Privacy Policy of collaboration Factory GmbH
Date: May 2026
1. Introduction
In this Privacy Policy, you will learn how we process your personal data in the context of your use of our websites and Internet services, including the German/European website and the U.S. website. This Privacy Policy is intended to serve as a single global policy. The provisions relating to the European Economic Area (“EEA”) and United Kingdom (“UK”) explain information required under the GDPR and comparable European data protection laws. The U.S. provisions explain additional disclosures and rights that may apply to residents of the United States, including California residents where applicable.
2. Definition of Terms
Unless this Privacy Policy contains or implies a different definition, reference is made to the definitions in Art. 4 GDPR with regard to the terms used. For U.S. users, terms such as “personal information,” “consumer,” “business,” “service provider,” “contractor,” “sell,” “share,” “targeted advertising,” “sensitive personal information,” and “profiling” have the meanings given to them under applicable U.S. state consumer privacy laws, including the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) (collectively, “CCPA “), where applicable.
3. Controller
For users in the EEA/UK, this Privacy Policy applies to data processing by us as controller pursuant to Article 4 (7) of the General Data Protection Regulation (GDPR) and applicable local data protection laws. For users in the United States, references to “personal data” include “personal information” as defined under applicable U.S. state consumer privacy laws. Our contact details are:
collaboration Factory GmbH
Arnulfstraße 34
D-80335 Munich
Represented by: Doug Surrett, Marie Pawelzik (Managing Directors)
Registry Court and -number: Munich, HRB 299416
Contact and privacy request methods:
E-Mail: [email protected]
Privacy requests: [email protected]
Tel: +49 (0)89 809133 230
Fax: +49 (0)89 809133 239
4. Data Protection Officer
External Data Protection Officer
Dr. Jochen Notholt
comp/lex – Lösungen & Dienste
Lindwurmstr. 10
80337 Munich
Germany
E-Mail: [email protected]
Tel: +49 (0)89 41614295 0
5. Website Access
When you access our websites (and if you do not transfer information to us in any other way), we or the host provider acting on our behalf only collect the personal data that your browser transfers to our server. The provision of server log data is technically necessary to access our websites; without this data, the websites cannot be displayed. For U.S. users, these data elements may fall within categories such as identifiers, internet or other electronic network activity information, geolocation information inferred from IP address, and device/browser information. If you wish to view our websites, we collect the following data:
- IP address
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (concrete page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Operating system
- Language and version of the browser software
This data is technically necessary for us to display and provide you with our websites, maintain security, troubleshoot errors, prevent misuse or fraud, and generate aggregated usage statistics where permitted. The legal basis for this processing for EEA/UK users is Art. 6(1)(f) GDPR; our legitimate interests are the proper provision and security of our websites, the prevention and detection of fraud, and the optimization of our services. For U.S. users, we process this information for business purposes such as providing and securing the websites. This data is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum of 7 days and then deleted, unless a longer period is required for evidentiary, security, legal, or compliance purposes. The hosting service provider we use processes personal data for us on assignment and within the scope of our instructions as a processor pursuant to Art. 28 GDPR and, for U.S. purposes, as a service provider/contractor where applicable.
6. Cookie Usage
6.1. Our websites use cookies.
Cookies are usually small text files that are stored in the browser directory or program data subdirectories of your computer. They are created when you use your browser to visit a website that uses cookies.
Cookies are stored in the browser directory of your computer or in subfolders during your visit to our websites either for the duration of your visit or in case you visit our websites again at a later time. They enable our websites to retrieve or store information about you, your settings or your device from your browser. They are mainly used to ensure the expected functionality of the websites. As a rule, cookies do not contain information that could directly identify you. However, they allow us to provide you with a more personalized web experience.
We distinguish the following categories of cookies and related data processing:
1. Strictly necessary
2. Experience enhancement
3. Measurement
4. Targeting & Advertising
We use a privacy-protective consent approach. Except for strictly necessary cookies and similar technologies, we will use cookies, analytics, advertising, tracking pixels, tags, SDKs, or similar technologies only where we have obtained consent as required by applicable law, including 25 TTDSG (German Telecommunications and Telemedia Data Protection Act) and Art. 6(1)(a) GDPR for EEA/UK users.
U.S. users may opt out of any sale, sharing, or processing for targeted advertising by disabling advertising cookies in the cookie consent management tool or using this link. We will also honor Global Privacy Control (“GPC,” a technical specification that allows users to signal opt-out preferences) and other legally required universal opt-out preference signals where required by applicable law. We do not discriminate against consumers who exercise their privacy rights. Our websites currently respond to Global Privacy Control signals. With respect to browser-based “Do Not Track” signals, we do not currently respond to such signals as there is no universally accepted standard for how to do so, but we will continue to monitor developments in this area.
| Tool | Cookie name | Category |
|---|---|---|
|
|
_gaesa |
Measurement |
|
|
NID |
Targeting & Advertising |
|
DoubleClick (Google) |
DSID |
Targeting & Advertising |
|
iubenda |
_iub_cs-252372 |
Strictly necessary |
|
Hubspot |
__hstc |
Measurement |
|
LinkedIn Ads |
GAID |
Targeting & Advertising |
|
|
AnalyticsSyncHistory |
Measurement |
|
Google Ads |
AID |
Targeting & Advertising |
|
GitBook |
gitbook-visitor-token |
Measurement |
|
WordPress |
wp-wpml_current_language |
Strictly necessary |
6.2. Analytics through Google Analytics 4
Our websites optionally use Google Analytics 4 so that we can further improve future websites. You can consent to the use of Google Analytics 4 when accessing the websites. You can revoke your consent to the use of Google Analytics 4 at any time. If you give us your consent, we evaluate the use of the websites. However, we do not make an allocation at the individual level. For this purpose, we process the following personal data from you
- IP adress (anonymized)
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (concrete page)
- Access status/HTTP status code
- Amount of data transferred in each case
- website, from which the request comes
- browser
- Information about your end device
- Operating system and its interface
- Language and version of the browser software
- screen and window resolution
- Your approximate location
- Information about the time you spend on the site
- Information about actions you perform on the websites
As already mentioned, we process this data exclusively with your consent. The legal basis for this is Art. 6 para. 1 lit. a GDPR.
In the context of the use of the Google Analytics 4 services, there are also data transfers from Google to affiliated companies and/or subcontracted processors. In this context, the above-mentioned data may be transferred to the USA and stored there. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy.
6.3. Use of Google Ads Remarketing
In rare cases, we use the remarketing function within the Google Ads service. The remarketing function allows us to present users of our websites with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called “Google Ads” or on other websites). You may consent to the use of Google Ads Remarketing when you access the websites. You can revoke your consent to the use of Google Ads Remarketing at any time. If you give us your consent, we evaluate the use of the websites in order to play you interest-based advertising on other websites. However, we do not make an allocation at the individual level. For this purpose, we process the following personal data from you
- IP address
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (concrete terms)
- Access status/HTTP status code
- Amount of data transferred in each case
- website, from which the request comes
- browser
- Information about your terminal device
- Operating system and its interface
- Language and version of the browser software
- screen and window resolution
- Your approximate location
- Information about the time you spend on the site
- Information about actions you perform on the websites
As already mentioned, we process this data exclusively with your consent. The legal basis for this is Art. 6 para. 1 lit. a GDPR.
In the context of the use of the Google Ads Remarketing services, there are also data transfers from Google to affiliated companies and/or subcontracted processors. In this context, the above-mentioned data may be transferred to the USA and stored there.. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy.
In addition to the possibility of revoking consent to this data processing, you can additionally prevent participation in this tracking procedure in various ways:
- by adjusting your browser software settings accordingly; in particular, suppressing third-party cookies will prevent you from receiving third-party ads;
- by installing the plug-in provided by Google at the following link: https://www.google.com/settings/ads/plugin;
- by disabling the interest-based ads of the providers that are part of the “About Ads” self-regulatory campaign at the link http://www.aboutads.info/choices, with this setting being deleted when you delete your cookies;
- by permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome at the link http://www.google.com/settings/ads/plugin,
- by means of the corresponding cookie setting. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent.
6.4. Use of the Google Tag Managers
We use the Google Tag Manager on our websites. The Google Tag Manager is a service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Through Google Tag Manager, we can include various codes and services on our websites in an orderly and simplified manner. This allows us to manage website tags via one interface. When a tag is triggered, Google may process information (including personal data) and process it. In particular, the following personal data is processed by Google Tag Manager:
- Online identifiers (including cookie identifiers)
- IP adress
We use the Google Tag Manager in our interest to be able to make a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services. The legal basis for this is Art. 6 para. 1 lit. f GDPR.
Google processes the data on our behalf as a so-called Processor pursuant to Art. 28 GDPR. In the context of using the services of the Google Tag Manager, there are also data transfers from Google to affiliated companies and/or subcontractors. In this context, the above-mentioned data may be transferred to the USA and stored there. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy.
6.5. Analytics through LinkedIn Insight Tags
Our websites optionally use the LinkedIn Insight Tag, a service of LinkedIn Ireland Ltd, Wilton Plaza, Wilton Place, Dublin 2, Ireland. The LinkedIn Insight Tag stores and processes information about your user behavior on our websites. For this purpose, the LinkedIn Insight Tag uses, among other things, pixel, i.e. small image files that are stored locally in the cache of your web browser on your end device and that enable an analysis of your use of our websites. We process your data to evaluate campaigns and collect information about websites visitors who may have reached us through our campaigns on LinkedIn. You can consent to the use of the LinkedIn Insight Tag when accessing the websites. You can revoke your consent to the use of the LinkedIn Insight Tag at any time. If you give us your consent, we evaluate the use of the websites. For this purpose, we process the following personal data from you:
- IP address
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of the request (concrete terms)
- Access status/HTTP status code
- Amount of data transferred in each case
- website from which the request comes
- browser
- Information about your terminal device
- Operating system and its interface
- Language and version of the browser software
- screen and window resolution
- Your approximate location
- Information about the time you spend on the site
- Information about actions you perform on the websites
- demographic information if you are an active LinkedIn member.
As already mentioned, we process this data exclusively with your consent. The legal basis for this is Art. 6 para. 1 lit. a GDPR.
In the context of the use of LinkedIn Analytics services, there are also data transfers from the LinkedIn Insight Tag to affiliated companies and/or subcontracted processors. In this context, the above-mentioned data may be transferred to the USA and stored there. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy.
6.6. Handling Support Request using Efecte
We use Efecte to handle incoming support requests. Efecte is a service provided by Efecte Germany GmbH, Fürstenrieder Straße 279a, 81377 München. Efecte is used to integrate contact forms and forward your requests to us. In particular, the following personal data is processed by Efecte when you submit a support request to us:
- E-mail adress
- Name
- Your adress
- Information about your request (including text entries, photographs, videos)
We use Efecte in our interest to integrate a convenient and simple solution for handling support requests and to be able to guarantee you fast and uncomplicated processing of your requests in this way. The legal basis for this is Art. 6 para. 1 lit. f GDPR. The use of Efecte is optional. If you do not agree to us processing your data using Efecte, we offer you alternative contact options for submitting support requests by phone or mail.
Efecte processes the data on our behalf as a so-called Processor pursuant to Art. 28 GDPR. The data processing takes place exclusively in a country of the European Union or the European Economic Area.
6.7. In the context of contacting us by e-mail
We process e-mails that you transfer to us and we transfer to you using the services of our e-mail provider. In the context of e-mail communication, our e-mail provider processes your personal data (i.e. your e-mail address and the information you provide in the e-mail) on our assignment to enable us to communicate with you by e-mail or, if you are our customer, to process the contract. The processing of your personal data occurs on the basis of Art. 6 para. 1 lit. f or Art. 6 para. 1 lit. b GDPR. We delete the data if it is no longer necessary and there are no legal obligations to the contrary. We review the necessity every six months.
6.8. Within the framework of the subscription to our newsletter
With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers. In addition, our newsletters contain information about our products, promotions and our company.
For the registration to our newsletter we use the so-called double opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter shipping. In addition, we store your IP addresses and the times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.
Mandatory information for sending the newsletter are your e-mail address and name. After your confirmation, we store your e-mail address for the purpose of sending the newsletter and your name for the purpose of personal address in the mailings. The legal basis is Art. 6 para. 1 lit. a GDPR. We store your e-mail address for this purpose until you revoke your consent.
For mailing our newsletter, we use the services of service providers who act on our behalf and within the scope of our instructions as so-called Processors in accordance with Art. 28 GDPR personal data. This also includes service providers based in the USA. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy..
6.9. In the context of contact by telephone
If you contact us by phone, we need your personal data (e.g. name, contact details, etc.) to process your inquiry or request. This data processing is necessary to enable us to communicate with you or, if you are our customer, to process the contract. The processing of your personal data is based on Art. 6 para. 1 lit. f or Art. 6 para. 1 lit. b GDPR. We delete the data if it is no longer necessary and there are no legal obligations to the contrary. We review the necessity every six months.
6.10. Within the scope of contacting us via contact form
If you contact us via contact form, we need your personal data (escpecially your first name, last name, salutation, company and e-mail address) to process your inquiry or request. This data processing is necessary to enable us to communicate with you or, if you are our customer, to process the contract. The processing of your personal data is based on Art. 6 para. 1 lit. f or Art. 6 para. 1 lit. b GDPR. We delete the data if it is no longer necessary and there are no legal obligations to the contrary. We review the necessity every six months.
For U.S. users, we process this information for business purposes as described above. Newsletter, webinar, whitepaper, or other marketing consent must be presented as an unchecked choice and must not be pre-selected.
6.11. In the context of surveys with Microsoft Forms
To conduct surveys, we use Microsoft Forms from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”). Microsoft Forms enables us to design and evaluate surveys and online forms.
Participation in surveys is voluntary. On the basis of the survey results, we make anonymous evaluations that have no reference to the person surveyed. Nevertheless, Microsoft may collect and store metadata, such as your IP address, when you call up the web application.
The provision of personal data, such as e-mail address, is voluntary. The processing of this data is based on Art. 6 para. 1 lit. a DSGVO. We delete the data if it is no longer required and there are no legal obligations to the contrary.
We have concluded an order processing agreement with Microsoft for the use of Microsoft Forms, which obliges Microsoft to protect the data of our site visitors and not to pass it on to third parties. Processing regularly takes place within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. However, data transfers to the USA cannot be ruled out.
Further information regarding international data transfers can be found in Section 11 of this Privacy Policy.
Further information on Microsoft Forms can be found here: https://support.office.com/de-de/forms.
Further information on Microsoft’s data protection policy can be found at: https://privacy.microsoft.com/de-de/privacystatement.
6.12. In the context of your participation in our annual conference
The digital part of our annual PPM conference cplace Day/DIGI CON takes place on the event platform HyperCon. HyperCon, the service provider used and contractually bound by us, processes personal data on our behalf and within the scope of our instructions as a so-called order processor in accordance with GDPR, Art. 28. When you access this event website, we, respectively, the provider of hosting services contracted by us, will exclusively collect the personally identifiable data your browser transmits to our server. Specifically, these include:
- IP address
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of request (specific page)
- Access status/HTTP status code
- Volume of data transmitted
- Website initiating the request
- Browser
- Operating system and its user interface
- Browser software language and version
- Information about your device
We need these data for technical purposes to provide you with access to the event platform. The legal basis for the processing is Art. 6(1)(b) GDPR (performance of a contract) and, where applicable, Art. 6(1)(a) GDPR (consent).”. These data are stored for the duration of no more than 14 days for security reasons (e.g. to support investigations of misuse or fraudulent activities), and will be deleted thereafter. Data which must be stored as evidence beyond that period are exempt from erasure pending final resolution of the case in question. Hypercon’s privacy policy can be found at: https://www.iubenda.com/privacy-policy/36889631/legal?ifr=true&height=80….
6.12.1 Analytics through Google Analytics 4
Our event websites use Google Analytics 4. See point 5.3.
6.13. In the context of playing embedded videos via Youtube, and the use of Google Fonts
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows websites to incorporate content of this kind on their pages. In this context and to our knowledge, Google processes usage data and tracking data.
You can find more information on Google Fonts here: https://policies.google.com/privacy
For our websites, Google Fonts are hosted by ourselves, thus no personal data is transferred to Google.
However, if you want to play embedded videos on our websites, Google Fonts are used, which are provided by Google Ireland Ltd. Therefore, we ask you beforehand for your consent according to Art.6 para. 1 lit. a and Art. 49 para. 1 lit. a GDPR. When playing the videos, the following personal data will be processed from you:
- Tracker
- UUID
6.14. In the context of playing embedded videos via Vimeo
Some embedded videos on our websites are provided via Vimeo. Vimeo (Vimeo LLC, 555 West 18th Street New York, NY 10011 USA) is responsible under data protection law for the operation of the Vimeo platform. You can find Vimeo’s data protection notice at: https://vimeo.com/privacy
In this context, Vimeo processes the following personal data of you to our knowledge:
- IP address
- Date and time of the request
- Time zone difference from Greenwich Mean Time (GMT)
- Content of request (specific page)
- Access status/HTTP status code
- Volume of data transmitted
- Website initiating the request
- Browser
- Operating system and its user interface
- Browser software language and version
- Information about interaction with the Vimeo plug-in
- Device identifier of your equipment if applicable
- Version of the Vimeo software used by us
- Information about playbacks of the video to date
- Information about the way the video has been playback (e.g. full screen)
Before playing a video, we ask for your consent according to Art.6 para. 1 lit. a and Art. 49 para. 1 lit. a GDPR.
Vimeo will inevitably receive the data specified above. Vimeo is a service rendered by a provider from USA. Furthermore, we cannot exclude that data may additionally be routed by Internet servers located outside the EU. In particular, this may be the case when you as a participant are located in a third country. This means that your personally identifiable data will likewise be processed in a third country.. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy.
6.15. As part of the recruiting process
We process the following personal data from you for this purpose:
- Contact data (esp. name, address, date of birth, telephone number, e-mail).
- Application data (i.e. all data that you have submitted or provided to us as part of your application; e.g.: Details of professional qualifications and school education, details of further professional training, cover letters, certificates, references from employers, etc.
We process this data for the following purposes:
- Establishing employment contracts
- Building a talent pool to manage applicants for future positions
The legal basis for the processing is:
- Art. 6 para. 1 lit. b GDPR
- Art. 6 para. 1 lit. f GDPR
- Art. 6 para. 1 lit. a GDPR (especially for our Talent Pool)
- § 26 BDSG
Justification of legitimate interest:
collaboration Factory is in a constant state of development and growth. The acquisition of new partners, customers and thus projects enables us to further penetrate the market. Our project successes and the further distribution of our product are based, among other things, on the cooperation with competent and motivated employees.
In order to cope with current and future tasks, we need to further increase our staffing levels. Recruiting new employees is a decisive criterion in this regard.
Furthermore, collaboration Factory wants to position and present itself in the market as a valuable and long-term employer.
Applicants visit so-called applicant or recruiting fairs with the intention of applying for jobs offered by the companies represented. From this point of view, the personal data used in this context are made available for processing of their own will and impulse. The data to be processed is to be regarded as rather uncritical and is also shared by the applicants on social networks, among other things.
The overall consideration and weighing of the above-mentioned points leads to the assessment that the risk for our applicants is to be classified as very low to non-existent to suffer damage as data subjects according to Article 4 (12) of the GDPR (personal data breach).
Recipients of this data are:
- Internally: supervisors or internal departments responsible for hiring the person, managing directors or persons authorized to represent the company.
- Externally: Order processors for personnel data processing.
- Personio GmbH (Rundfunkplatz 4, 80335 Munich, Germany) has been commissioned as a processor. The service provider used by us and bound by contract processes personal data for us on behalf of and within the scope of our instructions as a so-called order processor pursuant to Art. 28 GDPR.
Deletion of data:
If no employment contract is concluded with the applicant, the application documents will be deleted no later than six months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such deletion. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).
Data stored in the talent pool will be deleted after 5 years at the latest, unless consent is revoked by the applicant.
6.16. Whistleblower-Portal
The portal is used for the integration of contact forms and the forwarding of your reports to the responsible recipient, namely the external ombudsman/external compliance officer. The collaboration Factory does not have access to the data you provide. The collaboration Factory is solely responsible for providing the portal to meet legal requirements.
For this purpose, we process the following personal data, which may be voluntarily provided by you:
- Inventory data (names, addresses)
- Contact data (email, phone numbers, fax, messenger)
- Content data (text entries, photographs, videos)
We process this data for the following purposes:
- Implementation of legal requirements in accordance with the HinSchG (Whistleblower Protection Act)
The legal basis for processing is:
- Art. 6 para. 1 lit. c GDPR
- Art. 28 GDPR
- §§ 10; 12-14 HinSchG
Recipients of this data are:
- External ombudsman/external compliance officer
- Data processors
Data deletion: The data will be deleted two (2) years after the conclusion of the procedure (see §11(5) HinSchG).
6.17. Usage of Hubspot
Our websites use the service HubSpot (HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500). Hubspot is an integrated software solution that we use to cover various aspects of our online marketing. These include: Email marketing, social media publishing & reporting, reporting, campaign controlling, contact management (e.g. user segmentation & CRM), landing pages and contact forms.
Hubspot enables website visitors to take advantage of marketing offers, download marketing content, and get in touch with us. The contact information left by our visitors is stored on HubSpot servers and used by us solely for our marketing efforts. All information we collect is subject to our privacy policy.
As part of our marketing measures, the following data may be collected and processed via Hubspot:
- Geographical position
- Browser type
- Navigation information
- Referral URL
- Performance data
- Information about how often the application is used
- Mobile apps data
- HubSpot subscription service credentials
- Files that are displayed on site
- Domain names
- Pages viewed
- Aggregated usage
- Operating system version
- Internet service provider
- IP address
- Device identifier
- Duration of visit
- Where the application was downloaded from
- Operating system
- Events that occur within the application
- Access times
- Clickstream data
- Device model and version
In addition, we also use Hubspot to provide forms, e.g. our contact form. If you leave personal data (e.g. name, email address, etc.) in our forms, we use this data to process your inquiry or request. This data processing is necessary to enable us to communicate with you. The processing of your personal data is based on Art. 6 para. 1 lit. f or Art. 6 para. 1 lit. b GDPR. The personal data will be kept for as long as it is necessary to fulfill the purpose of processing. The data will be deleted as soon as they are no longer required to achieve the purpose.
Further information in this regard can be found in section 6.10 of this privacy policy.
In the context of the use of HubSpot’s services, the above-mentioned data may be transferred to the USA and stored there. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy..
More information on HubSpot’s privacy policy.
More information from HubSpot regarding EU data protection regulations.
More information about the cookies used by HubSpot can be found here & here.
6.18. Usage of Training bookings and execution
We offer the opportunity to book training courses from the cplace Academy (e-learning, classroom training) on our websites.
The following categories of personal data are processed
- Master data (e.g. surname, first name, company affiliation)
- Contact data (e.g. e-mail address, billing address)
- User data (e.g. GitHub username, user name of the cplace training environments)
- Content data (in particular texts that you leave in the comment fields)
- Communication data (e.g. content in emails in the context of further, personal communication)
- Training status (e.g. status of participation, certificates of attendance)
- Online data (personal data that is transmitted when you visit our cplace training environments or websites, e.g. via your browser, see above)
We process this data for the following purposes:
- Providing an online system to carry out the booking process
- Establishment and conclusion of a contractual relationship for training services
- Preparation, implementation and follow-up activities of the booked training courses
The legal bases for the processing are:
- Art. 6 para. 1 lit. a GDPR
- Art. 6 para. 1 lit. b GDPR
- Art. 6 para. 1 lit. f GDPR
Justification of the legitimate interest:
Our legitimate interest lies in bringing our customers, partners, employees and interested parties closer to the use, possible applications and potentials associated with our product in a methodically and didactically prepared form and also to disseminate cplace knowledge in the community via this channel.
This directly serves the further penetration of our product into the market and thus represents a contribution to the business model of collaboration Factory AG.
The personal data to be processed is not considered critical. In particular, protective measures are also taken (e.g. double opt-in in the booking process), which make the misuse of personal data significantly more difficult. In this processing, no personal data of special categories pursuant to Art. 9 para. 1 GDPR are processed.
The risk for the person concerned of suffering damage in accordance with Art. 4 para. 12 GDPR (violation of the protection of personal data) is to be classified as very low. We therefore consider our legitimate interest to be legitimate and feasible in consideration of the aforementioned points.
The recipients of this data are
- Internal: Employees of collaboration Factory GmbH
- Externally: Processors
The processing of personal data is also carried out by our hosting service providers as our subcontractors.
Our websites and cplace installation are operated on servers of hosting service providers located in Germany, the EU or the EEA.
We currently work with the following hosting service provider:
For the hosting of cplace installations
Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen
Further information on data protection, security of processing and the status of the hosting service provider’s certifications can be found under the following links:
https://www.hetzner.com/de/legal/privacy-policy https://www.hetzner.com/de/unternehmen/zertifizierung https://www.hetzner.com/AV/TOM.pdf
For the operation of our websites:
Mittwald CM Service GmbH & Co. KG, Königsberger Str. 4 – 6, 32339 Espelkamp
The hosting service providers are contractually binded and function as Processors on our behalf in accordance with Art. 28 GDPR.
6.19. Provision of our Knowledge Base using GitBook
We use GitBook, a service provided by GitBook, Inc., 440 N Barranca Ave #1430, Covina, CA 91723, USA, to provide our knowledge base (kb.cplace.com). GitBook enables us to provide and manage documentation on our products and services for our users.
When you access our knowledge base, we or the service provider acting on our behalf only collect the personal data that your browser transmits to the server. In particular, the following personal data is processed:
- IP address
- Browser type and version
- Language preferences
- Referring website
- Date and time of the request
- Operating system
- Device information
GitBook uses cookies to ensure the functionality of the service.
The legal basis for this is Art. 6 (1) (b) GDPR and (f) GDPR.
We have entered into a data processing agreement with GitBook, which obliges GitBook to protect the data in our knowledge base and not to disclose it to third parties. GitBook stores and processes the data in the USA. Further information regarding international data transfers can be found in Section 11 of this Privacy Policy..
For more information about data protection at GitBook, please visit: https://policies.gitbook.com/privacy-and-security/statement
7. Automated Decision-Making and Security
We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of Art. 22 GDPR. If this changes in the future, we will update this Privacy Policy and, where required, obtain your explicit consent or provide you with the right to contest the decision. For U.S. users, you may have the right to opt out of certain profiling as described in Section 8.
With respect to security, we implement appropriate technical and organizational measures to protect your personal data. These measures include, for example, encryption of data in transit (TLS/SSL), access controls, regular security assessments, and employee training on data protection. No website, transmission, or storage system can be guaranteed to be completely secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately.
8. Your Privacy Rights
If you reside in the United States, you may have rights to request access to, correction of, deletion of, or portability of personal information; to opt out of sale, sharing, targeted advertising, or certain profiling; to limit the use or disclosure of sensitive personal information where applicable; and to appeal a denied request. California residents may also have the right to know the categories and specific pieces of personal information collected, the categories of sources, purposes, categories of recipients, and categories of personal information sold, shared, or disclosed for a business purpose, and the right not to be discriminated against for exercising privacy rights.
If you are located in the EEA or UK, you have the following rights under the GDPR: the right of access (Art. 15), the right to rectification (Art. 16), the right to erasure (Art. 17), the right to restriction of processing (Art. 18), the right to data portability (Art. 20), the right to object to processing based on legitimate interests or direct marketing (Art. 21), and the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you (Art. 22). Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal. You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement (Art. 77 GDPR). The competent supervisory authority for collaboration Factory GmbH is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA).
To exercise these rights, contact us at [email protected]. For requests submitted by individuals in the EEA/UK, we will respond in accordance with Art. 12 GDPR, generally within one month of receipt of the request.
For U.S. privacy requests, we will acknowledge we will acknowledge receipt of your request within 10 business days and respond substantively within 45 calendar days of receipt.
If additional time is needed, we will notify you of the extension and the reason. We will verify your identity before fulfilling requests, which may require you to provide information that matches information we maintain. Authorized agents may submit requests where permitted by law, subject to verification and proof of written authorization.
9. Disclosures to Processors, Service Providers, and Third Parties
We may disclose personal data to vendors, processors, service providers, contractors, professional advisers, affiliates, event and webinar support providers, hosting providers, analytics or marketing technology providers where consent has been obtained or another lawful basis applies, and authorities where required by law. We do not sell personal information for monetary or other valuable consideration. EEA/UK processors act under Art. 28 GDPR processing terms. U.S. service providers and contractors are contractually required to process personal information only for specified business purposes and under contractual restrictions required by applicable law.
10. Retention
We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including providing the websites, responding to requests, administering downloads or webinars, sending opted-in marketing, maintaining business records, complying with legal obligations, resolving disputes, and enforcing agreements. For website access log data, we retain data for a maximum of 7 days unless a longer period is required for security or legal purposes. For contact form and event registration data, we retain data for the duration of the business relationship and for up to 3 years thereafter, unless longer retention is required by law (e.g., tax retention obligations under German law of up to 10 years). For marketing data, we retain data until you withdraw consent or unsubscribe and for a reasonable period thereafter to document the opt-out. Specific retention periods may vary by data category and context; further details are available upon request.
11. International Transfers
As a company based in Germany, we may process personal data in Germany, the EEA, the United States, and other countries where we or our service providers operate. Where EEA/UK personal data is transferred to countries outside the EEA/UK that do not benefit from an adequacy decision, we rely on the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) and, for UK transfers, the UK International Data Transfer Addendum, supplemented by additional technical and organizational measures where appropriate. Where applicable, we may also rely on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, or the Swiss-U.S. Data Privacy Framework for transfers to certified U.S. organizations. You may obtain a copy of these safeguards by contacting us at the address above. U.S. users should understand that personal information may be transferred to and processed in countries that may have data protection laws different from those in their state or country.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. The effective date above indicates when the policy was last updated. We will notify you of material changes by posting the updated Privacy Policy on our websites with reasonable advance notice where required by law and, where appropriate and required by law, by providing additional notice (such as by email or a prominent notice on our websites) or obtaining your consent before the changes take effect.
13. Children and Minors
Our websites are intended for business users and are not directed to children. We do not knowingly collect personal information from children under 13 (the age threshold under the U.S. Children’s Online Privacy Protection Act, COPPA) or knowingly sell or share personal information of minors under 16 (as required under the CCPA). Under EU/German law, where consent is the legal basis for processing, we do not knowingly process personal data of children under 16 without parental consent (Art. 8 GDPR, as implemented in Germany). If you believe that a child has provided personal information to us, please contact us so that we can take appropriate action.