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Privacy Policy

© Provident CRM LTD
Unit 1, The CHQ Building,
Custom House quay,
North Dock,
Dublin 1
Eircode: D01 Y6H7 Dublin – Ireland
+353 (0)1 693 0000
+44 203 411 6799

Data protection is a priority for Provident CRM, and we are committed to protecting the privacy of our customers and site visitors, in compliance with the General Data Protection Regulation (GDPR), the Irish Data Protection Act 2018, and similar international legal frameworks.

The use of Provident CRM web pages is possible without any indication of personal data; however, if a data subject wants to make use of certain services via our website, processing of personal data could become necessary. If the processing of personal data is required and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR) and follow the country-specific data protection regulations applicable to Provident CRM. Through this data protection declaration, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. And, with this data protection declaration, inform data subjects of the rights to which they are entitled.

As the data controller, Provident CRM has implemented numerous technical and organisational measures to ensure comprehensive protection for the personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

Use the contents below to navigate Provident CRM’s privacy policy and data protection declaration.

  1. Definitions
  2. Name and Address of the Controller
  3. Name and Address of the Data Protection Officer
  4. Cookies
  5. Collection and Processing of General Data/Information
  6. Subscription to our Newsletter
  7. Newsletter-Tracking
  8. Contact Possibility via the Website
  9. Subscription to Comments in the Website Blog
  10. Routine Erasure and Blocking of Personal Data
  11. Rights of the Data Subject
  12. Data Protection for Applications and the Application Procedures
  13. Data Protection Provisions Concerning the Application and use of Facebook
  14. Data Protection Provisions Concerning the Application and use of Google Analytics
  15. Data Protection Provisions Concerning the Application and use of Google+
  16. Data Protection Provisions Concerning the Application and use of Jetpack for WordPress
  17. Data Protection Provisions Concerning the Application and use of LinkedIn
  18. Data Protection Provisions Concerning the Application and use of Twitter
  19. Data Protection Provisions Concerning the Application and use of YouTube
  20. Legal Basis for the Processing
  21. The Legitimate Interests Pursued by the Controller or by a Third Party
  22. Period for which the Personal Data will be Stored
  23. Provision of Personal Data as Statutory or Contractual Requirement
  24. Existence of Automated Decision Making

1. Definitions

Provident CRM bases its data protection declaration on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable to the general public, as well as our customers and business partners. To ensure this, we would like first to explain the terminology used.

In this data protection declaration, we use, among other things, the following terms:

Personal Data

Personal data refers to any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data Subject

A Data Subject is an identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of Processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling refers to any form of automated processing of personal data; constituting the use of personal data to evaluate specific personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, lifestyle, orientation, interests, reliability, behaviour, location or movements.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that it can no longer be attributed to a specific data subject without the use of additional information; provided that such additional information is kept separately and is subject to technical and organisational safeguards to ensure that said personal data is not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing

The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other bodies which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor

The processor is a natural or legal person, public authority, agency or other bodies that process personal data on behalf of the controller.

Recipient

The recipient is a natural or legal person, public authority, agency or other bodies, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third party

A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons; who, under the direct authority of the controller or processor, is authorised to process personal data.

Consent

The consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes through which they, by a statement or a clear affirmative action, signify agreement to the processing of personal data relating to themselves.


2. Name and Address of the Controller

The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in member states of the European Union, including the Irish Data Protection Act 2018, and other provisions related to data protection is:

Unit 1, The CHQ Building,
Custom House quay,
North Dock,
Dublin 1
Eircode: D01 Y6H7 Dublin – Ireland
+353 (0)1 693 0000
+44 203 411 6799

Email: infsec@providentcrm.com
Website: www.providentcrm.com


3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Mr Gary Seery

Unit 1, The CHQ Building,
Custom House quay,
North Dock,
Dublin 1
Eircode: D01 Y6H7 Dublin – Ireland
+353 (0)1 693 0000
+44 203 411 6799

Email: infsec@providentcrm.com
Website: www.providentcrm.com

Data subjects are free to contact our Data Protection Officer directly with any questions and suggestions they may have concerning data protection.


4. Cookies

The Provident CRM website uses cookies. Cookies are text files that are stored on a device (such as a computer or smartphone) via an internet browser.

Many websites and servers use cookies. Many cookies contain a unique identifier often called a “cookie ID”; consisting of a character string through which websites and servers can be assigned to the specific browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognised and identified using said unique cookie ID.

Through the use of cookies, Provident CRM can provide website visitors with more user-friendly services than would be possible without the cookie setting.

Using a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us, as previously mentioned, to recognise our website users; the purpose of which is to make it easier for users to utilise our website’s resources.

For example, a website visitor that uses cookies does not have to enter access data each time they visit, because this is taken over by the website, and the cookie is thus stored on the user’s computer/device. Another example is the cookie of a shopping cart for an online retailer; The retailer’s website remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the use of cookies from our website through a corresponding setting on their internet browser, and may thus permanently deny the allocation of cookies. Further, cookies may be deleted at any time through an internet browser’s settings or with other software programs. This is possible with all major internet browsers. If the data subject disables cookies in their internet browser not all functions on our website may be entirely visible or usable.


5. Collection and Processing of General Data/Information

The Provident CRM website collects general data/information when a data subject or automated system opens the website. This general data/information is stored in the server log files and may include:

  1. The browser types and versions used.
  2. The operating system used by the accessing system.
  3. The website and sub-site from which an accessing system reaches our website (so-called referrers).
  4. The date and time of access to the website.
  5. The internet protocol address (IP address).
  6. The internet service provider (ISP) of the accessing system.
  7. Any other similar data and information that may be used in the event of attacks on our computer/devices.

When using this general data/information, Provident CRM does not draw any conclusions about the data subject. Rather, this information is required to:

  1. Deliver the content of our website correctly.
  2. Optimise the content of our website as well as its advertisement.
  3. Ensure the long-term viability of our computer/devices and website technology.
  4. Provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Thus, Provident CRM analyses anonymously collected data and information statistically, with the aim of maintaining and improving the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. Anonymous data from the server log files are stored entirely separately from personal data provided by data subjects.

Third-Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”


6. Subscription to our Newsletter

Users can subscribe to our newsletter on the Provident CRM website. The input mask used for this purpose determines what personal data is transmitted, as well as when the newsletter is ordered from the controller.

Provident CRM newsletters may only be received by the data subject if:

  1. The data subject has a valid email address.
  2. The data subject subscribes to the newsletter.

A confirmation email will be sent to the address registered by the subscribing data subject to validate a double opt-in. This confirmation email is used to prove whether the owner of the email address, as the data subject, has elected to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of registration, including a time stamp. The collection of this data is necessary in order to record the possible misuse of the data subject’s email address, and legally protect the data controller.

Personal data collected as part of a newsletter subscription will only be used to send our newsletter. Additionally, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. Subscription to our newsletter can be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for receiving the newsletter, may be revoked at any time. For revocation of consent, a corresponding link is included in each newsletter. It is also possible to unsubscribe from the newsletter at any time through the Provident CRM website or to communicate this to the controller in a different way (i.e., by telephone).


7. Newsletter-Tracking

The Provident CRM newsletters contain tracking pixels (miniature graphics embedded in emails sent in HTML format to enable log file recording and analysis), which enable a statistical analysis of the success or failure of online marketing campaigns. Through the embedded tracking pixels, Provident CRM can see if and when an email was opened by a data subject and which links in the email they clicked.

Personal data collected by the newsletter tracking pixels are stored and analysed by the controller to optimise the delivery of the newsletter, as well as to adapt and improve the content of future newsletters to better represent the interests of the data subject. This personal data is not passed on to third parties. Data subjects can at any time to revoke the respective separate declaration of consent issued through the double-opt-in procedure.


8. Contact Possibility via the Website

The Provident CRM website contains information that enables quick electronic contact with our organisation, as well as direct communication with us, including a general email address. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.


9. Subscription to Comments in the Website Blog

The comments made on the Provident CRM blog may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following their comments on a particular blog post.

If a data subject decides to subscribe to this option, the controller will send an automatic confirmation email to confirm the double opt-in procedure as to whether the owner of the specified email address validated this option. The option to subscribe to comments may be terminated at any time.


10. Routine Erasure and Blocking of Personal Data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with legal requirements.


11. Rights of the Data Subject

 

Right of Confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning them has been or is being processed. If a data subject wishes to avail themselves of this right of confirmation they may, at any time, contact any employee of the controller.

Right of Access

Each data subject shall have the right granted by the European legislator to obtain, from the controller, free information about their personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  1. The purposes of the processing.
  2. The categories of personal data concerned.
  3. The recipients or categories of recipients to whom the personal data have been or will be disclosed; in particular, recipients in third countries (i.e., countries outside of the EU) or international organisations.
  4. Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period.
  5. The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing.
  6. The existence of the right to lodge a complaint with a supervisory authority
  7. Where the personal data is not collected from the data subject, any available information as to its source.
  8. The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data is transferred to a third country or an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

With regards to third countries, Provident CRM does not transfer any personal data outside of the EU without obtaining the express written consent of the data subject.

If a data subject wishes to avail themselves of this right of access, they may, at any time, contact any employee of the controller. Although subject access requests may be made verbally, we would recommend that requests be emailed to the Data Protection Officer at Provident CRM: infsec@providentcrm.com

Right to Rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may, at any time, contact any employee of the controller.

Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning themselves without undue delay, and the controller shall have an obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  1. The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
  2. The data subject withdraws consent for which the processing is based, according to point (a) of Article 6(1) or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  3. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  4. The personal data has been unlawfully processed.
  5. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  6. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Provident CRM, they may, at any time, contact any employee of the controller. An employee of Provident CRM shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, their personal data, as far as processing is not required. An employee of Provident CRM will arrange the necessary measures in individual cases.

Right to Restriction of Processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  2. The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of its use instead.
  3. The controller no longer needs the personal data for the purposes of processing, but it is required by the data subject for the establishment, exercise or defence of legal claims.
  4. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Provident CRM, they may at any time contact any employee of the controller. The employee of Provident CRM will arrange the restriction of processing.

Right to Data Portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning themselves, which was provided to a controller, in a structured, commonly used and machine-readable format. They shall have the right to transmit this data to another controller without hindrance from the original controller to which the personal data has been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercising of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of Provident CRM.

Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to the processing of personal data concerning themselves, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Provident CRM shall no longer process the data subject’s personal data in the event of an objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If Provident CRM processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning themselves for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Provident CRM’s processing for direct marketing purposes, Provident CRM will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning themselves by Provident CRM for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of Provident CRM. Additionally, the data subject is free in the context of the use of information society services, and, notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications.

Automated Individual Decision Making, Including Profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject, or similarly significantly affects them, as long as the decision:

  1. is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or
  2. is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or
  3. is not based on the data subject’s explicit consent

If the decision:

  1. is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or
  2. it is based on the data subject’s explicit consent

Provident CRM shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, and at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact any employee of Provident CRM.

Right to Withdraw Data protection Consent

Each data subject shall have the right granted by the European legislator to withdraw their consent to the processing of their personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, they may, at any time, contact any employee of Provident CRM.


12. Data Protection for Applications and the Application Procedure

The data controller shall collect and process the personal data of applicants for the purpose of processing the application procedure. The processing may also be carried out electronically; which is the case if an applicant submits corresponding application documents by email or by means of a web form on the controller’s website.

If the data controller executes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is agreed with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Another legitimate interest in this relation is, for example, a burden of proof in a procedure under the Employment Equality Act.


13. Data Protection Provisions Concerning the Application and use of Facebook

On this website, the controller has integrated components of the Facebook social network.

A social network is a place for social meetings on the internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each visit to one of the individual pages of this website, which is operated by the controller and into which a Facebook component (Facebook plug-in) was integrated, the web browser on the computer/device of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is informed of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects every visit to our website by the data subject and, for the entire duration of their stay on our website, which specific sub-site of our webpage was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the visit to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then they can prevent this by logging off from their Facebook account before visiting our website.

The data protection guideline published by Facebook, available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it explains there what setting options Facebook offers to protect the privacy of the data subject. And also, different configuration options available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.


14. Data Protection Provisions Concerning the Application and use of Google Analytics

(with anonymization function)

On the Provident CRM website, the controller has integrated a component of Google Analytics (with the anonymization function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, among other things, data about the website from which a person has come (the referrer), which sub-pages were visited, and how often and for what duration a sub-page was viewed. Web analytics are mainly used for website optimisation and in order to carry out an internet advertising cost-benefit analysis.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For web analytics, through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application, the IP address of the data subject’s internet connection is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information to, among other things, evaluate the use of our website and to provide online reports showing the activity on our websites, and to provide other services concerning the use of our website for us.

Google Analytics places a cookie on the computer/device of the data subject, which enables Google to analyse the use of our website. With each visit to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component was integrated, the data subject’s browser will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, Google gains knowledge of personal information, such as the IP address of the data subject, which allows Google, among other things, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our website, such personal data, including the IP address of the internet access used by the data subject, will be transmitted to Google in the United States of America, where this personal data is stored. Google may pass this personal data to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of their web browser and thus permanently deny the setting of cookies. Such an adjustment to their browser settings would also prevent Google Analytics from setting a cookie on the computer/device of the data subject. Additionally, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

Also, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such use. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through JavaScript that any data and information about the visits of web pages may not be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the computer/device of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.


15. Data protection provisions concerning the application and use of Google+

On the Provident CRM website, the controller has integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.

The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each visit to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the internet browser on the computer/device of the data subject automatically downloads a display of the corresponding Google+ button of Google through the respective Google+ button component. During the course of this procedure, Google is made aware of what specific sub-page of our website was visited by the data subject. More detailed information about Google+ is available under https://developers.google.com/+/.

If the data subject is logged in at the same time to Google+, Google recognizes with each visit to our website by the data subject and, for the entire duration of their stay on our website, which specific sub-pages of our site were visited by the data subject. This information is collected through the Google+ button and Google matches this with the respective Google+ account associated with the data subject.

If the data subject clicks on the Google+ button integrated on our website and thus gives a Google+ 1 recommendation, then Google assigns this information to the personal Google+ user account of the data subject and stores their personal data. Google stores the Google+ 1 recommendation of the data subject, making it publicly available in accordance with the terms and conditions accepted by the data subject in this regard. Subsequently, a Google+ 1 recommendation given by the data subject on this website together with other personal data, such as the Google+ account name used by the data subject and the stored photo, is stored and processed on other Google services, such as search engine results of the Google search engine, the Google account of the data subject or in other places, e.g. on web pages, or in relation to advertisements. Google is also able to link the visit to this website with other personal data stored on Google. Google further records this personal information with the purpose of improving or optimising various Google services.

Through the Google+ button, Google receives information that the data subject visited our website if the data subject is logged into Google+. This occurs regardless of whether the data subject clicks or doesn’t click on the Google+ button.

If the data subject does not wish to transmit personal data to Google, they may prevent such transmission by logging out of their Google+ account before calling up our website.

Further information and the data protection provisions of Google may be found under https://www.google.com/intl/en/policies/privacy/. More references material from Google about the Google+ 1 button may be obtained under https://developers.google.com/+/web/buttons-policy.


16. Data Protection Provisions Concerning the Application and use of Jetpack for WordPress

On this website, the controller has integrated Jetpack. Jetpack is a WordPress plug-in, which provides additional features to the operator of a website based on WordPress. Jetpack provides an overview of the visitors to the site. By displaying related posts and publications, or the ability to share content on the page, it is also possible to increase visitor numbers. In addition, security features are integrated into Jetpack, so a Jetpack-using site is better protected against attacks. Jetpack also optimises and accelerates the loading of images on the website.

The operating company of Jetpack Plug-Ins for WordPress is Automattic Inc., 132 Hawthorne Street, San Francisco, CA 94107, UNITED STATES. The operating enterprise uses the tracking technology created by Quantcast Inc., 201 Third Street, San Francisco, CA 94103, UNITED STATES.

Jetpack places a cookie on the computer/device used by the data subject. The definition of cookies is explained above. With each visit to one of the individual pages of this website, which is operated by the controller and on which a Jetpack component was integrated, the internet browser on the data subject’s computer/device is automatically prompted to submit data through the Jetpack component for analysis purposes to Automattic. During the course of this procedure, Automattic receives data that is used to create an overview of website visits. Data obtained in this way is for analysis of the behaviour of the data subject, with access to the webpage of the controller and is analysed with the aim of optimising the website. The data collected through the Jetpack component is not used to identify the data subject prior to obtaining a separate express consent agreement from the data subject. The data comes also to the notice of Quantcast. Quantcast uses the data for the same purposes as Automattic.

The data subject can, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment on their web browser used to permanently deny the setting of cookies. Such an adjustment to said internet browser used would also prevent Automattic/Quantcast from setting a cookie on the computer/device of the data subject. Also, cookies already in use by Automattic/Quantcast may be deleted at any time via a web browser or other software programs.

In addition, the data subject can object to a collection of data relating to a use of this website through the generation of a Jetpack cookie as well as the processing of these data by Automattic/Quantcast and the chance to prevent any such. To achieve this, the data subject must press the ‘opt-out’ button under the link https://www.quantcast.com/opt-out/ which sets an opt-out cookie. The opt-out cookie set with this purpose is placed on the computer/device used by the data subject. If the cookies are deleted on the data subject’s system, then the data subject must follow the link again and set a new opt-out cookie.

With the setting of the opt-out cookie, however, the possibility exists that the websites of the controller are no longer fully usable by the data subject.

The applicable data protection provisions of Automattic may be accessed under https://automattic.com/privacy/. The applicable data protection provisions of Quantcast can be accessed under https://www.quantcast.com/privacy/.


17. Data Protection Provisions Concerning the Application and use of linkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each visit to one of the individual pages of this website, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the internet browser on the computer/device of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged into LinkedIn at the same time, LinkedIn detects every visit of our website by the data subject and, for the entire duration of their stay on our website, which specific sub-page of our site was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the visit to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then they may prevent this by logging off from their LinkedIn account before visiting our website.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from email messages, SMS messages and targeted ads, as well as the ability to manage advertisement settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy.


18. Data Protection Provisions Concerning the Application and use of Twitter

On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread ‘tweets,’ e.g. short messages, which are limited to 280 characters. These short messages are available to everyone, including those who are not logged onto Twitter. The tweets are also displayed to ‘followers’ of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each visit to one of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the internet browser on the computer/device of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://developer.twitter.com/en/docs/twitter-for-websites/tweet-button/overview.html. During the course of this procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged into Twitter at the same time, Twitter detects every visit to our website by the data subject and, for the entire duration of their stay on our website, which specific sub-page of our website was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the visit to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then they may prevent this by logging off from their Twitter account before a visit to our website is made.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/en/privacy.


19. Data Protection Provisions Concerning the Application and use of YouTube

On this website, the controller has integrated components of YouTube. YouTube is an internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the internet portal.

The operating company of YouTube is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each visit to one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the internet browser on the computer/device of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged into YouTube, YouTube recognizes with each visit to a sub-page that contains a YouTube video, which specific sub-page of our website was visited by the data subject.This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website if the data subject at the time of the visit to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs out of their own YouTube account before a visit to our website is made.

YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.


20. Legal Basis for the Processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR.

The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third parties. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. They considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).


21. The Legitimate Interests Pursued by the Controller or by a Third Party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.


22. Period for which the Personal Data will be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.


23. Provision of Personal Data as a Statutory or Contractual Requirement

Including Requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; and possible consequences of failure to provide such data.

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for the completion of a contract that the data subject provides Provident CRM with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be completed. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law, or contract, or is necessary for the execution of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.


24. Existence of Automated Decision Making

As a responsible company, we do not use automatic decision-making or profiling.