The protection and security of your (hereinafter “User”) personal data within the meaning of Article 4 No. 1 of the General Data Protection Regulation (hereinafter “DSGVO”) (hereinafter “pbD”) are important to us. Accordingly, we comply with the statutory provisions in order to provide the pbD of each user with the appropriate protection. In the following, we would like to inform you about the nature, scope and purpose of the processing of pbD: Reclay Holding GmbH (hereinafter referred to as “Reclay Group” or “we”) processes pbD exclusively within the scope of the DSGVO as well as within the scope of the data protection regulations set out under Art. 95 DSGVO in conjunction with. §§ 11-15a of the German Telemedia Act (“TMG”).

This data protection declaration (hereinafter “DSE”) provides the information pursuant to Art. 13 DSGVO for the use of the website www.reclay-group.com including the subpages. We first explain who the data controller is and who the data protection officer is, then, sorted by types of access in the different areas of the website, the information about the types of pbD, the purposes and legal basis of the processing, any recipients and any legitimate interests, deletion periods and other information, if applicable. To conclude this Privacy Policy, we explain your rights.

 

Contact details of the responsible party (Art. 13 (1) a) DSGVO).
The RECLAY GROUP, Austraße 34, 35745 Herborn, Germany, is responsible for the operation of the website, including all subpages, and for handling the pbD processed in this context.

 

Contact details of the data protection officer (Art. 13 para. 1 lit. b) DSGVO).
Our data protection officer is Mr. Frank Kraus, c/o con eco GmbH, Lindenallee 41, 50968 Cologne, Germany, e-mail address data.de(at)reclay-group.com.

 

Calling up the website, using the search function on the website and downloading documents in the freely accessible area of the website.

• Types of personal data: Each time the website is called up, the search function is used and documents are downloaded from the freely accessible area of the website, the following log files of the respective user are automatically recorded: Information about the browser type and version used, the user’s operating system, the address of the previously visited website (referrer), the user’s IP address, date and time of access.
• Purposes of processing (Art. 13 para. 1 lit. c) DSGVO): The log files are processed in order to ensure the functionality of the website, to enable the download or to serve your search request. In addition, the data is used to ensure the security of the information technology systems on which the website is operated. An evaluation of the data for marketing or other purposes does not take place.
• Legal basis for processing, legitimate interests (Art. 13 para. 1 lit. c) and d) DSGVO): The legal basis for the processing of log file data is Art. 6 (1) (f) DSGVO, i.e. it is the legitimate interests of RECLAY GROUP. These legitimate interests of ours are to be able to provide you with our web offer, including downloads of documents.
• Recipients/third parties/third country transfer (Art. 13 para. 1 lit. e) and f) DSGVO): Data will not be transmitted to third parties (Art. 4 No. 10 DSGVO). All data is processed on computers within the European Union. A transfer to a third country does not take place and is not intended. A transfer of pbD to state institutions and authorities only takes place within the framework of legal regulations.
• Deletion periods (Art. 13 para. 2 lit. a) DSGVO): The data is deleted at the latest when you end your visit to the website, i.e. when you close the browser on your computer. Data on the server (log files) are deleted cyclically every 14 days for technical reasons.

Use of the contact form

Before using the contact form (sending the completed form on the website www.reclay-group.com), the user must consent to the processing of the pbD associated with the use of the contact form in accordance with the following regulations by actively checking a box, otherwise the completed form cannot be sent. For the right to revoke a granted consent at any time, see section 8.

• Types of personal data: Types of data are first name/last name, e-mail, company/institution, message content, technical logging of a declared consent.
• Purposes of processing (Art. 13 para. 1 lit. c) DSGVO): The purpose is to respond to the user’s inquiry, and subsequently, if applicable, to initiate, establish and implement a business relationship, depending on the nature of the inquiry.
• Legal basis for the processing (Art. 13 para. 1 lit. c) DSGVO): The legal basis is Art. 6 para. 1 lit. a) DSGVO, i.e. a declared consent, as well as, depending on the further course of communication, for the initiation and implementation of a business relationship, Art. 6 para. 1 lit. b) DSGVO.
• Recipients/third parties/third country transfer (Art. 13 para. 1 lit. e) and f) DSGVO): User data will not be transferred to third parties (Art. 4 No. 10 DSGVO) unless the user explicitly requests this transfer in his request and the consent also refers to this. All data is processed on computers within the European Union. A transfer to a third country does not take place and is not intended. A transmission of pbD to governmental institutions and authorities will only take place within the framework of legal regulations.
• Deletion periods (Art. 13 para. 2 lit. a) DSGVO): The data will be deleted at the end of three months after the request has been dealt with, unless a different treatment results from the nature of the request (e.g. processing of consultation) or the consent given is revoked earlier. If the inquiry leads to a contractual relationship or prepares such a relationship, the data will be deleted in accordance with the statutory provisions, at the latest three months after the intended contractual or pre-contractual relationship has ended, unless Art. 17 (3) DSGVO intervenes, in particular statutory retention obligations exist and/or the data is required for the assertion, exercise or defense of legal claims or against legal claims.

Contacting us by e-mail via e-mail addresses provided on the website (unless application, cf. section 7).
At various points on the website, we give you the opportunity to contact us directly by e-mail by providing an e-mail address.

• Types of personal data: Types are e-mail address, log files about the characteristics of the e-mail as well as the time of arrival, furthermore all pbD indicated in the e-mail by the sender, for example.
  Purposes of processing (Art. 13(1)(c) GDPR): The purpose is to respond to the user’s inquiry, and subsequently, if applicable, to initiate, establish and implement a business relationship, depending on the nature of the inquiry.
• Legal basis for processing (Art. 13(1)(c) DSGVO): The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) (f) DSGVO, if the sender is not yet a customer or is not already in a business relationship or its initiation with us in another way. If a contractual relationship already exists or is to be initiated by the sender, the legal basis is Art. 6 (1) (b) DSGVO.
• Legitimate interests in the case of processing based on Art. 6 (1) f) DSGVO (Art. 13 (1) d) DSGVO): Our legitimate interests are to inform you and respond to your inquiry, if applicable, to enter into a business relationship with you, if this is part of your request.
• Recipients/third parties/third country transfer (Art. 13(1)(e) and (f) DSGVO): Data is not transmitted to third parties (Art. 4 No. 10 DSGV) unless the user expressly consents, insofar as affiliated companies are concerned. All e-mails are processed on computers within the European Union, there is an agreement with the mail hoster for order processing according to Art. 28 DSGVO. A transfer to a third country does not take place and is not intended. The transfer of pbD to government institutions and authorities only takes place within the framework of legal regulations.
• Deletion periods (Art. 13 para. 2 lit. a) DSGVO): The data will be deleted three months after the request has been processed, unless the nature of the request dictates otherwise (e.g., processing of consultation). If the inquiry leads to a contractual relationship or prepares such a relationship, the data will be deleted in accordance with the statutory provisions when the intended contractual or pre-contractual relationship is terminated, namely three months after its termination, unless Article 17 (3) DSGVO applies, in particular if there are statutory retention obligations and/or the data are required for the assertion, exercise or defense of legal claims or against legal claims.

Transmission of application documents

At www.reclay-group.com, we give you the opportunity to submit your application for a job with us by e-mail.

• Types of personal data: Types are e-mail address incl. logging of the e-mail on our computers as well as all pbD contained in your e-mail concerning your application, e.g. title, surname, first name, details from the CV, certificates and the like.
• Purposes of processing (Art. 13(1)(c) DSGVO): The purpose of the processing is the selection of applicants and the possible establishment of an employment relationship.
• Legal basis for processing (Art. 13 (1) (c) DSGVO): Legal basis is § 26 BDSG (new), possibly Art. 6 para. 1 lit. b) DSGVO (e.g. in case of application for freelance work).
• Recipient/third party/third country transfer (Art. 13 para. 1 lit. e) and f) DSGVO): Data is transmitted to third parties (Art. 4 No. 10 DSGV) if necessary to affiliated companies, otherwise not. All e-mails are processed on computers within the European Union, there is an agreement with the hoster of the e-mails for order processing according to Art. 28 DSGVO. A transfer to a third country does not take place and is not intended. The transfer of pbD to government institutions and authorities only takes place within the framework of legal regulations.
• Deletion periods (Art. 13 para. 2 lit. a) DSGVO): The data will be deleted within three months after completion of the application process (decision on whether or not to consider your application), unless (i) the application was successful and the entire application documents are attached to the personnel file (Section 26 BDSG), (ii) in your capacity as an applicant, you have expressly consented to being included in a talent pool for a certain period of time (after which the data will then be deleted) and/or (iii) Art. 17 (3) DSGVO applies, in particular statutory retention obligations exist and/or the data is required for the assertion, exercise or defense of legal claims or against legal claims.

Newsletter data

To send our newsletter, we need an e-mail address from you. Verification of the e-mail address provided is necessary and you must agree to receive the newsletter. Supplementary data is not collected or is voluntary. The data is used exclusively for sending the newsletter.

The data provided during the newsletter registration will be processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). A revocation of your already given consent is possible at any time. For the revocation, an informal message by e-mail or you unsubscribe via the “unsubscribe” link in the newsletter is sufficient. The legality of the data processing operations already carried out remains unaffected by the revocation.

Data entered to set up the subscription will be deleted in the event of unsubscription. If this data has been transmitted to us for other purposes and elsewhere, it will still remain with us.

Use of cookies and analysis tools
Cookies

RECLAY GROUP uses so-called “cookies”. Cookies are small text files that store website settings, e.g. in the user’s web browser, as part of website use. The cookies are used to make the website easier to use. RECLAY GROUP. only uses so-called session ID cookies. These are stored in the user’s web browser only for the current session and are automatically deleted when the browser is closed. Every user is free to prevent the installation of such cookies by setting his browser accordingly. In this case, however, it may be that not all functions of the website can be fully used.

Google Analytics

We use Google Analytics on our website. This is a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter referred to as “Google”.

Through the certification according to the EU-US Privacy Shield (“EU-US Privacy Shield”)

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google guarantees that the data protection requirements of the EU are also complied with when processing data in the USA.

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

The storage of Google Analytics cookies and the use of this analysis tool are based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its web offering and its advertising.

We have activated the IP anonymization function on this website. This means that your IP address will be shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set, which will prevent the collection of your data during future visits to this website: Disable Google Analytics

For more information on how Google Analytics handles user data, please see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Rights of the user (Art. 13 para. 2 lit. b) – e), Art. 7 para. 3 DSGVO).
If the legal requirements are met, the user has the right to information about pbD that we have stored about him at any time, Art. 15 DSGVO, as well as the right to rectification, Art. 16 DSGVO, restriction of processing, Art. 18 DSGVO, deletion of his data, Art. 17 DSGVO.

If the User has asserted the right to rectification, erasure or restriction of processing against RECLAY GROUP, RECLAY GROUP will communicate this rectification or erasure of the data or restriction of processing to all possible recipients to whom the pbD in question have been disclosed, unless this proves impossible or involves a disproportionate effort.

Likewise, the user has the right to revoke consent once given (Art. 7, Art. 6 para. 1 lit. a) DSGVO), Art. 7 para. 3 DSGVO). The proper revocation of consent does not affect the lawfulness of the data collection carried out up to that point.

In addition, the user has the right to object at any time, on grounds arising from their particular situation, to the processing of pbD relating to them which is carried out on the basis of Art. 6 (1) (e) or (f) DSGVO, Art. 21 DSGVO.

In addition, the user has the right, if the legal requirements are met, to receive his pbD, which he has provided to RECLAY GROUP, in a structured, common and machine-readable format (right of data portability, Art. 20 DSGVO).

For the purpose of exercising these rights, the User shall contact the offices indicated in section 1 or 2.

Furthermore, the user has the right to lodge a complaint with a supervisory authority if the legal requirements are met, Art. 77 DSGVO.