Privacy Declaration
Status November 2022
Table of contents
I. Name and address of the data controller
II. Contact details of the data protection officer
III. General information on data processing
IV. Rights of the data subject
V. Provision of the website and creation of log files
VI. Use of cookies
VII: Newsletter
VIII. Requests by e-mail, telephone or fax
IX. Integration of Google Maps
X. Use of Google Web Fonts
XI. Other company appearances
XII. Data protection information for applicants
I. NAME AND ADRESS OF THE DATA CONTROLLER
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection provisions is the:
Media Services GmbH
Türkenstraße 89
80799 München
Tel.: +49 89 4132578 -1555
E-mail: webmaster(at)pharos.de
Website: www.pharos.de
II. CONTACT DETAILS OF THE DATA PROTECTION OFFICER
The data protection officer of the controller is:
Florian Meigel
Alpenstraße 33
83556 Griesstätt
Tel.: +49 (0) 8039 497 0000
E-mail: datenschutz(at)pharos.de
III. GENERAL INFORMATION ON DATA PROCESSING
1. Scope of the processing of personal data
As a matter of principle, we only process personal data of our users insofar as this is necessary for the provision of a functional website as well as our contents and services. The processing of personal data of our users is regularly only carried out after the consent of the user. An exception applies in those cases in which obtaining prior consent is not possible for actual reasons and the processing of the data is required by legal regulations.
2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) sentence 1 lit. a GDPR serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6 (1) sentence 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 (1) sentence 1 lit. c GDPR serves as the legal basis.
If vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) sentence 1 lit. d GDPR serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) sentence 1 lit. f GDPR serves as the legal basis for the processing.
3. Data deletion and storage period
The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the person responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the standards expires unless there is a necessity for the continued storage of the data for the conclusion or fulfilment of a contract.
IV. 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 towards the controller:
1. Right to information
You may request confirmation from the controller as to whether personal data concerning you are being processed by him.
If there is such processing, you can request the following information from the controller:
• the purposes for which the personal data are processed;
• the categories of personal data which are processed;
• the recipients or categories of recipients to whom the personal data relating to you have been or will be disclosed;
• the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;
• the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
• the existence of a right of appeal to a supervisory authority;
• any available information on the origin of the data if the personal data are not collected from the data subject;
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 of the GDPR in connection with the transfer.
2. Right of rectification
You have a right of rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
3. Right to restriction of the processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
• if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and you refuse the erasure of the personal data and instead request the restriction of the use of the personal data;
• the controller no longer needs the personal data for the purposes of processing, but you need it for the assertion, exercise or defence of legal claims, or
• if you have objected to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller outweigh your grounds.
Where the processing of personal data relating to you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or 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.
4. Right to erasure
a) Obligation to delete
You may request the controller to erase the personal data concerning you without delay and the controller is obliged to erase this data without delay if one of the following reasons applies:
• The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
• You revoke your consent on which the processing was based pursuant to Art. 6 (1) sentence 1 lit. a or Art. 9 (2) lit. a GDPR and there is no other legal basis for the processing.
• You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
• The personal data concerning you have been processed unlawfully.
• The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to, or copies or replications of, that personal data.
c) Exceptions
The right to erasure does not exist insofar as the processing is necessary
• to exercise the right to freedom of expression and information.
• for compliance with a legal obligation which requires processing under 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;
• for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
• for the assertion, exercise or defence of legal claims.
5. Right to be informed
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 against the controller to be informed about these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you that 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 whom the personal data has been provided, provided that
• the processing is based on consent pursuant to Art. 6 (1) sentence 1 lit. a GDPR or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) sentence 1 lit. b GDPR and
• the processing is carried out with the aid of automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons.
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.
7. Right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 (1) sentence 1 lit. e or f GDPR; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, 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 using technical specifications.
8. Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. Automated decision 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
• is necessary for the conclusion or performance of a contract between you and the controller,
• is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests; or
• is done with your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (b) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
Regarding the cases mentioned in 1. and 3. above, the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
10. Right to complain to a supervisory authority
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 residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
The competent supervisory authority for us is:
Bayerisches Landesamt für Datenschutzaufsicht
[Bavarian Data Protection Authority]
Postfach 606
[PO Box 606)
91511 Ansbach
V. PROVISION OF THE WEBSITE AND CREATION OF LOG FILES
1. Description and scope of the data processing
For technical reasons, in particular to ensure a secure and stable internet presence, data is transmitted by your internet browser to us or to our web hoster.
The following data is collected and transmitted:
• Information about the browser type and version used
• The operating system of the user
• The user's Internet service provider
• The IP address of the user
• Date and time of access
• Websites from which the user's system accesses our website
• Websites that are accessed by the user's system via our website
This data is stored temporarily. This data is not stored together with other personal data of the user.
2. Purpose of the data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.
The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
When using these general data and information, the Media Services does not draw any conclusions about the data subject. Rather, this information is required in order to
• to deliver the contents of our website correctly,
• to optimise the content of our website and the advertising for it
• to ensure the long-term functionality of our information technology systems and the technology of our website, and
• to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
Therefore, the Media Services analyzes anonymously collected data and information on one hand for statistical purposes and on the other hand for the purpose of increasing the data protection and data security of our enterprise, and ultimately ensuring an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
3. Legal basis for the data processing
The legal basis for the temporary storage of the data and the log files is Art. 6 (1) p. 1 lit. f GDPR.
4. Storage duration
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is no longer possible.
5. Possibility of objection and removal
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.
VI. USE OF COOKIES
1. Description and scope of the data processing
Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system. When a user calls up a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.
We use technically necessary cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
2. Purpose of the data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.
3. Legal basis for the data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 (1) p. 1 lit. f GDPR.
4. Duration of storage, possibility of objection and elimination
Cookies are stored on the user's computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.
VII. WEB, LICENCE AND PCA SHOP
We offer a web, licence and PCA shop on our website.
2. Purpose of the data processing
The purpose of processing your personal data in the context of the web / licence / PCA shop is to fulfil a contract for the sale of goods or services.
3. Legal basis for the data processing
The legal basis for the processing of data after registration for the newsletter by the user is Art. 6 (1) lit. b GDPR if the user has given his consent.
4. Storage duration
Your personal data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the processing of your personal data within the scope of the web / licence / PCA shop, this is the case when all claims arising from the contractual relationship have become time-barred and there are no longer any legally prescribed retention periods.
5. Possibility of objection and removal
The processing of your personal data within the framework of the web / licence / PCA shop is mandatory for the sale of goods or services. Consequently, there is no possibility for you to object.
VIII. NEWSLETTER
1. Description and scope of the data processing
It is possible to subscribe to a free newsletter. When registering for the newsletter, the following data is transmitted to us from the input mask:
• First name
• Last name
• E-mail address
• Date and time of registration
• IT address of the user
Your consent is obtained for the processing of data during the registration process and reference is made to this data protection declaration.
No data will be passed on to third parties in connection with the data processing for sending newsletters. The data is used exclusively for sending the newsletter.
2. Purpose of the data processing
The collection of the user's email address is used to deliver the newsletter.
3. Legal basis for the data processing
The legal basis for the processing of data after registration for the newsletter by the user is Art. 6 (1) p. 1 lit. a GDPR if the user has given his consent.
The legal basis for sending the newsletter as a result of the sale of goods or services is Art. 7 (3) UWG.
4. Storage duration
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user's email address is therefore stored as long as the subscription to the newsletter is active.
The other personal data collected during the registration process is usually deleted after a period of seven days.
5. Possibility of objection and removal
The subscription to the newsletter can be cancelled by the user concerned at any time. For this purpose, there is a corresponding link in each newsletter.
This also enables revocation of the consent to the storage of the personal data collected during the registration process.
IX. REQUESTS BY E-MAIL, TELEPHONE OR FAX
1. Description and scope of the data processing
On our website you will find our contact details via e-mail, telephone and fax. In this case, the user's personal data transmitted with the contact will be stored.
The data is used exclusively for processing the conversation.
2. Purpose of the data processing
In the event of contact being made, this also constitutes the necessary legitimate interest in processing the data.
3. Legal basis for the data processing
The legal basis for the processing of data is Art. 6 (1) lit. a GDPR if the user has given his or her consent.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) lit. f GDPR.
If the e-mail contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.
4. Storage duration
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. Possibility of objection and removal
The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he or she can object to the storage of his or her personal data at any time. In such a case, the conversation cannot be continued.
Please send us an e-mail to datenschutz(at)pharos.de
All personal data stored in the course of contacting us will be deleted in this case.
IX. INTEGRATION OF GOOGLE MAPS
1. Scope of the processing of personal data
We use the online map service Google Maps of Google Ireland Ltd, Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter referred to as Google). We use the Google Maps plugin to visually display geographical data and embed it on our online presence. By using Google Maps on our online presence, information about the use of our online presence, your IP address and addresses entered in the route planning function are transmitted to a Google server and stored there.
Further information on the processing of data by Google can be found here:
https://policies.google.com/privacy?gl=DE&hl=de
2. Purpose of the data processing
The use of the Google Maps plugin serves to improve user-friendliness and an appealing presentation of our online presence.
3. Legal basis for the processing of personal data
The legal basis for the processing of the users' personal data is, in principle, the user's consent in accordance with Art. 6 (1) sentence 1 lit. a GDPR.
4. Storage duration
Your personal information will be retained for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by law.
5. Possibility of revocation and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
You can prevent the collection as well as the processing of your personal data by Google by preventing third-party cookies from being stored on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/ ) or Ghostery (https://www.ghostery.com ) in your browser.
You can deactivate the use of your personal data by Google using the following link: https://adssettings.google.de.
You can find further information on how to object to and remove Google's use of your personal data at: https://policies.google.com/privacy?gl=DE&hl=de
X. USE OF GOOGLE WEB FONTS
1. Scope of the processing of personal data
We integrate the fonts ("Google Fonts") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
2 Purpose of data processing
On this website, external fonts in the form of Google Fonts are used for the uniform display of fonts. Google Fonts is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; ("Google").
When you access our site, your browser loads the required web fonts directly from a Google server into your browser cache in order to display texts and fonts correctly. This transmits to the server which of our web pages you have visited. The IP address of the browser of the end device of the visitor to these Internet pages is also stored by Google. If your browser does not support web fonts, a standard font from your computer will be used.
3. legal basis for the processing of personal data
The legal basis for the processing of the user's personal data is generally the user's consent in accordance with Art. 6 Para. 1 S.1 lit. a DSGVO.
4. Duration of storage
Your personal information will be stored for as long as necessary to fulfil the purposes described in this privacy policy or as required by law.
5. possibility of revocation and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
You can prevent the collection and processing of your personal data by Google by preventing third-party cookies from being stored on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/ ) or Ghostery (https://www.ghostery.com ) in your browser.
XI. OTHER COMPANY APPEARANCES
Use of company presences in social networks.
Facebook
The purposes and means of processing personal data when visiting our Facebook page https://www.facebook.com/pharosthepostgroup ("Facebook page") are jointly determined by Media Services GmbH, Türkenstraße 89, 80799 Munich ("Media Services") and Facebook Ireland Ltd. ("Facebook") within the meaning of Art. 26 of the EU General Data Protection Regulation (GDPR).
You can find further information in the privacy policy for our Facebook fan page. You can find the link for this on our Facebook page.
Instagram
The purposes and means of processing personal data when visiting our Instagram page https://www.instagram.com/pharos_thepostgroup ("Instagram page") are jointly determined by Media Services GmbH, Türkenstraße 89, 80799 Munich ("Media Services") and Instagram Ireland Ltd ("Instagram") within the meaning of Art. 26 of the EU General Data Protection Regulation (GDPR).
You can find more information in the privacy policy for our Instagram fan page. You can find the link for this on our Instagram page.
LinkedIn
Media Services GmbH uses the technical platform and services of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland for the information service offered on LinkedIn at https://www.linkedin.com/company/pharosthepostgroup.
Further information can be found in the privacy policy for our LinkedIn fan page. You can find the link for this on our LinkedIn page.
Vimeo
We use videos from the company Vimeo on our website. The video portal is operated by Vimeo LLC, 555 West 18th Street, New York, New York 10011, USA. With the help of the plug-in, we can show you interesting video material directly on our website. Certain data may be transferred to Vimeo in the process.
You can find more information on our Vimeo channel: https://vimeo.com/pharosthepostgroup
If you have any questions, please do not hesitate to contact our data protection officer.
XII. DATA PROTECTION INFORMATION FOR APPLICANTS
We are pleased that you are applying or have applied for a position in our company. Below we inform you about the processing of your personal data as part of the application process.
Data collection
In the course of your application, we will process the application data listed below:
First name, surname
Telephone number (private or mobile)
e-mail address
Application documents (cover letter, CV, references, certificates, etc.)
Purpose of data collection and legal basis
We process the data that you have sent us in connection with your application in order to fill vacancies within our company. Your data will only be forwarded to the persons and specialist departments responsible for the application process. Your application data will not be used for any other purpose or passed on to third parties.
The application data may be processed for statistical purposes (e.g. reporting). It is not possible to draw conclusions about individual persons.
According to Section 26 BDSG-new, the processing of personal data required in connection with the decision on the establishment of an employment relationship is permitted. Should the data be required for legal prosecution after completion of the application process, data processing may be carried out in accordance with Art. 6 GDPR, in particular to safeguard legitimate interests in accordance with Art. 6 para. 1 lit. f) GDPR. Our interest then lies, for example, in the assertion of or defense against claims.
Finally, we process your data for further application procedures if you have given us your consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.
Retention period of the applicant data
Your application data will be deleted six months after completion of the application process. This does not apply if legal provisions prevent deletion, if further storage is necessary for the purpose of providing evidence or if you have consented to longer storage.
Storage for future jobs
If you agree to the storage of your application data beyond the current vacancy, we will continue to store your application data for future vacancies. In this case, we will delete your data after 24 months.
Place of data processing
The processing of your data takes place in the Federal Republic of Germany and in a member state of the European Union (EU). We have concluded a contract (Data Processing Addendum) with our subcontractor AWS, which ensures that the data processing is carried out in a permissible manner.
Cookies on the job portal server
As part of the applicant management function in HRworks, three essential cookies are set on the job portal server when the function is used.
The "HrwJobApplicationmanagementSession" cookie represents the session of the person on the job portal. This is necessary for operation, as the users of the session can be distinguished accordingly.
In addition, there are two AWS cookies ("AWSALB" and "AWSALBCORS"), which are required to assign any information to the correct instance of the server. Furthermore, they are necessary for uploading the application documents so that this process can be guaranteed smoothly for the applicants.