Thank you for your interest in our website.
The Data Controller, as defined in the EU General Data Protection Regulation (“GDPR”), who is responsible for the collection, processing and use of your personal data is PAIR Finance GmbH, Hardenbergstrasse 32, 10623 Berlin. You can reach us using the contact information in Imprint.
You can contact our Data Protection Officers by post at PAIR Finance GmbH, Datenschutz, Hardenbergstrasse 32, 10623 Berlin or by sending an e-mail to email@example.com.
In line with the use of our website, personal data is only collected where necessary for technical reasons or if you are using specific functions or services available on our website, such as the contact form or agent login. We also process data communicated to us by you when you make contact.
2.1 Visiting our website
When you visit our website, specific access data is recorded automatically, e.g. date and time of access, name of file requested, website from which the file was requested, access status (e.g. file transferred, file not found), the web browser you are using, the operating system of your device and the IP address of the requesting device.
It is necessary to process this data to make the visit to the website possible and guarantee the continuous functionality, availability and security of our systems. The legal basis for this data processing is Article 6, para. 1, letter b, GDPR.
For the purposes specified above, the access data is temporarily stored in internal logfiles in order to generate statistical Information about the use of our website and further develop our website in line with usage habits and maintain our website on a general, administrative basis. The legal basis for this data processing is Article 6, para. 1, letter f GDPR, based on our justified interest in the proper optimisation of our website.
The information stored in the logfiles does not allow any direct conclusions about who you are, and, in particular, we only store IP addresses in truncated, anonymised form. The logfiles are saved for 7 days and subsequently deleted.
2.2 Contact forms for potential clients
We give you the opportunity to send us enquiries about the use of our services directly via our contact form. At certain times, we also offer promotional pages, e.g. in line with trade shows, giving the option of contacting us and arranging a meeting.
In order to use the contact forms we provide, you must provide your name and an e-mail address so that we contact and discuss arrangements with you. Other mandatory fields are marked as such. You can also provide further information in order to allow us to assess your enquiry more quickly.
We process the information provided by you in the contact form in order to respond to your enquiry, put together a customised quotation, contact you for further discussions and react to your wishes, questions and criticisms. The legal basis for the data processing described is Article 6, para. 1, letter b, GDPR.
The data collected from the use of the contact form is deleted after your enquiry has been processed, providing no collection contract has been concluded and it does not need to be saved based on links to other processes until such processes are complete, or you have not given us you consent to make contact in future for other marketing measures.
2.3 Agents, contract partners and potential clients
If you are an agent, a contract partner or a potential client for our services, we collect regular master data (e.g. names and addresses) and contract data (e.g. contract content, contractual communications, names of contact persons) and, where applicable, payment data (e.g. bank details, payment history) on a regular basis in line with cooperation and communication with you for the purposes of fulfilling our contractual or pre-contractual services and obligations.
As a PAIR Finance client, you are given access to our service platform. To use the service platform, you will need to enter various details, most importantly your name, an e-mail address and a password. In line with the use of the platform, we also record the time of your first login, the last two logins, including times and IP address and the total number of logins for security verification reasons, plus the language selected in the system in order to display the content.
We process the data on our clients, contract partners and potential clients in accordance with Article 6, para. 1, letter b GDPR in order to provide services to them. The data processed, its scope and purpose and the necessity for processing is determined based on the underlying contractual relationship.
For the purposes of maintaining contacts, we use a Customer Relationship Management system, or CRM for short, from Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia (hereinafter “Pipedrive”). We record company contacts for agents, business partners and potential clients in the CRM. The Pipedrive servers we use are essentially within the European Union. However, elements of your data can be processed outside the European Economic Area, particularly in the USA, for technical reasons, e.g. in line with Pipedrive support services. In order to guarantee the security of your data even in these circumstances, Pipedrive, Inc., 460 Park Ave South, New York, NY 10016, has signed up to the EU-US Privacy Shield. The legal basis is Article 6, para. 1, letter f, GDPR, based on our justified interest in using an external service provider to organise our company contacts efficiently.
Finally, we offer you the opportunity to contact us via our website for the purpose of applying for an advertised position. To organize and process the application procedure, we use the services of Greenhouse Software, Inc.,18 West 18th Street, 11th Floor New York, NY 10011, USA (hereinafter referred to as “Greenhouse”). Greenhouse is implemented as a web service directly on our website (hereinafter: “Greenhouse website”). If you click on jobs on our website, you will be redirected to our Greenhouse website. Within this framework, we process your personal data in order to make the whole application process easier, based on the statutory reasons in Art. 6, para. 1, lit. b and lit. f GDPR.
For visitors to our Greenhouse website, personal access data is recorded automatically, including, for example, the requesting device, the web browser used and the operating system of your device, the IP address of the requesting device, the questions and answers sent to and from your device, the website from which the Greenhouse website was accessed and your behaviour on the Greenhouse website.
The collection of your personal data and the involvement of Greenhouse in the context of visiting our Greenhouse website and the associated data processing is necessary in order to monitor and improve the recruitment process and the performance of the Greenhouse website, based on our legitimate interest in the efficient design of our internal processes and our service, Art. 6 para. 1, lit. f GDPR.
Furthermore, the following personal application data may be processed in the context of the application process, in particular, but not limited to, all personal data you provide to us via the application form: name, e-mail address, telephone number, picture, address, cover letter, CV, LinkedIn profile, and the position for which you have applied for, status, notes and plans regarding your application and e-mail communication.
The collection of your personal data and the involvement of Greenhouse as part of the application process and the associated data processing is necessary for pre-contractual measures relating to your application, Art. 6 para. 1, lit. b GDPR.
At the end of the application process we will delete your personal data as soon as possible, unless we have informed you that we need the data for other purposes. As a general rule, we store the personal data we have received from you in the course of the application process for a period of 6 months for preventive reasons.
2.5 Communication with our customer services
If you send an e-mail to our customer services in response to a payment reminder or call our hotline, we will regularly record your e-mail address, your telephone number and, where applicable, your address, depending on the contact channel you use. In order to process your enquiry properly, we may need further information (e.g. a reference, address or date of birth).
We will use this information in order to put you through to the relevant case worker and process your enquiry. The legal basis for data processing in line with contacting our customer services is Article 6, para. 1, letters b and f, GDPR. The data is generally deleted at the end of the periods of limitation for the underlying process, unless it needs to be saved for longer because of a link to another process. The statutory archiving obligations also apply.
Finally, we sometimes record incoming telephone calls for training purposes and to improve our service quality, if and to the extent that you have given your explicit consent prior to recording. Before the call starts, you will be informed by a recorded message that your call may be recorded and asked for your consent. Of course, you can always refuse consent and not have your telephone call with us recorded. The legal basis for the recording and associated data processing is Article 6, para. 1, letter a and Article 7 GDPR, based on your consent. You have the right to revoke any consent you have given with immediate effect in accordance with Article 7, para. 3 GDPR. Once they have been evaluated for training and quality purposes, the recordings are deleted, unless they need to be saved until the resolution of an additional process of securing evidence.
3. Cookies and usage analysis
When you visit and use our website, different cookies are set. Cookies are small text files that are stored in the memory of your web browser and contain information that allow web servers to recognize you when you visit our website later. Cookies cannot execute programs or transfer viruses to your computer.
We use our own cookies, especially to record that information on our website has been shown to you, so you are not shown it again on your next visit. The main purpose of our own cookies is to make the use of our services as time-effective and user-friendly as possible.
The aim is to make your use of our website more convenient and customised. The processing of the respective cookies is based on our justified interests as above, in this respect, the legal basis is Article 6, para. 1, letter f GDPR.
You can block cookies from being saved by refusing to accept cookies from this website in your browser settings. However, not accepting cookies can, in some cases, significantly impede the functionality of our website.
3.2 Use of third-party cookies for usage analysis
On our website, we also apply various approaches to understanding the use of the website and finding out what content is particularly important for our users and what kind of devices they are using to access it. This allows us to optimise our content and the page design to the actual browser types and devices used.
For this purpose, we utilise services from various external providers, who are listed below. The legal basis for the data processing described below is Article 6, para. 1, letter f GDPR, based on our justified interest in the proper design and continuous optimisation of our website.
a) Google Analytics
You can block Google web analysis at any time. You have various options: (1) You can set your browser to block cookies from Google Analytics. (2) You can adjust your settings for Google advertising. (3) You can set a deactivation cookie by clicking here: Deactivate Google Analytics. (4) You can install the deactivation plug-in provided by Google in your Firefox, Internet Explorer or Chrome browser using the following link (this does not work on mobile devices): Browser-Plugin.
As an alternative to the browser plug-in or on mobile device, you can clickin order not to be tracked by Google Analytics on our website in future (this setting applies only to you current browser and this website). This saves a cookie to your device, which means you need to click on the link again if you delete your cookies. If you have deactivated cookies, it may be that not all services on our website are available to you.
b) Google Tag Manager
4. Links to other websites and online services
PAIR Finance also has a presence on social networks and other online platforms in order to communicate with current and future clients, business partners and existing and potential customers and inform them about our services..
The operation of our online services requires infrastructure services, processing capacity, storage space and database services, for which we use service providers. We and our service providers collect data on the basis of our justified interests in the efficient and secure availability of our online services in accordance with Article 6, para. 1, letter f and Article 28 GDPR.
Your data is partially processed on servers provided by Amazon Web Services, a service from Amazon Web Services Inc., 410 Terry Avenue North, Seattle, Washington 98109, USA (hereinafter “AWS”). The connection from your device to the content on our website is established via AWS servers. The servers we use are essentially within the European Union. However, elements of your data can be processed outside the European Economic Area, particularly in the USA, for technical reasons. In order to guarantee the security of your data in this instance, AQA is part of the EU-US Privacy Shield. We have also concluded a special contract with AWS which corresponds to the requirements of the standard contract clauses for the European Commission. The legal basis is Article 6, para. 1, letter f, GDPR, based on our justified interest in having the content of our website securely and reliably stored by external service providers and, at the same time, reducing our own outlay on the provision of IT infrastructure.
6. Data Transfer
We will only forward the data we have collected if you have given your explicit consent in accordance with Article 6, para. 1, letter a GDPR, forwarding is necessary in accordance with Article 6, para. 1, letter f GDPR in order to assert, exercise or defend legal claims and there is no reason to assume that there is an overwhelming proprietary interest in failing to disclose the data, we are obliged by law to forward the data in accordance with Article 6, para. 1, letter C GDPR or it is authorised by law or required in accordance with Article 6, para. 1, letter b GDPR for the processing of contractual relationships with you or for the implementation of pre-contractual measures following an enquiry from you.
Data can also be forwarded in conjunction with official requests, legal rulings and legal proceedings, if it is necessary for legal compliance or execution.
7. Your rights
You have the right to demand information on the processing of your personal data by us at any time. In providing the information, we will explain how the data is processed and provide you with an overview of the data we have stored about you.
If the data we have stored is incorrect or out-of-date, you have the right to have the data corrected.
You can also request the deletion of your data. If, in exceptional circumstances, it is not possible to delete the data because of other legal requirements, the data is blocked so that it is only available for this statutory purpose.
You can also restrict the processing of your data, e.g. if you believe the data we have saved is not correct. You also have the right to data transferability, i.e. on request, we will send you a digital copy of the personal data provided by you.
If you wish to assert the rights described here, you can use the contact details set out in Section 1 above. This also applies if you wish to receive copies of guarantees to evidence an appropriate level of data protection.
You also have the right to object to data processing based on Article 6, para. 1 letter e or f GDPR or for the purposes of direct advertising. Finally, you have the right to complain to the data protection regulators with jurisdiction over us. You can assert this right at a regulatory body in the Member State in which you live or work, or the location of the alleged infringement. In Berlin, the regulatory body with jurisdiction is: Berliner Beauftragte für Datenschutz und Informationsfreiheit, Friedrichstr. 219, 10969 Berlin.
In accordance with Article 7, para. 3 GDPR, you have the right to revoke consent granted to us at any time. As a result, we will discontinue the data processing to which the consent related with immediate effect. Revoking your consent does not affect the legality of the processing from the point of your consent until its revocation.
If we are processing your data based on a justified interest in accordance with Article 6, para. 1, letter F GDPR, you have, in accordance with Article 21 GDPR, the right to object to the processing of your data and give us reasons arising from your particular situation which you believe prove that your proprietary interests take priority. If this is an objection to data processing for the purposes of direct advertising, you have the right to object in general, which we can action without you having to cite reasons.
If you wish to assert your right to revoke or object, simply send a message to the contact data above, no specific format is required.
Date: June 2020