless legal retention requirements (e.g., commercial and tax law retention requirements) prevent deletion.

8. Your Rights

Under applicable data protection law, you may have the right to:

- Request a confirmation as to whether we process personal data about you and obtain information about the personal data we process,

- Request the rectification of inaccurate personal data,

- Request the deletion of personal data we process,

- Request the restriction of processing personal data,

- Request the transfer of the personal data you have actively provided to us,

- Object to the processing of personal data for reasons arising from your particular situation, or

- Withdraw a declaration of consent.

9. Data Security

We take appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

10. Contact Person

Our data protection organization supports all questions on the subject of data protection. You can also make complaints to our data protection organization and assert the rights set forth in this privacy policy.

Our data protection organization can be reached at datenschutz@GoTuro.de.

Our data protection organization is always committed to addressing and remedying your inquiries and complaints. Besides contacting the data protection organization, you also have the option to contact the relevant data protection supervisory authority at any time.

11. Processing of Personal Data within the Scope of the EU General Data Protection Regulation

This section applies if your personal data is processed by one of our companies based in the European Economic Area.

Data Controller for Data Processing

Online Offerings

The data controller within the meaning of the General Data Protection Regulation for the processing activities described in this privacy policy is the company named in the legal notice of the online offering.

Marketplaces

The company indicated as the operator of the marketplace on the marketplace is the data controller for data processing.

Personal Data of Business Partners in Our Customer Relationship Systems

We share the contact data of business partners in the course of your business relationship with us with other companies. We and these companies are jointly responsible for protecting your personal data (Article 26 of the General Data Protection Regulation). To ensure that you can exercise your data protection rights under this joint responsibility easily and reliably, we have agreed with these companies that you can assert your data subject rights as described in section 6 not only against the respective company but also centrally against SCAILE Technologies GmbH. Contact us at: datenschutz@GoTuro.de.

Legal Basis for Processing

The General Data Protection Regulation requires GoTuro to inform you of the legal basis for data processing. Unless stated otherwise at the time of the collection of personal data, the legal basis for data processing is:

- The execution and performance of a contract with you (Article 6 (1) (b) of the General Data Protection Regulation) (“Contract Performance”),

- Compliance with legal obligations to which we are subject (Article 6 (1) (c) of the General Data Protection Regulation) (“Compliance with Legal Obligations”), or

- Our legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation) (“Legitimate Interest in Processing”).

Our legitimate interest lies in processing your personal data for the purpose of:

(i) Offering and operating the Online Offerings and

(ii) Initiating, executing, and processing our business relationship.

Where, according to the table below, our Legitimate Interest in Processing is indicated as the basis for processing your personal data, we consider that your interests, fundamental rights, and freedoms are sufficiently considered since:

(i) We regularly review the processing activities and underlying processes described in this privacy policy,

(ii) We incorporate the protection of your personal data into our processes, including the Binding Corporate Rules for the protection of personal data (GoTuro Binding Corporate Rules),

(iii) We ensure transparency of our processing activities, and

(iv) You are entitled to the above-mentioned rights regarding our processing activities.

If you wish to receive further information on the balancing of interests described, please contact our data protection organization at datenschutz@GoTuro.de.

If in individual cases you have expressly given your consent to the processing of your personal data, this consent is the legal basis for processing (Article 6 (1) (a) of the General Data Protection Regulation) (“Consent”).

Processing of Personal Data Related to the Use of Our Online Offerings – Purpose and Legal Basis

- Enabling the use of the functions and features of the Online Offerings, including creating and managing your online account, as part of updates, security, and troubleshooting measures, to provide customer support and improve and develop our Online Offerings further

- Contract Performance (Article 6 (1) (b) of the General Data Protection Regulation)