of the Tradewind Group (www.tradewindfinance.com)
We take the protection of your personal data very seriously. Therefore, we treat your personal data always and of course in accordance with the legal data protection obligations. We have designated a qualified and reliable external Data Protection Officer. The external commissioning of data protection will be conducted by Dr. Jörn Voßbein of the UIMC Dr. Vossbein GmbH & Co KG.
In the following, we would like to inform you about the processing of personal data:
- Data protection concerning subscription to newsletters
- Data protection concerning processing of business clients’ personal data (B2B)
- Data protection concerning processing of customers’ personal data (B2C)
- Data protection concerning the application procedure
- Plug-ins on websites
- Rights of data subjects (applicable to all)
- Contact with the Data Protection Officer (applicable to all)
You can use our website without disclosing your identity. Any personal data which might be requested on our website e. g. in a contact form or upon login / registration is provided by you on a voluntary basis. The provided information is used for our own business purposes (such as sending the requested materials / information).
Please do not hesitate to contact us via the contact form provided on our website, should you have any questions. Fields marked with an asterisk are compulsory and have to be filled in so that we may attribute the query to you and reply to your request. Additional information is provided on a voluntary basis. The processing of data for the purpose of making contact with us takes place in accordance with Art. 6 para. 1 lit. a GDPR based on your voluntary consent.
The collected personal data resulting from the use of the contact form will be deleted after the execution of your request and after the retention periods according to tax law and commercial law have expired.
Once granted consent - e.g. for the purpose of receiving a newsletter or other interesting information from our company – can be withdrawn at any time with effect for the future, without giving any reasons. For this purpose, you can use the abovementioned contact form or any other means of contact mentioned in the newsletter.
This site uses “Cookies”. Cookies are text files that will be stored on your computer and allow analysis of the use of the website and which recognize you automatically on your next visit of this website. You can prevent the installation of cookies through an appropriate setting in your browser. However, as a consequence, you might not be able to make full use of our website.
Every time this website is accessed, protocols are created and processed. Thereby, individual users remain anonymous:
- Referrer (site that provided the link to and referred you to this website)
- Search terms (search engines as referrer)
- IP is analysed to determine the country of origin and the provider
- Browser, operating system, installed plug-ins and screen resolution
- Duration of the visit on the website.
The abovementioned data are processed by us on the basis of our legitimate interests according to Art. 6 para. 1 lit. f GDPR for the following purposes:
- Ensuring a reliable connection establishment to the website
- Ensuring of a comfortable use of our website
- Evaluation of the system security and stability, as well as
- Further administrative purposes.
We reserve the right to check this data subsequently if we have concrete indications of an illegal use. The data will be deleted immediately when they are no longer needed for the purpose for which they were collected, the latest after six months.
Transfer of Data
A transfer to Third Parties for commercial or non-commercial purposes will not happen without your explicit consent. We will only transfer your personal data to third parties if this is lawful in accordance with the current laws [e.g.: on the basis of article 6 GDPR] and/or it is necessary. To some extent we appoint service provider for the necessary statutory processing of data; the website is hosted by <service provider> and maintained by <agency>. The full responsibility for the data processing remains with us. Further on we use to some extent Plug-ins of other service provider on our website; please find details below.
We inform you that we also transfer personal data with the above-mentioned purpose if necessary to our worldwide group companies (see “About us”). The data transfer takes place on the basis of a legitimate interest, in order to provide to you a holistic offer of your services.
Here by data is also being transferred to affiliates outside of the Union / European Economical Area. For this case we ensure a suitable data protection level by concluding standard contractual clauses.
Liability for own Content
The content of these sites has been created with the utmost care. We cannot give any guarantee for accuracy, completeness and topicality of the content. As operator of the website, we are responsible for our own content on these sites according to the general laws.
Liability for Links (Content of Third Party Providers)
It is important to distinguish between our own content and cross references (“links”) that link to content provided by other site operators. We have no influence on the content of their linked websites. Here, it is always the provider or the operator of these sites that is responsible for the content.
Data protection when subscribing to a newsletter
At various points you have the opportunity to order a newsletter. We process your personal data exclusively in connection with your order and subscription of our newsletter, in order to send you information about products, services, events and other interesting facts about us. You can unsubscribe at any time with effect for the future.
We use tracking for statistical purposes regarding the information which links within the newsletter you click on and which lead to actions on our website ("Conversion"). However, these data are not attributed to you; rather, these are anonymous.
The data provided by you are required so that we can send you the newsletters. Without these data we cannot consider your registration for the newsletter.
Transfer of personal data
Other companies in our globally operating Tradewind Group will use your personal data to send you newsletters only if you have agreed to this.
Retention and erasure of personal data
Your personal data will be stored until you unsubscribe from the newsletter.
Data protection regarding the processing of personal data of our business partners (customers / suppliers; B2B)
We as the contractual partner of your company, process the personal data with regard to your person for purposes of our legitimate interests for the preparation of the offer und the fulfilment of the contracts on the basis of art. 6 (1) s. 1 let. F GDPR. Bookkeeping and cost accounting on the basis of art. 6 (1) s. 1 let. b GDPR and for the fulfilment of contractual and legal obligations (e.g. commercial and tax law) on the basis of art. 6 (1) s. 1 let. c GDPR. The business relationship exists between your company and us. Because of external requirements (e.g. within the scope of tax law and customs law) it can happen that personal data regarding your person is compared to lists which were published by federal authorities.
Furthermore, data may also be processed for legitimate purposes in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, such as marketing, internal market research and marketing purposes, in-house statistics. The legitimate interests are in particular process optimisation and cost-based attribution; in this connection your interests, fundamental rights and freedoms are duly taken into account.
Only if you have given us your consent or if we have informed you adequately about the data collection according to § 7 UWG (German Law against Unfair Competition), we use your data to provide you with information about products, services, events and other useful information about us. You can object to receiving such information any time with effect for the future.
The data provided by you are essential in order to conduct the contractual relationship. Without these provided data we are not able to perform the contractual relationship.
We reserve the right to check this data subsequently, if we become aware of concrete indications for illegal use. The data will be deleted immediately if it is no longer needed to fulfil the purposes, at the latest after six months.
Transfer of personal data
Your personal data is partly transferred to external service providers (e. g. tax consultants, legal advisors). To some extent, external IT contractors can access your data (within the scope of commissioned data processing according to Art. 28 GDPR). In these cases, the service providers are bound by instructions. This is ensured by corresponding contracts. Some of these contractors are located outside the EU / EEA; those contractors ensure an adequate level of data protection by concluding EU standard contractual clauses / self-certification under the privacy shield.
In order to provide you with the best possible information and services for the purposes outlined above, information about the contractual relationship (including personal data) is provided within our globally operating Tradewind group (including the US and other non-EU / non-EEA countries). Even those companies within the group which are located outside the EU ensure an adequate level of data protection by concluding EU Standard Contractual Clauses / Binding Corporate Rules / self-certification under the Privacy Shield. The rules are available here.
Retention and erasure of personal data
Your personal data will be stored as long as these are required to fulfil the above-mentioned purposes. The data will be erased at the latest after the termination of the contractual relationship and after expiry of the statutory retention periods of civil, commercial and tax law.
Data protection concerning the application procedure
We process your personal data in the context of the application procedure as well as to determine your potential work-related applicability. In this regard, we process the data provided by you for the purpose of a well-founded personnel decision in accordance with Art. 6 para. 1 lit. b GDPR. In addition, assessment based on objective, non-discriminating criteria, are added; if permissible in the particular case, additional publicly available personal data will be added as well.
The data provided by you are essential for the execution of the application procedure. We are not able to consider your application without these data.
Your personal data will be transferred to other affiliates of our corporate group, which are acting as a service provider, to support us within the scope of the application procedure. To some extent, IT contractors can access your data. The service providers are bound by instructions in any such cases. This is ensured by corresponding contracts. Some of these contractors are located outside the EU / EEA; those contractors ensure an adequate level of data protection by concluding EU standard contractual clauses / self-certification under the privacy shield.
Transfer of data to other affiliates
We transfer your personal data to other affiliates of our corporate group in order to give you the opportunity to potentially fill another vacancy within our corporate group only when you have given your consent to do so. All those companies within our corporate group which are located outside the EU/EEA also ensure an adequate level of data protection by concluding the EU Standard Contractual Clauses / Binding Corporate Rules.
Retention and erasure of data
Your data is kept as long as it is needed for the purpose of the application procedure. In case you object to the data processing during the application procedure, the data – as far as no retention period is specified by law – will be erased.
The data will be erased at the end of the application procedure and after the period for filing a law suit has passed unless you agreed that your application will be saved for other job offers. Unsolicited applications will be kept at the longest until your withdrawal or for the period of two years and will then be erased.
Data protection regarding our employees
We are processing your personal data as your employer for the purpose in relation to reason, execution and handling of your employment. This processing is based on § 26 GDPR (for employment contract based on German law) and art. 6 para. 1 s. 1 let. b GDPR as well as on legal duties (e.g. tax law and national insurance) in accordance with art. 6 abs. 1 s. 1 let. c GDPR. Including payroll account, human resource management, travel expense report, vehicle fleet management, cost controlling, company pension, internal and external communication, IT administration / IT access right administration, creation of visa proposal and insurance matters. Further on, data is being processed for the purpose of performance assessments, for the evaluation of your potential work-related application, for potential analysis and for the coordination of work-related trainings. Further on, data will be recorded which allow to draw conclusions on your behaviour and on the work accomplished by you (e.g. evaluations, disciplinary sanctions).
Moreover, data will be processed on the basis of a legitimate interest, according to art. 6 para. 1 s. 1 let. f GDPR, like logging for monitoring access, logging of the IT systems, video surveillance of the campus and the building and logging of the machines used (Factory data capture). The legitimate interest specially lies in the optimisation of processes, prevention of unauthorized physical and logical access, the protection of the IT systems and to attribute costs to their origin; while doing so your interest, fundamental rights and freedoms will be taken properly into account.
Only when you consented we will use your data and pictures of you in the scope of public relations activities (exact information on the purpose and range of data being used can be taken out of the corresponding declaration of consent).
Health data as they are special categories of personal data will only be processed on the basis of art. 9 para. 2 s.1 let. b, h GDPR and to an extent they are necessary in order to perform the relationship to the superior and to administrate your employment contract (e.g. notification on the inability to work, information in relation to occupational accidents, information on handicap (as far as relevant for the employment relationship), information in the context of the occupational rehabilitation management).
The data provided by you is essential in order to conduct the contractual relationship. Without these provided data we are not able to perform the contractual relationship.
Beside the human resource department other functionaries also receive access to your personal data, this only happens to the purposes stated above and in line with the “Need-to-Know”-principal. All these persons are obliged to comply to data confidentiality.
Transfer / Service provider
Your personal data is partly transferred to external service provider, for the purpose of payroll accounting, for the management of the company pension scheme, for the booking related to travels (e.g. hotel, car rental, flights, and trains), legal support. Further on, personal data will be transferred on the basis of contractual or legal obligations to the corresponding finance authority, insurance broker, canteen, social insurance carrier, insurances and banks. Personal data will also be transferred to a third party for validation purpose (banks), if required (Art. 6 Abs. 1 lit. b DSGVO).
To some extent, external service provider can access your data (within the scope of an order data processing in accordance with art. 28 GDPR). In these cases, the service provider is bound to instructions, this is ensured by corresponding contracts. These service providers are partly located outside of the EU/EEA. Those service providers guarantee an adequate level of data protection by concluding the EU standard contractual clauses / the binding corporate rules / the privacy shield.
To make sure, the functions can be guaranteed by Tradewind GmbH when taking the global strategy planning and the matrix organisation of the globally operating Tradewind Group into account it is necessary that Tradewind GmbH transfers your personal data to other affiliates (incl. USA and other states with are not located within the EU/EEA). Data is just being transferred to the extent it is necessary for collaboration and for the superior relationship to employees of members of the corporate group. This includes data transfers to departments of the company group, which have a functional relationship. This includes the human resource department.
Even those companies within the group that are located outside the EU ensure an adequate level of data protection by concluding EU standard contractual clauses with the Tradewind GmbH.
Retention and erasure of data
Your data is kept as long as it is needed for the above descripted purposes. The data is being deleted at latest after the termination of the employment relationship, the legally required retention period of tax law and commercial law and employment laws.
Plug-ins on websites
We are using various plug-ins of other service providers on our website, which we would like to inform you about in the following:
Web analysis with Google Analytics
This website uses Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics uses so-called Cookies, text files that will be stored on your computer and allow an analysis of the use of the website. The information about the use of the website produced through Cookies (including your shortened IP address) is transferred and stored on a Google server in the US. Google will use this information to evaluate the use of the website, to prepare reports of website activities for the website provider and to deliver other services connected with the use of the website and the Internet. Additionally, Google may transfer this information to Third Parties if it is legally required to do so or if Third Parties process these data on behalf of Google. Google will not in any case establish a combination between your IP address and other data of Google Inc.
You can object to the use of your data through Google Analytics by installing a so-called add-on in your browser. You can download the add-on to deactivate Google Analytics by following this link that leads you to the site of Google: http://tools.google.com/dlpage... [external site].
Rights of the data subjects
We hereby inform you that pursuant to Article 15 et seqq. GDPR you have the right to obtain information on the personal data concerned, as well as the right to rectification, erasure, restriction of processing and the right to object to processing of your personal data as well as the right to data portability. Moreover, you have the right to lodge a complaint with a supervisory authority according to Art. 77 GDPR if you believe that the processing of your personal data infringes the GDPR. If the processing of the personal data is based on Article 6 para. 1 lit. a GDPR or Article 9 para. 2 lit. a GDPR (Consent), you also have the right to withdraw your consent at any time without affecting the legality of the processing based on the consent until its withdrawal.
Right of access by the data subject, Art. 15 GDPR
You have the right to obtain confirmation as to whether or not and to which extent personal data of the data subject is being processed (especially the purpose of the processing, recipient of the data, retention period, etc.).
Right to rectification, Art. 16 GDPR
You have the right to obtain the rectification of the personal data concerning you, if these are incorrect or incomplete. This includes the right of completion of incomplete personal data by providing supplementary statements or notifications.
Right to erasure, Art. 17 GDPR
You have the right to demand the erasure of your personal data. This is possible e. g. when the data is not needed anymore for the purpose it was originally collected for or if there is another legal obligation that requires erasure of the personal data. This right may be excluded in individual cases.
Right to restriction of processing, Art. 18 GDPR
You have the right to demand restriction of the processing of your personal data. This is possible e. g. when the data has been recorded incorrectly or the processing of the data is unlawful. When restricting the processing of personal data, the processing is only allowed in closely defined cases.
Right to data portability, Art. 20 GDPR
You have the right to receive the personal data concerning you in a structured, commonly used, and machine-readable format, and the right to have those data transmitted from one controller to another controller. This only applies if you have provided that information yourself.
Right to object, Art. 21 GDPR
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you with effect to the future, if the processing of personal data was based on legitimate interests (see Art. 6 para. 1 lit. e, f GDPR). If you object, it will be evaluated whether or not the processing is based on current law and, if this is not the case, any further processing of your personal data will be refrained from.
Right to lodge a complaint with a supervisory authority, Art. 77 GDPR
You have the right to lodge a complaint with a supervisory authority of the Union or Member States in case of potential infringements of current data protection provisions.
Contact details of the Data Protection Officer
If you have any questions regarding the processing of your personal data, you can contact our data protection officer directly, who will be available with his team i. a. in the event of requests for information, other requests or complaints.
Dr. Jörn Voßbein (UIMC Dr. Vossbein GmbH & Co KG) as external Data Protection Officer
T: +49 202 946 7726 200