Privacy Policy

Welcome to our website and thank you for your interest. The protection of your personal data is important to us. We therefore conduct our activities in accordance with the applicable legislation on the protection of personal data and data security. We would like to inform you below about which data from your visit is used for which purposes.

last edited: February 2024

Controller for processing in accordance with the GDPR

The controller within the meaning of the General Data Protection Regulation and other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is

SYNTINELS GmbH
Engelstraß3 50
‚Äć48143 M√ľnster
Germany
Phone number: +49 251 50853979
E-mail: privacy@syntinels.com

Data protection officer

The controller within the meaning of the General Data Protection Regulation and other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Sebastian Feldmann
Keyed GmbH
Siemensstraße 12
48341 Altenberge, Westfalen
E-mail: s.feldmann@keyed.de

What is personal data?

The term personal data is defined in the Federal Data Protection Act and the EU GDPR. Accordingly, this is individual information about the personal or factual circumstances of an identified or identifiable natural person. This includes, for example, your civil name, your address, your telephone number or your date of birth.

Scope of anonymous data collection and data processing

Unless otherwise stated in the following sections, no personal data is collected, processed or used when you use our websites. However, through the use of analysis and tracking tools, we obtain certain technical information based on the data transmitted by your browser (e.g. browser type/version, operating system used, websites visited on our site including length of visit, previously visited website). We only evaluate this information for statistical purposes.

Relevant legal bases for the processing of personal data

  1. Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
  2. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b) GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
  3. Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c) GDPR serves as the legal basis.
  4. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d) GDPR serves as the legal basis.
  5. If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f) GDPR serves as the legal basis for the processing.

Cookies

The Internet pages of the SYNTINELS GmbH use cookies. Cookies are data that are stored by the Internet browser on the user's computer system. The cookies can be transmitted to a page when it is called up and thus enable the user to be identified. Cookies help to simplify the use of websites for users.

It is possible to object to the setting of cookies at any time by changing the settings in the Internet browser. Cookies that have been set can be deleted. Please note that if you deactivate cookies, you may not be able to use all the functions of our website to their full extent. The user data collected in this way is pseudonymized by technical precautions. It is therefore no longer possible to assign the data to the accessing user. The data is not stored together with other personal data of the user. When accessing our website, users are informed by an info banner about the use of cookies for analysis purposes and referred to this privacy policy. In this context, there is also a reference to how the storage of cookies can be prevented in the browser settings. The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f) GDPR. The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a) GDPR if the user has given consent to this. To find out whether and to what extent cookies are used on our website, please refer to our cookie banner and our information in this privacy policy.

Use of cookies

SYNTINELS GmbH uses an automated system to collect data and information each time the website is accessed. This data is stored in the server log files. The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

The following data may be collected:

  1. Information about the browser type and version used
  2. The user's operating system
  3. The user's internet service provider
  4. The IP address of the user
  5. Date and time of access
  6. Websites from which the user's system accesses our website (referrer)
  7. Websites that are accessed by the user's system via our website

Duration of storage of personal data

Personal data is stored for the duration of the respective statutory retention period. After this period has expired, the data will be routinely deletion of the data, unless it is necessary for the initiation or fulfillment of a contract.

How to contact us

There is a contact form on the SYNTINELS GmbH website that can be used to contact us electronically. Alternatively, contact can be made via the e-mail address provided. If the data subject contacts the controller via one of these channels, the personal data transmitted by the data subject will be stored automatically. The data is stored solely for the purpose of processing or contacting the data subject. The data is not passed on to third parties. The legal basis for the processing of the data is Art. 6 para. 1 lit. a) GDPR if the user has given consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f) GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b) GDPR. The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is deemed to have ended when it can be inferred from the circumstances that the matter in question is conclusively clarified.

Registration on our website

If the data subject uses the option to register on the controller's website by providing personal data, the data in the respective input mask will be transmitted to the controller. The data is stored exclusively for internal use by the controller. The data is deleted as soon as it is no longer required for the purpose for which it was collected. During registration, the user's IP address and the date and time of registration are stored. This serves to prevent misuse of the services. The data is not passed on to third parties. An exception is made if there is a legal obligation to pass on the data. The registration of data is necessary for the provision of content or services. Registered persons have the option of having the stored data deleted or amended at any time. The data subject can obtain information about their stored personal data at any time.

Routine erasure and blocking of personal data

The controller processes and stores personal data of the data subject only for as long as is necessary to achieve the purpose of storage. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. As soon as the storage purpose no longer applies or a storage period prescribed by the aforementioned regulations expires, the personal data is routinely blocked or deleted.

Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

Right to information pursuant to Art. 15 GDPR

You can request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you can request the following information from the controller:

  1. the purposes for which the personal data are processed
  2. the categories of personal data being processed
  3. the recipients or categories of recipients to whom your personal data have been or will be disclosed
  4. the planned duration of the storage of your personal data or, if specific information on this is not possible, criteria for determining the storage period
  5. the existence of a right to rectification or erasure of your personal data, a right to restriction of processing by the controller or a right to object to such processing
  6. the existence of a right to lodge a complaint with a supervisory authority
  7. all available information about the origin of the data if the personal data is not collected from the data subject
  8. the existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information about whether your personal data is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

Right to rectification pursuant to Art. 16 GDPR

You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must make the rectification without undue delay.

Right to rectification pursuant to Art. 16 GDPR

(1) You have the right to obtain from the controller the erasure of your personal data without undue delay and the controller shall have the obligation to erase this data without undue delay where one of the following grounds applies:

  1. The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  2. You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) GDPR and there is no other legal basis for the processing.
  3. You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
  4. The personal data concerning you has been processed unlawfully.
  5. The deletion of personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
  6. The personal data concerning you have been collected in relation to the offer of information society services referred to in Art. 8 (1) GDPR.

(2) If the controller has made your personal data public and is obliged to erase it pursuant to Art. 17 (1) GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

(3) The right to erasure does not exist if the processing is necessary

  1. for exercising the right of freedom of expression and information
  2. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  3. for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h) and i) and Art. 9 para. 3 GDPR
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in para. 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing 
  5. or for the establishment, exercise or defense of legal claims.

Right to restriction of processing pursuant to Art. 18 GDPR

You may request the restriction of the processing of your personal data under the following conditions

  1. if you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead
  3. the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, or
  4. if you have objected to the processing pursuant to Art. 21 para. 1 GDPR and it is not yet certain whether the legitimate reasons of the controller outweigh your reasons.

If the processing of your personal data has been restricted, this data - apart from its storage - may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

Recht auf Unterrichtung gem. Art. 19 DSGVO

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.

Right to data portability pursuant to Art. 20 GDPR

You have the right to receive your personal data, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

  1. the processing is based on consent pursuant to Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and
  2. the processing is carried out by automated means. In exercising this right, you also have the right to have your personal data transmitted directly from one controller to another, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this. The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right to object pursuant to Art. 21 GDPR

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller will no longer process your personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes. You have the option, in connection with the use of information society services - notwithstanding Directive 2002/58/EC - to exercise your right to object by means of automated procedures that use technical specifications.

Right to revoke the declaration of consent under data protection law pursuant to Art. 7 para. 3 GDPR

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR

Without prejudice to any other administrative or judicial remedy, you 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 if you consider that the processing of your personal data infringes the GDPR. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 77 GDPR.

Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  1. is necessary for the conclusion or performance of a contract between you and the controller
  2. is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  3. with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a) or g) applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in a. and c., the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

Integration of other third-party services and content

Description and purpose

Third-party content, such as videos, fonts or graphics from other websites, may be integrated into this online offering. This always presupposes that the providers of this content (hereinafter referred to as "third-party providers") are aware of the user's IP address. Without the IP address, they would not be able to send the content to the respective user's browser. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. However, we have no influence on whether the third-party providers store the IP address, e.g. for statistical purposes. Insofar as we are aware of this, we will inform users of this. We would like to provide and improve our online offering through these integrations.

Legal basis

The legal basis for the integration of other third-party services and content is Art. 6 para. 1 lit. f) GDPR. Our overriding legitimate interest lies in the intention to present our online presence accordingly and to provide user-friendly and economically efficient services on our part. Further information can be found in the respective data protection information of the providers.

Contractual or legal obligation to provide personal data

The provision of personal data is not required by law or contract and is not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide this data may mean that you will not be able to use this function or will not be able to use it to its full extent.

Data transfer to third countries

The controller may transfer personal data to a third country. In principle, the controller can provide various suitable guarantees to ensure that an adequate level of protection is established for the processing operations. It is possible to transfer data on the basis of an adequacy decision, internal data protection regulations, approved codes of conduct, standard data protection clauses or an approved certification mechanism pursuant to Art. 46 para. 2 lit. a) - f) GDPR.

If the controller carries out a transfer to a third country on the legal basis of Art. 49 para. 1 a) GDPR, you will be informed here about the possible risks of data transfer to a third country.

There is a risk that the third country receiving your personal data may not have an equivalent level of protection compared to the protection of personal data in the European Union. This may be the case, for example, if the EU Commission has not issued an adequacy decision for the respective third country or if certain agreements between the European Union and the respective third country are declared invalid. Specifically, there are risks in some third countries with regard to the effective protection of EU fundamental rights through the use of surveillance laws (e.g. USA). In such a case, it is the responsibility of the controller and the recipient to assess whether the rights of the data subjects in the third country enjoy an equivalent level of protection as in the Union and can also be effectively enforced.
However, the General Data Protection Regulation should not undermine the level of protection of natural persons guaranteed throughout the Union when personal data is transferred from the Union to controllers, processors or other recipients in third countries or to international organizations, even if personal data is transferred from a third country or from an international organization to controllers or processors in the same or another third country or to the same or another international organization.

Further website functionailties

Calendly

Description and purpose

We use Calendly for online appointments. Calendly is an offer from Calendly LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, USA. Calendly is an external platform for arranging appointments. No data is passed on to third parties. The transmission and storage serves only the administration and organization of the appointments.

Legal basis

The legal basis for the transmission of data is Art. 6 para. 1 lit. b) GDPR. The purpose of transmitting the data is to make the appointment to fulfill a support service. The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the appointment account, this is the case when the appointment has been carried out and a support service has been provided in this context and any related queries have been answered. Mandatory statutory provisions, in particular retention periods, remain unaffected. Furthermore, a "Data Processing Addendum" has been concluded with Calendly. This is a contract in which Calendly undertakes to protect users' data, to process it on our behalf in accordance with its data protection provisions and, in particular, not to pass it on to third parties (https://calendly.com/de/pages/dpa).

Recipient

The recipient of the data is Calendly LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, USA Transmission to third countries

Transfer to third countries

The data is transmitted to Calendly's servers in the USA.
The personal data is transmitted on the basis of Art. 46 and/or Art. 49 para. 1 lit. a) GDPR.

Duration of the processing

Information regarding the duration of processing can be found in Calendly's privacy policy: https://calendly.com/pages/privacy

Contractual or legal obligation for the provision of personal data

The provision of personal data is not required by law or contract and is not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide it may mean that you will not be able to use this function of our website or will not be able to use it to its full extent.
Further information on calendly's data security can be found here: https://calendly.com/pages/privacy

Applications (training & job vacancies)

By submitting an application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the type and scope set out in this privacy policy. The legal basis for the processing of applicant data is Art. 88 GDPR, § 26 BDSG-new and Art. 9 para. 2 lit. b) GDPR. Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated as part of the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. b) GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. a) GDPR (e.g. health data if this is necessary for the exercise of the profession). If provided, applicants can send us their applications using an online form on our website.The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We therefore cannot assume any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or sending it by post. Instead of applying via the online form and e-mail, applicants still have the option of sending us their application by post. In the event of a successful application, we may process the data provided by applicants for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion takes place after a period of six months so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the General Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Security

We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to technological progress. In addition, we ensure data protection on an ongoing basis by constantly auditing and optimizing our data protection organization.

Changes & subject to change

SYNTINELS reserves all rights to make changes and updates to this privacy policy. This privacy policy was created by the data protection management system within hellotrust, a brand of Keyed GmbH.