7p-mobility.com/ (hereinafter referred to as the “Website”).
We consider data protection to be extremely important. Your personal data is collected and processed in compliance with the applicable data protection regulations, in particular, the General Data Protection Regulation (GDPR).
1 Data Controler
The data controller, who is responsible for the collection, processing and use of your personal data within the meaning of Art. 4 para. 7 GDPR, is
Seven Principles Mobility GmbH
If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations either as a whole or for individual measures, you can address your objection to the data controller.
2 General purposes of the processing
We use personal data for the purpose of operating the website, to process your enquiries in a business context, and to improve our web offering.
3 Which data we use and why
The hosting services we avail of are used to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating the Website.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, metadata and communication data of customers, potential customers and visitors to this Website on the basis of our legitimate interests in the efficient and secure provision of this Website according to Art. 6 para. 1 clause 1 f) GDPR in conjunction with Art. 28 GDPR.
3.2 Access data
We collect information about you when you use this Website. We automatically collect information about your usage behaviour and your interaction with us and record data about your computer or mobile device. We collect, store and use data about every instance of access to our Website (so-called server log files). The access data includes:
- Name and URL of the file(s) you retrieve/access
- Date and time of the access
- Data volume transferred
- Message about successful retrieval (HTTP response code)
- Browser type and version
- Operating system
- Referrer URL (i.e. the previously visited page)
- The websites that are accessed by the user’s system via our Website
- The user’s internet service provider
- The IP address and requesting provider
We use this log data without allocation to your person or other profiling for statistical evaluations for the purpose of operating, security and optimisation of our website, but also for anonymous recording of the number of visitors to our website (traffic) and the extent and type of use of our website and services, as well as for billing purposes in order to measure the number of clicks received from cooperation partners. This information enables us to provide personalised and location-based content, to analyse traffic, to detect and correct errors, and to improve our services.
We also have a legitimate interest in this pursuant to Art 6. para. 1 clause 1 f) GDPR.
We reserve the right to subsequently check the log data if, based on concrete indications or evidence, there is a justified suspicion of unlawful use. We also store IP addresses if we have reason to suspect that a criminal offence has been committed in connection with the use of our Website.
We use so-called session cookies to optimise our Website. A session cookie is a small text file that is sent by the server in question when you visit a website, and which is temporarily stored on your hard drive. This session cookie file stores a session ID, which makes it possible to track the various requests made by your browser during the joint session. This allows your computer to be recognised when you return to our Website. These cookies are deleted after you close your browser. They serve, e.g., to prevent the cookie banner from being displayed repeatedly.
To a small extent, we also use persistent cookies (another type of small text file that is stored on your device), which remain on your device and enable us to recognise your browser the next time you visit our Website. These cookies are stored on your hard disk and are deleted automatically after a specified time. Their life span is between 1 month and 10 years. These cookies enable us to present our offering in a more user-friendly, effective and secure manner and, for example, to display information on the site that is specifically tailored to your interests.
The following data and information is stored in the cookies:
- Login information
- Language settings
- Search terms entered
- Information about the number of visits to our Website and use of individual features on our Website.
When a cookie is activated, it is assigned an identification number, but your personal data will not be mapped to this identification number. Your name, IP address or similar data that would allow the cookie to be traced to you does not get placed in the cookie. Based on the cookie technology, we only receive pseudonymised information.
You can set your browser so that you are informed in advance about cookies being set and can decide in individual cases whether you want to exclude cookies from being accepted in specific cases or in general, or can prevent cookies entirely. However, this may restrict the functionality of the Website.
3.4 Cookie banner
3.5 Data in order for us to fulfil our contractual obligations
We process personal data that we need in order to fulfil our contractual obligations, such as name, address, email address, ordered products, and billing and payment data. This data needs to be collected in order to conclude the contract.
The data will be deleted after expiry of the warranty periods and statutory retention periods. Data that is associated with a user account (see below) will always be retained for the duration the account is maintained for.
The legal basis for the processing of this data is Art. 6 para. 1 clause 1 b) GDPR, because this data is required in order for use to be able to fulfil our contractual obligations to you.
3.6 Contacting us
If you contact us (e.g., via our contact form or email), we will process your details in order to handle your enquiry and in the event that any follow-up questions arise.
If the data processing takes place in order to execute pre-contractual measures that are taking place at your request or, if you are already a customer of ours, in order to execute the contract between us, then the legal basis for this data processing is Art. 6 para. 1 clause 1 b) GDPR.
We will only process further personal data if you give your consent to this (Art. 6 para. 1 clause 1 a) GDFPR) or we have a legitimate interest in the processing of your data (Art. 6 para. 1 clause 1 f) GDPR). There is a legitimate interest, for example, in replying to your email. Consent given can be revoked at any time, with effect for the future.
4 Data protection information for applicants
Various media are used by SEVEN PRINCIPLES AG as part of employee recruiting.
In addition to postal applications, these can also be sent by e-mail, via the SEVEN PRINCIPLES AG website (online application), application portals and commissioned recruiting companies.
We process the data that you have sent us in connection with your application in order to check your suitability for the position (or other open positions in our company, if applicable) and to carry out the application process.
On what legal basis is that?
The legal basis for the processing of your personal data in this application process is primarily Section 26 BDSG in the version applicable from May 25, 2018. Thereafter, the processing of the data is permitted that is necessary in connection with the decision on the establishment of an employment relationship.
Should the data be required for legal prosecution after the application process has been completed, data processing can be carried out on the basis of the requirements of Art. 6 GDPR, in particular to safeguard legitimate interests according to Art. 6 Para. 1 clause 1f) GDPR. Our interest then lies in the assertion or defense of claims.
How long will the data be stored?
Applicants’ data will be deleted after 6 months in the event of rejection.
If you have consented to your personal data being stored further, we will transfer your data to our applicant pool. There the data will be deleted after two years.
If you have been accepted for a position as part of the application process, the data will be transferred from the applicant data system to our personnel information system.
To which recipients is the data passed on?
All applications (regardless of their channel of receipt) are immediately transferred to the applicant management system onlyfy one and processed there. Subsequently, a pre-selection and forwarding to the requesting departments takes place. Data may be forwarded to authorities for examination on the basis of official requirements (e.g. recruitment of applicants from outside the EU). The data will not be passed on to third parties beyond this.
The provider of our applicant management system is
New Work SE
Am Strandkai 1
The use of onlyfy one and the associated handling of personal data is based on a joint responsibility with New Work SE.
5 Social media
This website uses links to our presences on social media pages. The data protection and liability regulations of the respective providers, which you can access as described below, apply to these presences.
We process your data for the purpose of effectively informing and supporting our customers and interested parties. This is our legitimate address according to Art. 6 Para.1 clause 1f GDPR. The processing takes place based on the declaration of joint responsibility (https://www.facebook.com/legal/terms/page_controller_addendum).
The service provider is Meta Platforms Inc.
Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, is responsible for the European region.
6 Information on service providers
In order to operate this Website, we integrate external services in order to make our Website more user-friendly, more effective and more secure. We have a legitimate interest in this pursuant to Art 6. para. 1 clause 1 f) GDPR.
We expressly point out that some of the service providers we use are located in unsafe third countries or transmit data to unsafe third countries (e.g. USA). According to the European Court of Justice, there is no adequate level of protection in these states. The transfer to these countries only takes place after consent has been given.
6.1 Cows Online GmbH
This website is hosted externally. The personal data collected on this website is stored on the servers of the hosting provider(s). This may primarily include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access, and other data generated through a website.
External hosting is done to fulfill our contractual obligations to potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast, and efficient provision of our online offerings by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, processing will be based solely on Art. 6(1)(a) GDPR and § 25(1) TTDSG, to the extent the consent includes storing cookies or accessing information on the user's device (e.g. device fingerprinting) in the sense of TTDSG. Consent can be revoked at any time.
Our hosting provider(s) will process your data only to the extent necessary to fulfill their service obligations and will follow our instructions regarding this data.
We use the following hosting provider(s):
Cows Online GmbH
Data Processing Agreement (DPA):
We have entered into a Data Processing Agreement (DPA) for the use of the aforementioned service. This is a legally required contract that ensures that the processing of personal data of our website visitors is carried out only according to our instructions and in compliance with the GDPR.
6.2 Google Tag Manager
The Google Tag Manager service is used on our website to control the display of services. This service is offered by the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Please read here how Google complies with data protection requirements, also with regard to transmission to the USA: https://policies.google.com/privacy?hl=de
We use the Google Tag Manager on the basis of Art. 6 para. 1 p. 1 f) DSGVO. Our legitimate interest lies in being able to effectively play out services on our site.
If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO. This consent can be revoked at any time.
6.7 CRM HubSpot
To manage and analyse our customer contacts, we use the HubSpot CRM service. The provider of the software is HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA.
If you contact us in connection with a business enquiry (e.g. by email, contact form or social media channels), your details and contact data that you have provided to us will be stored in our CRM software HubSpot.
In addition to analysing the user behaviour of our contacts on our website, we can analyse and evaluate customer interactions.
The processing is carried out to handle your enquiries and to conduct individual communication with you, as well as to improve our offer.
The legal basis for the processing of the data is our legitimate interest in responding to your request in accordance with Art. 6 Para. 1 clause 1 f) GDPR. If the purpose of your contact is to conclude a contract, the additional legal basis for the processing is Art. 6 Para. 1 clause 1 b) GDPR.
If you have given your consent to the use of the service in accordance with Art. 6 Para. 1 clause 1 a) GDPR and § 25 Para. 1 TTDSG, this will serve exclusively as the legal basis. Consent given can be revoked at any time with effect for the future.
Data will be deleted after your request has been processed unless there are legal obligations to retain the data.
We have concluded an order processing contract with HubSpot.
In principle, no data processing takes place outside the European Union (EU), as it is hosted exclusively in AWS data centres in the EU.
However, there are theoretical access possibilities via HubSpot, Inc. and its affiliated companies, as well as via Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA.
In this context, we would like to point out that due to the US CLOUD Act of 2018, it is theoretically possible that US authorities can access data from US IT companies and cloud providers that is stored outside the USA.
HubSpot generally bases transfers of EU data to the US on the EU Commission’s standard data protection clauses.
Please read here how HubSpot also complies with data protection requirements about transfers to the USA:
Data protection information for webinars via “Microsoft Teams
We would like to inform you below about the processing of personal data in connection with the use of Microsoft Teams.
Purpose of the processing
We use the Microsoft Teams tool to conduct webinars. Microsoft Teams is a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
Note: To the extent that you access the Microsoft Teams website, Microsoft Corporation is responsible for data processing.
What data is processed?
When you use Microsoft Teams, various types of data are processed. The scope of the data also depends on the data you provide before or when participating in a webinar. The following personal data is subject to processing:
User details: e.g. display name (“Display name”), e-mail address.
Protocol files/meeting metadata: e.g. description (optional), IP address of the PC ́s or mobile device, date and time of access. Device/hardware and software information, language settings, relevant system configuration details (e.g. graphics card, sound card, driver version).
Text, audio and video data: You may have the opportunity to use the chat function in a webinar. In this respect, the text entries you make are processed in order to display them in the webinar and, if necessary, to record them. In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device will be processed accordingly for the duration of the webinar. You can switch off or mute the camera or microphone yourself at any time via the Microsoft Teams applications.
To participate in a webinar, you must at least provide details of your display name.
Scope of processing
We use Microsoft Teams to deliver webinars. The webinars are not recorded.
The chat content is only available for the duration of the webinar.
Legal basis of data processing
We use Teams on the basis of Art. 6 para. 1 clause 1 f) GDPR. Our legitimate interest is to be able to conduct webinars effectively.
If you have given your consent to the use of the service in accordance with Art 6. para. 1 clause 1 a) GDPR and § 25 Para. 1 TTDSG, this will serve exclusively as the legal basis. Consent given can be revoked at any time with effect for the future.
Recipients / passing on of data
Personal data processed in connection with participation in webinars will not be passed on to third parties as a matter of principle, unless they are specifically intended to be passed on. Please note that content from webinars, as well as from face-to-face meetings, is often used to communicate information with employees, customers, interested parties or third parties and is therefore intended for disclosure.
Other recipients: The Microsoft Teams provider necessarily receives knowledge of the above-mentioned data insofar as this is provided for in the context of our order processing agreement with Microsoft Teams.
Data processing outside the European Union
In principle, there is no data processing outside the European Union (EU), as the data centres are located in the EU.
Nevertheless, there are theoretical access possibilities through Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
In this context, we would like to point out that due to the US CLOUD Act of 2018, there is a theoretical possibility for US authorities to access data of US IT companies and cloud providers that are stored outside the USA.
However, the data is encrypted during transport over the internet and thus secured against unauthorised access by third parties.
Further information on data protection can be found here: https://privacy.microsoft.com/de-de/privacystatement
7.1 Google Analytics
We use Google Analytics, a web analysis service from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter referred to as “Google”. Google Analytics uses so-called “cookies”, which are text files that are placed on your computer in order to analyse your use of our Website. The information the cookie generates about the use of this Website by the user is generally transmitted to and stored on a Google server in the USA.
We use Google Analytics in accordance with Art 6. para. 1 clause 1 a) GDPR. Consent given can be revoked at any time with effect for the future.
This is used to analyse user behaviour and to improve our website.
As of 12th August 2020, Google has generally supported transfers of EU data to the USA based on standard data protection clauses of the EU Commission.
We have enabled IP anonymisation on this Website (anonymizeIp). Your IP address will therefore be truncated by Google within the member states of the European Union or in other countries that are party to the Agreement about the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. On our behalf, Google will use this information to evaluate your use of the Website, to compile reports on Website activities, and to provide us with additional services related to use of the Website and Internet usage.
The IP address provided by your browser within the framework of Google Analytics will not be combined with other data from Google. You may prevent the storage of cookies by selecting the corresponding setting in your browser; however, we would like to point out that this may prevent you from fully utilising all features provided on this Website.
You can also prevent the data relating to your use of the Website that was generated by the cookie (including your IP address) from being transferred to Google, as well as the processing of such data by Google, by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
As an alternative to the browser plug-in, or on mobile browsers, you can set an opt-out cookie by clicking on the following link, which will prevent Google Analytics from collecting data within this Website in the future (this opt-out cookie will only work in that browser and for that domain; If you delete the cookies in your browser, you must click this link again): [disable Google Analytics].
8 Retention period
Unless specifically stated, we only store personal data for as long as is necessary to carry out the intended purposes.
In some cases, the legislator stipulates that personal data must be retained, for example under tax law or commercial law. In these cases, the data will only be stored by us for these legal purposes, but will not be processed in any other way and will be deleted after expiry of the legal retention period.
9 Your rights as a data subject
Under the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by email or by post to the address specified in section 1, clearly identifying yourself.
You will find an overview of your rights below.
9.1 Right to confirmation and right of access to personal data
You have the right to access clear information about the processing of your personal data.
You have the right to obtain confirmation from us at any time as to whether personal data concerning you is being processed. Should this be the case, you have the right to request information from us, free of charge, about the personal data stored about you, together with a copy of this data. Furthermore, you have the right to the following information:
- The purposes of the processing.
- The categories of personal data that are processed.
- The recipients or categories of recipients to whom the personal data has been or is still being disclosed – in particular, recipients in third countries or at international organisations.
- If possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this period.
- The existence of a right to rectification or erasure of personal data concerning you, or to restrict the processing by the data controller, or of a right to oppose such processing.
- The existence of a right to appeal to a supervisory authority.
- If the personal data is not collected from the data subject him/herself, any available information as to the source of the data.
- The existence of any automated decision-making, including profiling, pursuant to Art. 22 para. 1 and 4 GDPR and – at least in such cases – meaningful information about the logic involved as well as the scope and intended effects of such processing for you.
If personal data are transferred to a third country or to an international organisation, you have the right to be informed of the appropriate guarantees in connection with the transfer pursuant to Art. 46 GDPR.
9.2 Right to rectification
You have the right to request that we rectify personal data concerning you, or, if applicable, complete it.
You have the right to request that we rectify inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
9.3 Right to erasure (“right to be forgotten”)
In a number of cases, we are obliged to delete personal data concerning you.
In accordance with Art. 17 para. 1 GDPR, you have the right to demand that we delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay if any of the following reasons applies:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 clause 1 a) GDPR or Art. 9 para. 2 a) GDPR, and there is no other legal basis for such processing.
- You object to the processing pursuant to Art. 21 para. 1 GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR.
- The personal data has been unlawfully processed.
- The personal data has to be erased in order to comply with a legal obligation under Union or Member State law to which we are subject.
- The personal data concerning you has been collected in relation to the offer of information society services referred to in Art. 8 para. 1 GDPR.
If we have made your personal data public and are obliged to delete it pursuant to Art. 17 para. 1 GDPR, we shall take reasonable measures, including technical measures – while taking into account the available technology and the implementation costs – to inform the data controllers who are responsibly for processing your personal data that you have requested that all links to your personal data, as well as any copies or replications of your personal data, be deleted.
9.4 Right to restriction of processing
In a number of cases, you are entitled to request that we restrict the processing of your personal data.
You have the right to request that we restrict the processing if one of the following conditions is met:
- You contest the accuracy of your personal information for a period of time that allows us to verify the accuracy of the personal data.
- The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
- We no longer need the personal data for the purposes of the processing, but you require it in order to establish, exercise or defend legal claims.
- You have objected to the processing pursuant to Art. 21 para. 1 GDPR, pending verification of whether our legitimate grounds override yours.
9.5 Right to data portability
You have the right to receive, transmit or have us transmit personal data concerning you in a machine-readable format.
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and the right to transmit this data to another data controller without hindrance from us, where:
- the processing is based on consent pursuant to Art. 6 para. 1 clause 1 a) GDPR or Art.9 para. 2 a) GDPR, or on a contract pursuant to Art. 6 para. 1 clause 1 b) GDPR; and
- the processing is carried out by automated means.
In exercising your right to data portability pursuant to paragraph 1, you have the right to have your personal data transmitted directly from us to another data controller, provided that this is technically feasible.
9.6 Right to object
You have the right to object to the lawful processing of your personal data by us if this is justified by your particular situation and provided that our interests in the processing do not outweigh yours.
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6 para. 1 (e) or (f) GDPR, including profiling based on those provisions. We will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Art. 89 para. 1 GDPR, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.7 Automated decision-making including profiling
You have the right to not be subject to a decision based solely on automated processing – including profiling – which has a legal bearing on you or which significantly affects you in a similar manner.
No automated decisions are made on the basis of the personal data that we collect.
9.8 Right to revoke consent previously provided under data protection law
You have the right to revoke your consent to the processing of your personal data at any time.
9.9 Right to file a complaint with a supervisory authority
You have the right to file a complaint with a supervisory authority, in particular, in the Member State where you live or work or where the alleged violation took place, if you believe that the processing of your personal data is unlawful.
10 Data security
We make every effort to ensure the security of your data in accordance with the applicable data protection laws and the technical possibilities at our disposal.
Your personal data will be transmitted by us in encrypted form. This applies to all forms that are offered. We use the SSL (Secure Socket Layer) encryption protocol but would like to point out that any data transmission on the Internet may be subject to security vulnerabilities (e.g., when communicating by email). It is not possible to completely protect data against access by third parties.
To protect your data, we maintain technical and organisational security measures in accordance with Art. 32 GDPR, which we continually adapt to reflect the latest technological developments.
We also do not guarantee that our website will be available at specific times; disturbances, interruptions or failures cannot be excluded. We regularly and carefully backup the servers we use.
11 Disclosure of data to third parties, no data transfer to non-EU countries
In principle, we only use your personal data inside our company.
Should we involve third parties in the fulfilment of contracts (such as logistics service providers), these third parties will only receive personal data to the extent necessary to perform the corresponding service.
In the event that we outsource certain parts of the data processing (“contract processing”), we contractually oblige the processors we contract to only use personal data in accordance with the requirements of the applicable data protection laws and to ensure that the rights of the data subject are protected.
No data is transferred to places or persons outside the EU apart from the cases mentioned in clauses 4, 6 and 7 of this policy, nor is any such transfer planned.
12 Data protection officer
As an ISO 27001-certified company, information and data security is of great importance to Seven Principles AG That is why we handle your data with appropriate sensitivity. If you have any questions about data protection, you can contact our data protection officer at Datenschutz@7p-group.com or by post at:
Data protection officer
Seven Principles Mobility GmbH