Data protection

Privacy Notice solutions.cht.com

1.Introduction

We would like to use the information below to provide you “data subject” with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent.

Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the “CHT Germany GmbH”. The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process.

As the data controller, we have implemented numerous technical and organisational measures to ensure the most complete possible protection of the personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps so that absolute protection cannot be guaranteed. For this reason, you are free to submit personal data on alternative ways, such as by phone or by post to us.

2. Data controller

The data controller, as defined by the GDPR, is:

CHT Germany GmbH
Bismarckstraße 102, 72072 Tübingen, Deutschland

Data controller’s representative:

3. Data protection officer

You can reach the data protection officer as follows:

Data protection officer of CHT Germany GmbH
c/o TÜV SÜD Akademie GmbH
Westendstraße 160
80339 München
data-protection@cht.com

You may contact our data protection officer directly at any time if you have any questions or suggestions regarding data protection.

4. Legal basis for processing

Art. 6 Paragraph 1 a GDPR serves as our company’s legal basis for processing operations in 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 you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, processing is based on Article 6 Paragraph 1 b GDPR The same applies to those processing operations required to carry out pre-contractual measures, such as in cases of queries regarding our products or services.

If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfilment of tax obligations, processing is based on Article 6 Paragraph 1 c GDPR.

In rare cases, 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 someone visiting our business were to be injured and their name, age, health insurance data or other vital information needed to be disclosed to a doctor, hospital or other third party. Processing would then be based on Article 6 Paragraph 1 d GDPR.

Finally, processing operations could be based on Article 6 Paragraph 1 f GDPR. Processing operations not based on any of the above-mentioned legal bases may be carried out on the basis of Article 6 Paragraph 1 f GDPR if processing is necessary to safeguard the legitimate interests of our company or those of a third party, provided the interests and fundamental rights and freedoms of the data subject do not take precedence. We are permitted to engage in such processing operations in particular because they have been specifically mentioned in European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47 Sentence 2 GDPR).

Our offer is basically directed at adults. Persons under 16 years of age may not transmit any personal data to us without the consent of their parents or legal guardians. We do not request personal data from children and young people, do not collect it and do not pass it on to third parties.

5. Transmission of data to third parties

We do not transfer your personal data to third parties for purposes other than those listed below.

We only pass on your personal data to third parties if:

1. you have given us your express consent to do so in accordance with Article 6 Paragraph 1 a GDPR,
2. the disclosure is permissible under Article 6 Paragraph 1 f GDPR to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
3. in the event that a legal obligation exists for the disclosure pursuant to Article 6 Paragraph 1 c GDPR,
and 4. this is legally permissible and necessary according to Article 6 Paragraph 1 b GDPR for the processing of contractual relationships with you.

As part of the processing operations described in this Privacy Policy, personal data may be transferred to the USA. The USA does not have an adequate level of data protection (ECJ: Schrems II ruling). In particular, U.S. investigative authorities can oblige U.S. companies to hand over or disclose personal data without the data subjects being able to effectively take legal action against this. Thus, in principle, there is a possibility that your personal data will be processed by U.S. investigative authorities. We have no influence on these processing activities. To protect your data, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent can serve as a legal basis for the transfer to third countries in accordance with Article 49 Paragraph 1 a GDPR. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Article 45 GDPR.

6. Technology

6.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login details or contact requests that you send to us as the website operator. You can recognise an encrypted connection by your browser’s address bar reading “https://” instead of “http://” and the lock symbol in the browser bar.

We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website

If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data your browser sends our server (in what is known as “server log files”). Our website collects a range of general data and information each time you access a website or an automated system. This general data and information is stored in the server’s log files.
It may be collected:

1. the browser types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system accesses our website (called a referrer),
4. the sub-pages accessed via an accessing system on our website,
5. the date and time the website is accessed,
6. an internet protocol address (IP address) and
7. the accessing system’s internet service provider.

No conclusions are drawn about you when using this general data and information. Instead, this information is needed to

1. properly deliver our website content,
2. to optimise the content of the website as well as to advertise it,
3. to ensure the continued functioning of our information technology systems and our website’s technology as well as to
4. provide the information necessary for law enforcement authorities to prosecute in the event of a cyber-attack.

This collected data and information is therefore statistically analysed and further analysed by us with the aim of increasing data protection and data security within our company to ultimately ensure an optimum level of protection for the personal data being processed by us. The data from the server log files is stored separately from all personal data provided by a data subject.

The legal basis for data processing is Article 6 Paragraph 1 f Sentence 1 GDPR. Our legitimate interest is based on the purposes listed above for the collection of data.

7. Cookies

7.1 General information about cookies

We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our website.

Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity.

The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are deleted automatically when you leave our website.

We also use temporary cookies to optimise user-friendliness. These cookies are stored on your device for a specific period of time. If you return to our website to use our services, cookies allow us to automatically recognise that you have visited our website previously and remember the inputs and settings you have made so that you do not have to enter them again.

We also use cookies to statistically record the use of our website and analyse it for the purpose of optimising our services. These cookies allow us to automatically recognise that you have already visited our website when you visit our website again. These cookies are automatically erased after a defined period of time. The respective storage period of the cookies can be taken from the settings of the consent tool used.

7.2 Legal basis for the use of cookies

The data processed by cookies, which are required for the proper functioning of the website, are to safeguard our legitimate interests pursuant to Article 6 Paragraph 1 f GDPR.

For all other cookies you have given your consent to this through our opt-in cookie banner in accordance with Article 6 Paragraph 1 a GDPR.

7.3 Hints for avoiding cookies in common browsers

You have the option of deleting cookies, only allowing selected cookies or completely deactivating cookies at any time via the settings of the browser you are using. You can find more information on the support pages of the respective providers:

7.4 Cookiebot (Consent Management Tool)

We use the consent management tool “Cookiebot” from Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark. This service allows us to obtain and manage the consent of website visitors to data processing.

Cookiebot collects data generated by end users who use our website. When an end user gives consent via the cookie consent tool, Cookiebot automatically logs the following data:

The IP number of the end user in anonymized form (the last three digits are set to 0).
Date and time of consent.
User agent of the end user’s browser.
The URL from which the consent was sent.
An anonymous, random and encrypted key.
The consent status of the end user, which serves as proof of consent.

The key and consent status are also stored in the end user’s browser in the cookie “CookieConsent” so that the website can automatically read and follow the end user’s consent in all subsequent page requests and future end user sessions for up to 12 months. The key is used for proof of consent and for an option to verify that the consent status stored in the end user’s browser is unchanged from the original consent submitted to Cybot.

The functionality of the website is not guaranteed without the processing. The “CookieConsent” cookie set by Cookiebot is classified as necessary.

Cybot is a recipient of your personal data and acts as a processor for us.

Detailed information on the use of Cookiebot can be found at: https://www.cookiebot.com/en/privacy-policy/.

8. Our activities in social networks

To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks If you visit one of our social media pages, we and the provider of the social media network are joint controllers (Art. 26 GDPR) regarding to the processing operations triggered thereby, which concern personal data.

We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers.
We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behaviour by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behaviour may be assigned directly to your own member profile on the respective social network (if you are logged in).

The processing operations of personal data described are carried out in accordance with Article 6 Paragraph 1 f GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Article 6 Paragraph 1 a GDPR in conjunction with Article 7 GDPR.

Since we have no access to these providers’ databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt out) is listed below for each of the social network providers we use:

8.1 Instagram

(Jointly) Data controller responsible for data processing in Europe:
Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Privacy Notice (Data Policy):
https://instagram.com/legal/privacy/

8.2 LinkedIn

(Jointly) Data controller responsible for data processing in Europe:
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland

Privacy Notice:
https://www.linkedin.com/legal/privacy-policy

8.3 YouTube

(Jointly) Data controller responsible for data processing in Europe:
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Privacy Notice:
https://policies.google.com/privacy

8.4 XING (New Work SE)

(Jointly) Data controller responsible for data processing in Europe:
New Work SE, Am Strandkai 1, 20457 Hamburg, Deutschland

Privacy Notice:
https://privacy.xing.com/de/datenschutzerklaerung

Requests for information for XING members:
https://www.xing.com/settings/privacy/data/disclosure

9. Your rights as a data subject

9.1 Right to confirmation

You have the right to request confirmation from us as to whether personal data relating to you will be processed.

9.2 Right to information (Article 15 GDPR)

You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.

9.3 Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

9.4 Erasure (Article 17 GDPR)

You have the right to demand that we erase the personal data relating to you be deleted without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.

9.5 Restriction to processing (Article 18 GDPR)

You have the right to request that we restrict the processing of your data if one of the legal requirements is met.

9.6 Data transferability (Article 20 GDPR)

You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Article 6 Paragraph 1 a GDPR or Article 9 Paragraph 2 a GDPR or on a contract pursuant to Article 6 Paragraph 1 b GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us.

Furthermore, when exercising your right to data transferability pursuant to Article 20 Paragraph 1 GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.

9.7 Objection (Article 21 GDPR)

You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Article 6 Paragraph 1 e (data processing in the public interest) or (f) (data processing on the basis of the weighing of legitimate interests) GDPR.

This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR.

Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.

In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose.

In addition, you have the right to object to our processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89 Paragraph 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest.

You are free to exercise your right to lodge an objection in relation to the use of information society services, Directive 2002/58/EC notwithstanding, by means of automated procedures using technical specifications.

9.8 Revocation of consent regarding data protection

You have the right to revoke any consent to the processing of personal data at any time with future effect.

9.9 Lodging a complaint with a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.

10. Routine storage, erasure and blocking of personal data

We process and store your personal data only for the period of time necessary to meet the storage purpose or as required by the legal provisions to which our company is subject.

If the storage purpose no longer applies or if a required retention period expires, personal data will be routinely blocked or erased in accordance with the statutory provisions.

11. Duration of storage of personal data

The criterion for the duration of the retention of personal data is the respective legal retention period. Once this period expires, the data in question will be routinely erased, provided it is no longer required for the fulfilment or initiation of the contract.

12. Version and amendments to the Privacy Notice

This Privacy Notice is currently valid and was last updated on June 2023.

It may be necessary for us to amend this Privacy Notice in the process of further developing our website and the services we offer through our website or due to changes in legal or regulatory requirements. You can view and print our current Privacy Notice on the website at any time by visiting ” https://sustainability-report.cht.com/en/datenschutz/”.

This privacy statement has been prepared with the assistance of the privacy software TÜV SÜD DSMS.

REPORTING PERIOD: JANUARY 1st TO DECEMBER 31st, 2022(EDITORIAL DEADLINE MAY 31st, 2023)

REPORTING PERIOD: January 1<sup>st</sup> to december 31<sup>st</sup>, 2022 (editorial deadline may 31<sup>st</sup>, 2023)