Declaration of Data Protection

Privacy policy by reCIRCLE AG

1. What is this privacy policy about?

2. Who is responsible for processing your data?

3. What data do we process?

4. For what purposes do we process your data?

5. On what basis do we process your data?

6. What applies to profiling and automated individual decisions?

7. Who do we disclose your data to?

8. Does your personal data also end up abroad?

9. How long do we process your data?

10. How do we protect your data?

11. What rights do you have?

12. Do we use online tracking and online advertising techniques?

13. What data do we process on our social network pages?

14. Can this privacy policy be changed?

 

1. What is this privacy policy about?

reCIRCLE AG (hereinafter also “we“, “us“) obtains and processes personal data relating to you or also to other persons (so-called “third parties“). We use the term “data” here synonymously with “personal data“.

In this Privacy Policy, we describe what we do with your information when you use recircle.ch and the reCIRCLE APP (collectively, the “Website“), obtain our services or products, otherwise interact with us under a contract, communicate with us or otherwise deal with us. Where applicable, we will provide you with timely written notice of additional processing activities not mentioned in this Privacy Policy.

If you transmit or disclose data about other persons such as family members, work colleagues, etc., we assume that you are authorised to do so and that this data is correct. By submitting data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.

This privacy statement is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”), the Swiss Data Protection Act (“DSG”) and the revised Swiss Data Protection Act (“revDSG“). However, whether and to what extent these laws are applicable depends on the individual case.

2. Who is responsible for processing your data?

In terms of data protection, reCIRCLE AG, Bern (reCIRCLE), is responsible for the data processing by reCIRCLE AG described in this data protection declaration, unless otherwise communicated in individual cases, e.g. in further data protection declarations, on forms or in contracts .

You can contact us for your data protection concerns and to exercise your rights in accordance with paragraph 11, you can reach us as follows:

reCIRCLE AG
Greyerzstrasse 70
CH-3013 Bern

info@recircle.ch

3. What data do we process?

We process different categories of data about you. The main categories are as follows:

• Technical data: When you use our website or other electronic offerings (e.g. WLAN), we collect the IP address of your end device and other technical data to ensure the functionality and security of these offerings. This data also includes logs in which the use of our systems is recorded. In order to ensure the functionality of these offers, we may also assign an individual code to you or your end device (e.g. in the form of a cookie, cf. 12). The technical data in itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they can be linked to other data categories (and thus possibly to your person). Technical data includes, among other things, the IP address and details of the operating system of your terminal device, the date, region and time of use and the type of browser you use to access our electronic offerings. This can help us to communicate the correct formatting of the website. Based on the IP address, we know which provider you use to access our offers (and therefore also the region), but we cannot usually deduce who you are. This changes when you create a user account, for example, because personal data can then be linked to technical data (e.g. we can see which browser you use to access an account via our website). Examples of technical data also include logs that occur in our systems (e.g. the log of user logins on our website).
• Registration data: Certain offers, e.g. of competitions and services (e.g. login areas of our website, newsletter dispatch) can only be used with a user account or registration, which can take place directly with us or via our external login service providers. In doing so, you must provide us with certain data and we collect data about the use of the offer or service. If we issue you with a voucher for one of our partners, we may transmit or receive certain of your registration data to the respective contractual partner (cf. para. 7). Access controls to certain facilities may generate registration data; depending on the control system, biometric data may also be generated. We generally retain registration data for 12 months after the end of the use of the service or the termination of the user account. Registration data includes, among other things, the information you provide when you create an account on our website (e.g. user name, password, name, e-mail). However, registration data also includes the data we may require from you before you can use certain free services such as our Wi-Fi service, in which case: name, email and telephone number; or redeem vouchers, in which case: name, address, contact details, time of redemption. You also need to register if you want to subscribe to our newsletter.
• Communication data: If you are in contact with us via the contact form, by e-mail, telephone or chat, by letter or via other means of communication, we collect the data exchanged between you and us, including your contact details and the marginal data of the communication. If we record or listen to telephone conversations or video conferences, e.g. for training and quality assurance purposes, we will specifically draw your attention to this. Such recordings may only be made and used in accordance with our internal guidelines. You will be informed if and when such recordings take place, e.g. by a display during the video conference in question. If you do not wish to be recorded, please inform us or end your participation. If you simply do not want your image to be recorded, please turn off your camera. If we want or need to establish your identity, e.g. in the case of a request for information submitted by you, a request for media access, etc., we collect data to identify you (e.g. a copy of an ID card). We usually keep this data for 12 months from the last exchange with you. This period may be longer where this is necessary for reasons of proof or to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years. Recordings of (video) conferences are generally kept for 24 months. Chats are usually kept for 2 years. Communication data is your name and contact details, the way and place and time of communication and usually also its content (i.e. the content of e-mails, letters, chats, etc.). This data may also include details of third parties. For identification purposes, we may also process your ID number or a password set by you or your press card. For secure identification, the following mandatory information must be provided for media enquiries: Publisher, name of publication, title, first name, last name, postal address, e-mail address and telephone number of the reporting person.
• Master data: Master data is the basic data we need, in addition to contractual data (see below), to process our contractual and other business relationships or for marketing and promotional purposes, such as name, contact details and information about, for example, your role and function, your bank account(s), customer history, powers of attorney, signature authorisations and consent forms. We process your master data if you are a customer or other business contact or are working for one (e.g. as a contact person of the business partner), or because we want to address you for our own purposes or the purposes of a contractual partner (e.g. as part of marketing and advertising, with invitations to events, with vouchers, with newsletters etc.). We receive master data from you (e.g. when making a purchase or as part of a registration), from bodies for which you work or from third parties such as our contractual partners, associations and address dealers and from publicly accessible sources such as public registers or the Internet (websites, social media etc.). We generally keep this data for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. For pure marketing and advertising contacts, the period is usually much shorter, usually no more than 2 years since the last contact. Master data includes, for example, data such as name, address, email address, telephone number and other contact details, gender, date of birth, nationality, details of associated persons, websites, social media profiles, photos and videos, copies of ID cards; also details of your relationship with us (customer, supplier, visitor, service recipient etc.), details of your status with us (customer, supplier, visitor, service recipient etc.).), details of your status with us, allocations, classifications and distribution lists, details of our interactions with you (if applicable, a history of these with corresponding entries), reports (e.g. from the media) or official documents (e.g. excerpts from the commercial register, authorisations etc.) which concern you. As payment information, we collect e.g. your bank details, account number and credit card data. Consent or blocking notices are also part of the master data, as are details about third parties, e.g. contact persons, recipients of services, advertising recipients or representatives. In the case of contact persons and representatives of our customers, suppliers and partners, we process as master data e.g. name and address, information on role, function in the company, qualifications and, if applicable, information on superiors, employees and subordinates and information on interactions with these persons. Master data is not collected comprehensively for all contacts. Which data we collect in detail depends in particular on the purpose of the processing.
• Contract data: This is data that arises in connection with the conclusion or processing of a contract, e.g. information about contracts and the services to be provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information about reactions (e.g. complaints or information about satisfaction, etc.). We generally collect this data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third party sources (e.g. providers of creditworthiness data) and from publicly accessible sources. We generally keep this data for 10 years from the last contractual activity, but at least from the end of the contract. This period may be longer if this is necessary for reasons of evidence or to comply with legal or contractual requirements or for technical reasons.
• Behavioural and preference data: Depending on our relationship with you, we try to get to know you and better tailor our products, services and offers to you. To do this, we collect and use data about your behaviour and preferences. We do this by evaluating information about your behaviour in our area, and we may also supplement this information with information from third parties, including publicly available sources. Based on this, we can calculate, for example, the probability that you will use certain services or behave in a certain way. Some of the data processed for this purpose is already known to us (e.g. when you use our services), or we obtain this data by recording your behaviour (e.g. how you navigate on our website). We anonymise or delete this data when it is no longer meaningful for the purposes pursued, which may be between 2-3 and 24 months (for product and service preferences) depending on the nature of the data. This period may be longer where necessary for evidential purposes or to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in para. 12.
• Other data: We also collect data from you in other situations. In connection with official or judicial proceedings, for example, data is collected (such as files, evidence, etc.) which may also relate to you. We may also collect data for health protection reasons (e.g. in the context of protection concepts). We may obtain or make photographs, videos and sound recordings in which you may be identifiable (e.g. at events, through security cameras etc.). We may also collect data on who enters certain buildings or has corresponding access rights and when (incl. in the case of access controls, based on registration data or visitor lists, etc.), who participates in events or campaigns (e.g. competitions) and when, or who uses our infrastructure and systems. The retention period of this data depends on the purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras and usually a few weeks for contact tracing data, to visitor data that is usually kept for 3 months, to reports on events with pictures that can be kept for a few years or longer.

Many of the measures described in paragraph 3, are disclose to us by you (e.g. via forms, in the course of communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, subject to individual cases, e.g. within the framework of binding protection concepts (legal obligations). If you wish to conclude contracts with us or claim services, you must also provide us with data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you will need to provide us with registration data. However, in the case of behavioural and preference data, you generally have the option of objecting or not giving consent.

Unless this is inadmissible, we also take data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, the media or the internet incl. social media) or receive data from other companies within our group, from public authorities and from other third parties (such as credit agencies, address dealers, associations, contractual partners, internet analysis services etc.).

4. For what purposes do we process your data?

We process your data for the purposes we explain below. Further information for the online area can be found in paragraph 12 and 13. These purposes or the underlying objectives represent legitimate interests of us and, if applicable, of third parties. You will find further information on the legal basis for our processing in section 5. 5.

We process your data for purposes related to communication with you, in particular to respond to enquiries and to assert your rights (para. 11) and to contact you in the event of queries. For this purpose, we use in particular communication data and master data and, in connection with offers and services used by you, also registration data. We retain this data to document our communication with you, for training purposes, for quality assurance and for follow-up enquiries.

We process data for the purpose of establishing, managing and processing contractual relationships.

We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalised advertising on products and services from us and from third parties (e.g. from advertising contractual partners). This may take the form of e.g. newsletters and other regular contacts (electronically, by post, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, competitions etc.) and may also include free benefits (e.g. invitations, vouchers etc.). You can refuse such contacts at any time (see at the end of this section 4) and refuse or revoke your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the internet more specifically to you (see section 12). Finally, we also want to enable our contractual partners to contact our customers and other contractual partners for advertising purposes (see section 7).

Relationship management also includes addressing existing customers and their contacts – possibly personalised on the basis of behavioural and preference data. In the context of relationship management, we may also operate a customer relationship management system (“CRM”) in which we store the data on customers, suppliers and other business partners necessary for the relationship management, e.g. on contact persons, on the relationship history (e.g. on products and services purchased or supplied, interactions, etc.), interests, wishes, marketing measures (newsletters, invitations to events, etc.) and other information.

We continue to process your data for market research, to improve our services and operations and for product development.

We may also process your data for security and access control purposes.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations (“Compliance“).

We also process data for the purposes of our risk management and as part of prudent corporate governance, including operational organisation and corporate development.

We may process your data for other purposes, e.g. as part of our internal processes and administration or for training and quality assurance purposes.

 

5. On what basis do we process your data?

Insofar as we ask for your consent for certain processing (e.g. for the processing of particularly sensitive personal data, for marketing mailings, for the creation of personalised movement profiles and for advertising control and behavioural analysis on the website), we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time with future effect by written notification (by post) or, where not otherwise stated or agreed, by e-mail to us; you will find our contact details in para. 2. For the revocation of your consent for online tracking, see para. 12. Where you have a user account, revocation or contacting us may also be possible via the relevant website or other service. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purposes to which you originally consented unless we have another legal basis for doing so. The revocation of your consent will not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Where we do not ask for your consent to process your personal data, we base the processing of your personal data on the fact that the processing is necessary for the initiation or performance of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, in particular in order to fulfil the obligations set out in section 4 above. 4 and related objectives described above and to be able to take appropriate action. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognised as a legal basis by the respective applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and in Switzerland). However, this also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including operations, safely and efficiently.

6. What applies to profiling and automated individual decisions?

We may add certain of your personal attributes to those listed in para. 4 using your data for the purposes set out in section 4. 3) (“profiling”), if we want to determine preference data , but also to determine abuse and security risks, to carry out statistical evaluations or for operational planning purposes. For the same purposes, we can also create profiles, i.e. we can combine behavioural and preference data, but also master and contract data and technical data assigned to you, in order to better understand you as a person with your different interests and other characteristics.

In these cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. If these can have legal effects or significant disadvantages for you, we generally provide for a manual review.

7. Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise in order to protect our legitimate interests and the other interests set out in section 4. 4 we also transfer your personal data to third parties, in particular to the following categories of recipients:

• Service providers: We work with service providers in Switzerland and abroad who process data about you on our behalf or in joint responsibility with us or who receive data about you from us in their own responsibility (e.g. IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit agencies or address checkers). For information on the service providers used for the website, see section 12. Microsoft is our central IT service provider. In order to provide our products and services efficiently and to be able to concentrate on our core competencies, we procure services from third parties in numerous areas. These services relate, for example, to IT services, the dispatch of information, marketing, sales, communication or printing services, facility management, security and cleaning, the organisation and holding of events and receptions, debt collection, credit agencies, address checkers (e.g. for updating address lists in the event of relocations), anti-fraud measures and services from consulting firms, lawyers, banks, insurers and telecoms companies. We disclose to these service providers in each case the data required for their services, which may also concern you. These service providers may also use such data for their own purposes, e.g. information on outstanding debts and your payment history in the case of credit agencies or anonymised data to improve services. In addition, we enter into contracts with these service providers that include provisions for the protection of data where such protection does not arise from the law. Our service providers may also process data on how their services are used and other data that arise in the course of using their services as independent data controllers for their own legitimate interests (e.g. for statistical evaluations or billing). Service providers provide information about their independent data processing in their own data protection statements. More information on how Microsoft processes data can be found here: https://privacy.microsoft.com/de-de/privacystatement; for the use of Microsoft Teams in particular here https://docs.microsoft.com/de-de/microsoftteams/teams-privacy.
• Contractual partners including clients: This initially refers to our customers (e.g. service recipients) and other contractual partners, because this data transfer results from these contracts. For example, they receive registration data on issued and redeemed vouchers, invitations, etc. If you work for such a contractual partner yourself, we may also transfer data about you to them in this context. The recipients also include contractual partners with whom we cooperate or who advertise on our behalf and to whom we therefore transmit data about you for analysis and marketing purposes (these may again be service recipients, but also e.g. sponsors and providers of online advertising). We require these partners to only send you advertising or play it out based on your data if you have consented to this (for the online area, cf. para. 12).
• Authorities: We may disclose personal data to offices, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. This may also include health data. The authorities process data about you that they receive from us on their own responsibility.
• Other persons: This refers to other cases where the inclusion of third parties arises from the purposes set out in paragraph 4g. service recipients, media and associations in which we participate or if you are part of one of our publications.

All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).

We also allow certain third parties to collect personal data from you on our website and at events organised by us (e.g. media photographers, providers of tools that we have embedded on our website, etc.). Insofar as we are not decisively involved in these data collections, these third parties are solely responsible for them. If you have any concerns or wish to assert your data protection rights, please contact these third parties directly. see paragraph 12 for the website.

8. Does your personal data also end up abroad?

As described in paragraph 7 we also disclose data to other bodies. These are not only located in Switzerland. Your data can therefore be processed both in Europe; but in exceptional cases in any country in the world.

If a recipient is located in a country without adequate legal data protection, we contractually oblige the recipient to comply with the applicable data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj? ), insofar as it is not already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have given your consent or if it concerns data made generally accessible by you, the processing of which you have not objected to. Please also note that data exchanged via the Internet is often routed via third countries. Your data may therefore end up abroad even if the sender and recipient are in the same country.

9. How long do we process your data?

We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically necessary. Further information on the respective storage and processing duration can be found under the individual data categories in section 3.  3 or for the cookie categories in paragraph 12. If there are no legal or contractual obligations to the contrary, we will delete or anonymise your data after the storage or processing period has expired as part of our normal processes.

10. How do we protect your data?

We take reasonable security measures to maintain the confidentiality, integrity and availability of your personal data, to protect it against unauthorised or unlawful processing and to protect against the risks of loss, accidental alteration, unauthorised disclosure or access.

11. What rights do you have?

Applicable data protection law grants you the right to object to the processing of your data in certain circumstances, in particular for direct marketing, direct marketing profiling and other legitimate processing interests.

To help you control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

• The right to request information from us as to whether and which of your data we are processing;
• the right to have us correct data if it is inaccurate;
• the right to request the deletion of data;
• the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
• the right to withdraw consent insofar as our processing is based on your consent;
• the right to obtain, on request, further information necessary for the exercise of these rights;

If you wish to exercise any of the above rights against us (or against any of our group companies), please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; our contact details are set out in clause 2. In order for us to be able to exclude misuse, we must identify you (e.g. with a copy of your identity card, if this is not otherwise possible).

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (e.g. to protect third parties or trade secrets). We will inform you accordingly if necessary.

If you do not agree with our handling of your rights or data protection, please let us know (paragraph 2). In particular, if you are in the EEA, the United Kingdom or Switzerland, you also have the right to complain to the data protection supervisory authority in your country.

12. Do we use online tracking and online advertising techniques?

We use various techniques on our website which enable us and third parties engaged by us to recognise you when you use our website and, in some circumstances, to track you across multiple visits. We inform you about this in this section.

In essence, this is so that we can distinguish accesses by you (via your system) from accesses by other users, so that we can ensure the functionality of the website and carry out evaluations and personalisations. In doing so, we do not want to infer your identity, even if we can do so insofar as we or third parties engaged by us can identify you through a combination with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of the third parties) assigning you or your browser a specific identification number (so-called “cookie”).

We use such techniques on our website and allow certain third parties to do so as well. You can program your browser to block, deceive or delete existing cookies from certain cookies or alternative techniques. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword “data protection”) or on the websites of the third parties that we list below.

A distinction is made between the following cookies (techniques with comparable functions such as fingerprinting are included here):

• Necessary cookies: Some cookies are necessary for the website to function as such or for certain functions. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary (“session cookies”). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one session (i.e. one visit to the website) if you use this function (e.g. language selected, consent given, the function for automatic login etc.). These cookies have an expiry date of up to 24 months.
• Performance cookies: In order to optimise our website and corresponding offers and to better adapt them to the needs of users, we use cookies to record and analyse the use of our website, possibly even beyond the session. We do this through the use of third-party analytics services. We have listed these below. Performance cookies also have an expiry date of up to 24 Details can be found on the websites of the third-party providers.

We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set on your computer for advertising purposes):

• Google Analytics: Google Ireland (based in Ireland) is the provider of the “Google Analytics” service and acts as our order processor. Google Ireland relies on Google LLC (based in the USA) as its order processor (both “Google“). Google uses performance cookies (see above) to track the behaviour of visitors to our website (duration, frequency of pages viewed, geographical origin of access, etc.) and compiles reports for us on the use of our website on this basis. We have configured the service in such a way that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the USA and thus cannot be traced. We have switched off the “Data sharing” and “Signals” settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these individuals. If you consent to the use of Google Analytics, you explicitly agree to such processing, which also includes the transfer of personal data (in particular usage data for the website and app, device information and individual IDs) to the USA and other countries. Information on the data protection of Google Analytics can be found here [https://support.google.com/analytics/answer/6004245] and if you have a Google account, you can find further details on processing by Google here [https://policies.google.com/technologies/partner-sites?hl=de].
• This website uses Google Maps API to visually display geographical information. When using Google Maps, Google also collects, processes and uses data about visitors’ use of the map functions. You can find more information about data processing by Google in the Google privacy policy. There you can also change your personal data protection settings in the data protection centre.
• Embedded YouTube videos: We embed YouTube videos on some of our websites. The operator of the corresponding plugins is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. When you visit a page with the YouTube plugin, a connection to YouTube servers is established. This tells Youtube which pages you are visiting. If you are logged into your YouTube account, YouTube can assign your surfing behaviour to you personally. You can prevent this by logging out of your Youtube account first. If a Youtube video is started, the provider uses cookies that collect information about user behaviour. If you have deactivated the saving of cookies for the Google Ad programme, you will not have to expect such cookies when watching Youtube videos. However, Youtube also stores non-personal usage information in other cookies. If you wish to prevent this, you must block the storage of cookies in your browser. Further information on data protection at “Youtube” can be found in the provider’s data protection statement at: https://www.google.de/intl/de/policies/privacy/
• Google AdWords: Our website uses Google conversion tracking. If you have reached our website via an ad placed by Google, a cookie is set on your computer by Google Adwords. The conversion tracking cookie is set when a user clicks on an ad placed by Google. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of our website and the cookie has not yet expired, we and Google can recognise that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies can therefore not be tracked across AdWords customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. The customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in the tracking, you can reject the setting of a cookie required for this – for example, by means of a browser setting that generally deactivates the automatic setting of cookies or by setting your browser in such a way that cookies from the domain “googleleadservices.com” are blocked. Please note that you may not delete the opt-out cookies as long as you do not want any measurement data to be recorded. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again.
• Google Fonts: We use third-party services to embed selected fonts as well as icons, logos and symbols on our website. In particular, we use: Google Fonts: Fonts; Provider: Google; Google Fonts-specific information: “Privacy and Google Fonts” (“Privacy and Google Fonts”), “Privacy and Data Collection”.

13. What data do we process on our social network pages?

We may operate pages and other online presences (“fan pages”, “channels”, “profiles”, etc.) on social networks and other platforms operated by third parties and use the services described in section 3. 3 and hereinafter described data about you. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g. on your behaviour and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalise advertising) and to control their platforms (e.g. which content they show you).

We process this data for the purposes described in paragraph 4 in particular for communication, for marketing purposes (including advertising on these platforms, cf. 12) and for market research. You will find information on the relevant legal basis in section 5. 5. Content published by you yourself (e.g. comments on an announcement) may be disseminated by us (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the usage guidelines (e.g. inappropriate comments).

For further information on the processing of the platform operators, please refer to the data protection notices of the platforms. There you will also find out in which countries they process your data, which rights of access, deletion and other data subjects you have and how you can exercise these or obtain further information. We currently use the following platforms:

• Facebook: Here we operate the page https://www.facebook.com/reCIRCLEnow. The responsible body for operating the platform for users from Europe is Facebook Ireland Ltd, Dublin, Ireland. Their data protection information can be found at www.facebook.com/policy. Some of your data will be transferred to the USA. You can object to advertising here: www.facebook.com/settings?tab=ads. With regard to the data collected and processed when visiting our site for the creation of “Page Insights”, we are jointly responsible with Facebook Ireland Ltd, Dublin, Ireland. As part of Page Insights, statistics are compiled about what visitors do on our site (comment on posts, share content, etc.). This is described at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us understand how our site is used and how we can improve it. We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information on www.facebook.com/legal/terms/page_controller_addendum.
• Instagram: Here we operate the page https://www.instagram.com/recirclenow/. The responsible body for operating the platform for users from Europe is Facebook Ireland Ltd, Dublin, Ireland. Their data protection information can be found at https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect. Some of your data will be transferred to the USA. You can object to advertising here: www.facebook.com/settings?tab=ads. With regard to the data collected and processed when visiting our site for the creation of “Page Insights”, we are jointly responsible with Facebook Ireland Ltd, Dublin, Ireland. As part of Page Insights, statistics are compiled about what visitors do on our site (comment on posts, forward content, etc.). We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information on www.facebook.com/legal/terms/page_controller_addendum. In what way Instagram uses the data from the visit of Instagram pages for its own purposes, to what extent activities on the Instagram page are assigned to individual users, how long Instagram stores this data and whether data from a visit to the Instagram page is passed on to third parties, is not conclusively and clearly stated by Instagram and is not known to us. When you access an Instagram page, the IP address assigned to your end device is transmitted to Instagram. According to Instagram, this IP address is anonymised (for “German” IP addresses) and deleted after 90 days. Instagram also stores information about its users’ end devices (for example, as part of the “login notification” function); this may enable Instagram to assign IP addresses to individual users. If you are currently logged in to Instagram as a user, there is a cookie with your Instagram ID on your end device. This enables Instagram to track that you have visited this page and how you have used it. This also applies to all other Instagram pages. Via Instagram buttons embedded in websites, it is possible for Instagram to record your visits to these website pages and assign them to your Instagram profile. Based on this data, content or advertising can be offered tailored to you. If you want to avoid this, you should log out of Instagram or deactivate the “stay logged in” function, delete the cookies on your device and close and restart your browser. This will delete Instagram information that can directly identify you. This allows you to use our Instagram page without revealing your Instagram identifier. When you access interactive features of the site (like, comment, message and more), an Instagram login screen will appear. After any login, you will again be recognisable to Instagram as a specific user.
• Linkedin: Instagram: Here we operate the page https://www.linkedin.com/company/recirclenow/mycompany/ The responsible authority for the operation of this platform is: LinkedIn Ireland Unlimited Community, Wilton Place, Dublin 2, Ireland, back. We would like to point out that you use this LinkedIn page and its functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. commenting or rating). You can find information about which data is processed by LinkedIn and for what purposes in the LinkedIn data protection declaration: https://www.linkedin.com/legal/privacy-policy When you visit our LinkedIn company page, LinkedIn collects, among other things, your IP address and other information that is present on your PC in the form of cookies. This information is used to provide us, as operators of the LinkedIn pages, with statistical information about the use of the LinkedIn page. The data collected about you in this context is processed by the LinkedIn Ireland Unlimited Community and, where applicable, transferred to countries outside the European Union in the process (https://www.linkedin.com/help/linkedin/answer/62533). LinkedIn describes in general terms what information it receives and how it is used in its privacy policy. There you will also find information on how to contact LinkedIn. In what way LinkedIn uses the data from visits to LinkedIn pages for its own purposes, to what extent activities on the LinkedIn page are assigned to individual users, how long LinkedIn stores this data and whether data from a visit to the LinkedIn page is passed on to third parties, is not conclusively and clearly stated by LinkedIn and is not known to us. As the provider of a LinkedIn company page, we do not collect or process any data from your use of our service.

14. Can this privacy policy be changed?

This Privacy Policy does not form part of any contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated: 30.08.2023