Data Privacy

This privacy statement informs you about how we treat your data. To make the processing of your data transparent, we would like to provide you with the following information to give you an overview of these processing operations. To keep things fair, we additionally want to inform you about your rights pursuant to the EU-General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG). We will inform you in detail about
  1. General Information
  2. Data Processing on our Website
  3. Data Processing on our Social Media
  4. Further Data Processing
The Sanity Group GmbH is the controller of the data processing (hereinafter referred to as ‘we’ or ‘us’).

I. General Information

1. Contact

If you have any questions or feedback concerning this information or wish to contact us to exercise your rights, please send your enquiry to Sanity Group GmbH Jägerstr. 28-31 Tel.: +49 (0) 30 8878 9424 Email: info@sanitygroup.com

2. Legal Basis

The legal term ‘personal data’ refers to all information relating to an identified or identifiable natural person. We process personal data in compliance with the data protection regulations, in particular the GDPR and the BDSG. We solely process data based on law. We process personal data
  • solely with your consent (Art. 6 section 1 letter a) GDPR),
  • to perform a contract to which you are a party or to take steps at your request prior to entering into a contract (Art. 6 section 1 letter b) GDPR),
  • to comply with a legal obligation (Art. 6 section 1 letter c) GDPR) or
  • where processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (Art. 6 section 1 letter f) GDPR).

3. Period of Storage

Unless otherwise stated in the following, we will only store your data for as long as required to achieve the intended processing purpose or to fulfil our contractual or statutory obligations. In particular, such statutory retention requirements may result from regulations under commercial or tax law.

4. Recipients of Data

For certain processing activities, we rely on service providers. These processing activities include, for example, hosting, maintenance and support for IT systems, customer and client management, order processing, accounting, marketing or destruction of paper files and data carriers. A ‘processor’ is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Processors process data not for their own purposes but solely for the controller and are contractually obliged to implement appropriate technical and organizational measures ensuring data protection. Apart from that, we may transfer your data to postal and delivery services, our bank, consultants/auditors or the fiscal authority if necessary. Should your data be transferred to further recipients, you can find this information under the description of the respective processing activity.

5. Processing in the Exercise of your Rights pursuant to Art. 15 to 22 GDPR

If you exercise your rights pursuant to Art. 15 to 22 GDPR, we process the personal data transferred in order for us to grant you your rights and to acquire proof thereof. For the purpose of providing information and preparing such information, we will process the stored data only for this purpose as well as for purposes of data protection control and otherwise restrict processing in accordance with Art. 18 GDPR. These processing operations are based on Art. 6 section 1 letter c) GDPR in combination with Art. 15 to 22 GDPR and section 34 para. 2 BDSG.

6. Your rights

As the data subject, you are entitled to exercise your rights against us. In particular, you have the following rights:
  • Pursuant to Art. 15 GDPR and section 34 BDSG, you have the right of access to information confirming whether and, if so, to what extent we are processing personal data concerning you. Pursuant to Art. 16 GDPR, you have the right to rectification of your data.
  • Pursuant to Art. 17 GDPR and section 35 BDSG, you have the right to erasure of your personal data.
  • Pursuant to Art. 18 GDPR, you have the right to require us to restrict the processing of your personal data.
  • Pursuant to Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transfer such data to another controller.
  • Where you have granted us specific consent to a processing activity, you can withdraw such consent at any time pursuant to Art. 7 section 3 GDPR. Any such withdrawal of consent shall not affect the lawfulness of processing based on that consent prior to its withdrawal.
  • If you are of the view that the processing of your personal data infringes GDPR provisions, you have the right to lodge a complaint with a supervisory authority pursuant to Art.77 GDPR.

7. Right to object

Pursuant to Art. 21 section 1 GDPR, you have the right to object to processing activities based on Art. 6 section 1 letter e) or letter f) GDPR on grounds relating to your particular situation. If we process your personal data for the purpose of direct marketing, you may object to such processing pursuant to Art. 21 section 2 and section 3 GDPR.

8. Data protection officer

You can contact our data protection officer via the following address: dsb@sanitygroup.com.

II. Data processing on our website

During use of our website, we collect information that you provide yourself. We also automatically collect certain information about your use of the site during your visit to the site. In data protection law, the IP address is also considered personal data. An IP address is assigned to each device connected to the internet by the internet provider so that it can send and receive data.

1. Processing of Server-Log-Files

When using our website for informative purposes only, general information that your browser transfers to our server is initially stored automatically (not via registration). This includes by default: browser type/-version, operating system used, page called, the previously visited page (referrer URL), IP address, date and time of server request and HTTP status code. The processing is carried out in pursuit of our legitimate interests and is based on Art. 6 section 1 letter f) GDPR. This processing serves the technical administration and security of the website. The IP address is anonymized after 24 hours. For this the last octet is zeroed. The data collected will be deleted after seven days unless there is a justified suspicion of illegal use based on concrete indications and further examination and processing of the information is necessary for this reason. We are unable to identify you as a data subject based on the information collected. Art. 15 to 22 GDPR therefore do not apply pursuant to Art. 11 section 2 GDPR, unless you provide additional information to enable your identification in order to exercise the rights set out in these articles.

2. Data Transfer to third countries

Visiting our website may involve the transfer of certain personal data to third countries, i.e. countries where the DSGVO is not applicable law. Such a transfer shall be authorised if the European Commission has decided that an adequate level of data protection is ensured in such third country. In the absence of such an adequacy decision by the European Commission, personal data will only be transferred to a third country if appropriate safeguards are in place in accordance with Art. 46 DSGVO or if one of the conditions of Art. 49 DSGVO is met. Unless otherwise stated below, we use as appropriate safeguards the EU standard contractual clauses for the transfer of personal data to processors in third countries: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087.

3. Contact form and requests

Our website provides a contact form, through which you can enquire an offer from us. Your data is transferred encrypted (note the ‚https‘ in the address bar of your browser). All data fields marked as mandatory are necessary to be filled in for the handling of your request. Failure to provide the required information will result in us being unable to process your request. You have the alternative option to send us an email. We process the data for the purpose of handling your request. If your request relates to the establishment or execution of a contract with us, the processing of your data is based on Art. 6 section 1 letter b) GDPR. In all other cases we process data out of our legitimate interest in contacting the person enquiring. The latter data processing finds its legal basis in Art. 6 section 1 letter f) GDPR.

4. Newsletter

On our website we offer the possibility to subscribe to our newsletter. After the registration we will inform you regularly about the latest news about our offers. A valid e-mail address is required to register for the newsletter. To verify the e-mail address, you will first receive a registration e-mail, which you must confirm via a link (double opt-in). If you subscribe to the newsletter on our website, we process personal data such as your e-mail address and your name on the basis of the consent you have given. The processing is based on the legal basis of Art. 6 section 1 letter a) GDPR. You can revoke your consent at any time with effect for the future, for example by clicking on the “unsubscribe” link in the newsletter or by contacting us via the channels mentioned above. The legality of the data processing operations already carried out remains unaffected by the revocation. When you register for the newsletter, we also store the IP address and the date and time of registration. The processing of this data is necessary to prove that you have given your consent. The legal basis results from our legal obligation to document your consent (Art. 6 section 1 Letter c) in connection with Art. 7 section 1 GDPR). We also analyze the reading behavior and opening rates of our newsletter. For this purpose, we collect and process pseudonymized usage data which we do not merge with your e-mail address or IP address. The legal basis for the analysis of our newsletter is Art. 6 section 1 letter f) GDPR and the processing serves our legitimate interest in optimizing our newsletter. You can object to this at any time by contacting one of the contact channels mentioned above. For the administration of the subscribers and the sending of the newsletter, we use the service Klaviyo of the Klaviyo, Inc. (USA).

5. Cookies

We use cookies and similar technologies on our website. Cookies are small text files that are stored by your browser when you visit a website. This makes the browser identifiable so it can be recognised by our web server. We use so-called ‘session cookies’, which are deleted when the browser session is ended. Other cookies (‘persistent cookies’) are automatically deleted after a specific period, which may vary depending on the cookie. In part, the use of cookies is necessary to maintain functionality and operation of our website. Apart from that, we use cookies and similar technologies to measure the coverage of our website and analyse the use of our website. Cookies are stored on the computer of the user. Therefore, you as the user have full control over the use of cookies. You can delete cookies in the security settings of your browser at any time. You can object to the use of cookies entirely or for certain cases in your browser settings. Further information from the Federal Office for Information Security is available at https://www.bsi-fuer-buerger.de/BSIFB/DE/Empfehlungen/EinrichtungSoftware/EinrichtungBrowser/Sicherheitsmassnahmen/Cookies/cookies_node.html. You can find information on how we use cookies and similar technologies in the description of the specific processing activity. Further information about cookies used on our website can be found via the privacy settings in the consent banner. [uc-embed layout=”1″ data=”all”]

6. Usercentrics

On our website we use the Consent Management Platform Usercentrics. Usercentrics is a product of the company Usercentrics GmbH (Germany), which enables users of our website to grant or revoke their consent to certain data processing procedures. In addition, Usercentrics supports us in being able to provide evidence of the declaration of consent. For this purpose, Usercentrics processes information on the declaration of consent and further protocol data on this declaration. Cookies are also used to collect this data. The collected IP address is only processed in anonymized form. Proof of the revocation of a previously given consent is kept for three years. This is done so that we can meet our obligation to provide proof. The processing of this data is necessary in order to be able to prove that consent has been granted. The legal basis is derived from our legal obligation to document your consent (article 6 paragraph 1 letter c) in conjunction with Art. 7 section 1 GPDR).

7. Website analysis with Google Analytics

We use the Google Analytics service of Google Ireland Limited (Ireland/EU) to evaluate our website visits. Google uses cookies that enable an analysis of your use of our website. Personal data in the form of online identifiers (including cookie identifiers), IP addresses, device identifiers and information about your interaction with our website are processed. The information generated by the cookie about the use of our website by the user is usually transferred to a Google server in the USA and stored there. Google will use this information on our behalf to evaluate the use of our website by the users, to compile reports on the activities within our website and to provide us with further services related to the use of our website and the internet. The processed data can be used to create pseudonymous user profiles of the users. We only use Google Analytics with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. The IP address transmitted by the user’s browser is not merged with other Google data. We use the Google Universal Analytics variant. This enables us to assign interaction data from different devices and from different sessions to a unique User-ID. This allows us to put individual user actions into context and analyze long-term relationships. Data on user actions are stored for a period of 14 months and then automatically deleted. Data whose storage period has expired is automatically deleted once a month. The setting of cookies and the further processing of personal data described here is done with your consent. The legal basis for the data processing in connection with the Google Analytics service is therefore Art. 6 section 1 letter a) GDPR. You can prevent the storage of cookies by Google Analytics via a corresponding setting in your browser software. You can also prevent the collection of the information generated by the cookie by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout. If you visit our website via a mobile device, you can deactivate Google Analytics by clicking on this link. Please also note that we will document any consent you have given us in order to comply with our duty of proof under Art. 7 section 1 GDPR. As we are obliged to do so, this storage is based on the legal basis of Art. 6 section 1 letter. c) GDPR).

III. Data processing on our Social Media

We operate company pages on multiple social media platforms via which we offer further opportunities to obtain information about our company and for exchange. We operate company pages on the following social media platforms:
  • Facebook
  • Twitter
  • LinkedIn
  • YouTube
Visiting a company page on social media can result in your personal data being processed. The information in your social media account constitutes personal data. This also encompasses messages and statements made with the account. Additionally, certain information about your visit to a company page is often collected automatically during your visit.

1. Data Processing during the Visit of a Social Media Page

a. Facebook Page

Certain information about you is processed relating to your visit to our Facebook page on which we present our company or individual products. Facebook Ireland Ltd (Ireland/EU – ‘Facebook’) is the sole controller of this processing. Further information about the processing of personal data by Facebook is available via https://www.facebook.com/privacy/explanation. Facebook provides the opportunity to object to certain processing activities; corresponding information and opt-out-methods are available via https://www.facebook.com/settings?tab=ads. Facebook provides us with anonymised statistics and insights for our Facebook page, which enable us to gain knowledge about the ways in which people interact with our page (so called ‘insights’). These insights are created based on certain information about persons who have visited our page. Facebook and we are joint controllers of this processing. The processing serves our legitimate interest in evaluating the ways in which people interact with our page and improving our page based on this. This finds its legal basis in Art. 6 section 1 letter f) GDPR. It is impossible to match the information obtained via insights to individual accounts which interact with our Facebook page. We have concluded an agreement with Facebook on joint controllership in which the data protection duties are allocated between Facebook and us. Details of the processing of personal data for the creation of insights and of the agreement we concluded with Facebook are available via https://www.facebook.com/legal/terms/information_about_page_insights_data. Regarding these processing activities, you may also exercise your rights (see above ‘Your Rights’) against Facebook directly. Further information is available in Facebook’s privacy statement via https://www.facebook.com/privacy/explanation. Please note that user data is also processed in the USA and other third countries according to Facebook’s data protection guidelines. Facebook only transfers user data to countries for which the European Commission has made an adequacy decision pursuant to Art. 45 GDPR or based on appropriate safeguards pursuant to Art. 46 GDPR.

b. LinkedIn Company Page

Generally, the LinkedIn Ireland Unlimited Company (Ireland/EU – ‘LinkedIn’) is the sole controller of the processing of your personal data relating to a visit to our LinkedIn page. Further information on the processing of personal data by LinkedIn are available via https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy. If you visit or follow our LinkedIn company page, LinkedIn processes personal data to provide us with anonymised statistics and insights which enable us to gain knowledge about the ways in which interact with our page (so called ‘insights’). For this purpose, LinkedIn processes, in particular, such data that you already shared with LinkedIn by adding it to your profile like, for example, position, country, field of work, seniority, company size and employment status. Further, LinkedIn collects information on how you interact with our LinkedIn company page, for example whether you follow our LinkedIn company page. LinkedIn does not share personal data with us by providing us with the insights. We only have access to a summarized version of the insights. Also, we are unable to make conclusions about individual members from the information in the insights. LinkedIn and we are joint controllers of the processing regard the page insights. The processing serves our legitimate interest in evaluating the ways in which people interact with our page and improving our page based on this. This finds its legal basis in Art. 6 section 1 letter f) GDPR. We have concluded an agreement with LinkedIn on joint controllership in which the data protection duties are allocated between LinkedIn and us. The agreement is available via https://legal.linkedin.com/pages-joint-controller-addendum. The agreement stipulates the following:
  • LinkedIn and we have agreed that LinkedIn is responsible for enabling you to exercise your rights pursuant to the GDPR. In order to do so, you can contact LinkedIn online via (https://www.linkedin.com/help/linkedin/ask/PPQ?lang=de) or via the contact details in the data protection guidelines. You can contact the Data Protection Officer of LinkedIn Ireland via the following link: https://www.linkedin.com/help/linkedin/ask/TSO-DPO. You can also reach out to us via the contact details mentioned above for the exercise of your rights relating to the processing of your personal data for insights. In such a case, we will forward your request to LinkedIn.
  • LinkedIn and we have agreed that the Irish data protection commission shall be the responsible supervisory authority monitoring the processing for insights. You always have the right to lodge a complaint with the Irish data protection commission (see www.dataprotection.ie) or any other supervisory authority.
Please note that user data is also processed in the USA and other third countries according to LinkedIn’s data protection guidelines. LinkedIn only transfers user data to countries for which the European Commission has made an adequacy decision pursuant to Art. 45 GDPR or based on appropriate safeguards pursuant to Art. 46 GDPR.

c. Twitter

Generally, Twitter Inc. (USA) is the sole controller of the processing of your personal data relating to your visit to our Twitter account. Further information on the processing of personal data by Twitter Inc. is available via https://twitter.com/de/privacy.

d. YouTube

Generally, Google Ireland Limited (Ireland/EU) is the sole controller of the processing of your personal data relating to your visit to our YouTube channel. Further information on the processing of personal data by YouTube and Google Ireland Limited is available via https://policies.google.com/privacy.

2. Processing of Data you Share with us via our Company Pages

Additionally, we process information which you provide us with via the respective social media platform. Such information can include the username, contact details or a message to us. Generally, we only process this personal data if we have expressly requested you to share this data with us like, for example, in connection with a survey. We are the sole controller of such processing activities. We process this data in pursuit of our legitimate interest to reach out to persons submitting requests. The legal basis for this is Art. 6 section 1 letter f) GDPR. Additionally, we might process such data shared with us for purposes of evaluation or marketing. Such processing is based on Art. 6 section 1 letter f) GDPR and serve our legitimate interest to develop our product range and inform you about our product range. Further data processing can take place if you have consented (Art. 6 section 1 letter a) GDPR) or if this serves to fulfil a legal obligation (Art. 6 section 1 letter c) GDPR).

IV. Further data processing

1. Contact via Email

If you send us a message via our contact email address, we will process the transferred data in order to process the request. We process this data in pursuit of our legitimate interest to reach out to persons submitting requests. The legal basis for this is Art. 6 section 1 letter f) GDPR.

2. Contractual relationship

In order to establish and execute the contractual relationship with our customers, suppliers and business partners it is regularly necessary to process the master, contract and payment data provided to us. If we process personal data of our contact persons at commercial customers, suppliers and business partners in the course of this, this happens in pursuit of our legitimate interests and is based on Art. 6 section 1 letter f) GDPR. In addition, we process customer and potential customer data for evaluation and marketing purposes. This processing takes place on the legal basis of Art. 6 section 1 letter f) GDPR and serves our interest in further developing our product range and informing you specifically about products by Sanity Group GmbH. Further data processing can take place if you have consented (Art. 6 section 1 letter a) GDPR) or if this serves to fulfil a legal obligation (Art. 6 section 1 letter c) GDPR). August 2020