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Privacy Policy for Customers and Users of 100 Worte in accordance with the EU General Data Protection Regulation (GDPR)

(Current as of June 17, 2022)

Introduction

The European Union, in the context of the introduction of the General Data Protection Regulation (GDPR), redefined the framework conditions for the handling of personal data as of May 2018. Since data protection is of the highest priority for 100 Worte Sprachanalyse GmbH (hereinafter “100Worte”), every processing of personal data is carried out in accordance with the new regulation as well as the corresponding provisions of the Federal Data Protection Act (BDSG).

With this privacy policy, our company aims to inform the public and affected individuals about the type, scope, and purpose of the personal data we collect, use, and process about those affected in accordance with Article 13 GDPR, and to inform you about your rights.

Structure of the Privacy Policy

This privacy policy is structured as follows:

  • Overview (A): Defines important terms, responsible parties, contact persons, data recipients, rights, and storage duration.
  • Detailed Processing Activities (B): Explains in detail the processing activities carried out by 100Worte, including data scope, purpose, and legal bases.
  • Selected Processors (C): Provides information about the processors chosen by 100Worte.

100Worte has implemented numerous measures to ensure the most comprehensive protection of personal data.

A) Overview

In this privacy policy, we use the terms defined in Article 4 of the GDPR: personal data, data subject, processing, restriction of processing, pseudonymization, controller, processor, recipient, third party, and consent. Definitions can be found, for example, at https://dsgvo-gesetz.de/art-4-dsgvo/.

Since 100Worte is a company specialized in data processing in the B2B sector, we have similarly defined additional terms to facilitate your understanding of the following explanations:

  • Publicly Available Data: Defined by 100Worte in the sense of Art. 14 para. 2 f GDPR as all data, information, and entries that are accessible or viewable by anyone through public sources directly (e.g., via a link) or indirectly (e.g., through a query). Examples include websites, news portals, blog articles, publicly shared posts and profiles from social media, as well as public databases from specialist portals, the commercial register, the Federal Gazette, or Wikipedia.

  • Business-related Data: Defined by 100Worte as data with a business context if it can be associated with a business purpose, such as addressing customers, prospects, or talents. For example, a processed message may contain the name of the company, as well as the names of the sender and recipient; likewise, a public social media profile (e.g., on LinkedIn) may contain the employer's name.

A1) Controller / Data Protection Officer

Responsible Entity: The management of 100 Worte Sprachanalyse GmbH.

Contact Details for the Data Protection Officer:

Name First Name Phone Email
Tschürtz Simon +49 16096696826 simon.tschuertz@100worte.de
DataCo GmbH N/A 089 442 550 - 62649 kontakt@dataguard.de

A2) What Sources and Data Does 100Worte Use for What Purpose?

If 100Worte collects personal data directly from you as the data subject, this is done for one of the following three reasons:

  1. You visit the 100Worte website.
  2. You are an interested party and have submitted data to us as part of an inquiry/contact.
  3. You have registered as a user with 100Worte or are a customer under a contractual relationship.

Using the websites of 100Worte is generally possible without providing any personal data. However, in this case, data about your usage behavior is collected. Which data is collected for what purpose and how you can prevent this is explained in section B1. In the case of interested parties, all data you have transmitted to us as part of your inquiry is added. Depending on the content of your inquiry, this can be brief or very extensive; more information is provided in section B2. As a registered user or customer of 100Worte, we add to the previously mentioned data information relevant to fulfilling your contract, such as billing data. Further details are available in section B3.

A3) On What Legal Basis Are Data Processed?

We process the aforementioned personal data in accordance with the legal provisions of the GDPR and the Federal Data Protection Act (BDSG):

  • For the Fulfillment of Contractual Obligations pursuant to Art. 6 para. 1 b GDPR:

    The processing of personal data takes place within the framework of the execution of our contracts with our customers or for the execution of pre-contractual measures. The purposes of data processing are primarily determined by the specific product and may include needs analyses, consulting, providing online software, or processing application documents. All details of each processing activity can be found in section B.

  • Legitimate Interests pursuant to Art. 6 para. 1 f GDPR:

    Where necessary, we process your data already before entering into or fulfilling a contract or even beyond that to protect the legitimate interests of us or third parties. Examples include:

    • Operation of our website and optimization of our online offerings.
    • Examination and optimization of customer engagement procedures.
    • Advertising, marketing, and sales, provided you have not objected to the use of your data.
    • Market and opinion research, provided you have not objected to the use of your data.
    • Assertion of legal claims and defense in legal disputes.
    • Ensuring IT security and IT operations; elimination of errors and disruptions.
    • Prevention of crimes.
    • Business and risk management measures and controlling.
    • Development of services and products.
    • Event management.

    Further processing activities according to this legal basis are appropriately marked in section B.

  • Consent pursuant to Art. 6 para. 1 a GDPR:

    Where you have given us consent to process personal data for specific purposes, the legality of this processing is based on your consent. A given consent can be revoked at any time. This also applies to the revocation of consent declarations made before the applicability of the GDPR, i.e., before May 25, 2018, made to us. Please note that the revocation only affects future processing. Processing activities carried out before the revocation are not affected.

    The classic example of an explicit consent is receiving newsletters as described in B2.4. Other processing activities in section B also rely on this legal basis.

  • Legal Obligations pursuant to Art. 6 para. 1 c GDPR:

    If 100Worte is legally obligated to process certain data, personal data may also be involved. An example of this is the legal retention obligations for billing data as described in section B3.5.

A5) Deletion and Retention Periods

We process and store your personal data as long as it is necessary to fulfill our contractual and legal obligations. It should be noted that our business relationship is a long-term obligation, which is planned for several years. If the data is no longer required for fulfilling contractual or legal obligations, it is regularly deleted unless a given consent exists beyond the end of the contract or a balancing of interests results in a legitimate interest of 100Worte in further storage, which outweighs the expected restrictions on the data subject. However, the legislator's intention of data minimization must be taken into account. Detailed information on the storage duration of individual processing activities can be found in section B.

A6) Who Receives My Data / Who Are the Recipients?

Recipients of the data collected about data subjects are:

  • The respective employees of 100Worte (e.g., from customer service, sales, HR, or IT).
  • The processors commissioned by 100Worte (service providers, tool providers, and vicarious agents – for a detailed list see section C).

In the event that you have given us consent (e.g., if you provide a reference for 100Worte), other users or interested parties of 100Worte may also receive the respective data (e.g., their name, position, and a quote). Additionally, public authorities may be recipients who must receive data due to legal provisions or other reasons (e.g., court order).

A7) Own Data Processing by 100Worte in Germany

If 100Worte stores or processes data itself, this is done exclusively on self-managed servers hosted in selected German data centers (see section “C. Hosting” for details).

A8) Transfer to Third Countries / Processing of Data by External Services

When selecting suitable service providers for external data processing, we only work with vetted and, if necessary, certified providers who are committed to complying with European data protection regulations and the national data protection laws. We check whether an appropriate certification for secure data handling exists. If the European Commission has not determined the presence of an adequate level of protection for a third country, we ensure adequate guarantees to protect your data adequately. This can be done, for example, by entering into data processing agreements containing EU standard data protection clauses (2010/87/EU and/or 2004/915/EG), which, in the opinion of the European Commission, provide adequate guarantees (available here). All service providers where a transfer of personal data to third countries is possible are separately listed in section C). Furthermore, all companies processing data on our behalf (processors) are contractually obligated through a data processing agreement (DPA). All relevant processors can be found under section C.

A9) Data Subject Rights

Each data subject has the following rights under the GDPR:

  • Right of Access (Article 15 GDPR): To obtain confirmation as to whether personal data concerning them are being processed, and, where that is the case, access to the personal data and information about the processing.

  • Right to Rectification (Article 16 GDPR): To have inaccurate personal data corrected or completed if incomplete.

  • Right to Erasure (Article 17 GDPR): To have personal data erased in certain circumstances.

  • Right to Restriction of Processing (Article 18 GDPR): To request the restriction of processing under certain conditions.

  • Right to Object (Article 21 GDPR): To object to processing based on legitimate interests or for direct marketing purposes.

  • Right to Data Portability (Article 20 GDPR): To receive personal data in a structured, commonly used, and machine-readable format and to transmit those data to another controller.

Restrictions under §§ 34 and 35 BDSG apply to the right of access and the right to erasure. Additionally, there is the right to lodge a complaint with a data protection supervisory authority (Article 77 GDPR in conjunction with § 19 BDSG). Any consent given for the processing of personal data can be revoked at any time towards us. This also applies to the revocation of consent declarations made before the GDPR, i.e., before May 25, 2018, towards us. Please note that the revocation only affects future processing. Processing activities carried out before the revocation are not affected.

If you wish to exercise your right to lodge a complaint, please visit the website https://www.baden-wuerttemberg.datenschutz.de/ for more information.

A10) Waiver of “Profiling”

Profiling describes a type of automated processing of personal data that consists of evaluating, analyzing, or predicting certain personal aspects such as health or personal preferences. 100Worte refrains from automated decision-making and profiling that can have legal effects on you.

A11) Changes to Our Data Protection Provisions

We reserve the right to adapt this privacy policy to ensure it always meets legal requirements or to implement changes to our services in the privacy policy, e.g., when introducing new services.

B) Processing Activities

The processing activities of personal data take place in three different areas, which are elaborated in the following sections B1 – B3:

B1) Website Visitors and Users without Prior Registration

Using the websites and apps of 100Worte is generally possible without providing any personal data. However, in this case, data about your usage behavior is collected via various tools. Which data is collected for what purpose and how you can prevent this is explained in the following sections:

B1.1) Web Analytics

100Worte conducts various types of web analytics itself and with the help of external service providers (see section C1). The data collected serves different purposes for 100Worte:

Purpose:

The collected data is needed, among other things, to:

  1. Correctly deliver the content of our websites and apps.
  2. Optimize the content of our website and the advertising for it.
  3. Ensure the permanent functionality of our information technology systems and the technology of our website.
  4. Provide law enforcement authorities with the information necessary for prosecution in the event of a cyber-attack.
  5. Facilitate access and use of the web presence.
  6. Enhance the quality of the user experience.
  7. Maintain user-initiated sessions.

Collected Data:

The following data can be collected:

  1. The types and versions of browsers used.
  2. The type of device used by the accessing system, screen size, and operating system.
  3. The website from which an accessing system arrives at our website (so-called “referrer”).
  4. The subpages that are accessed via an accessing system on our website.
  5. The date and time of access to the website.
  6. An Internet Protocol (IP) address and, if applicable, the associated connection location.
  7. The Internet service provider of the accessing system.
  8. Other similar data and information that serve to defend against threats in the event of attacks on our information technology systems.

Although your name is not collected here, this data could still potentially be used to identify you.

Legal Basis for Web Analytics:

The legal basis for the techniques used (see below) and for processing the collected data is Art. 6 para. 1 lit. f GDPR. According to this, we have a legitimate interest in using the aforementioned collected data. Our interest arises from the purposes of use outlined above in “Purpose”. Through existing data processing agreements, we are also authorized to work with external service providers in processing. These providers, as mentioned, are committed to complying with the GDPR.

Storage Duration and Objection:

The duration of storage is determined by the respective statutory retention periods. After the expiration of the period, the corresponding data is routinely deleted, provided it is no longer necessary for the fulfillment or initiation of the contract and/or we do not have a legitimate interest in continued storage. Separate regulations are explained separately in the following sections.

Techniques Used:

For web analytics, we use various techniques on our website:

B1.1.a) Cookies

The websites of 100Worte use both first-party and third-party cookies. Cookies are text files that are stored on a computer system via a web browser. These allow us to recognize users of our website. Many cookies contain a so-called cookie ID, which consists of a string of characters that can be assigned to the specific web browser in which the cookie is stored. This enables us to distinguish the individual browser of the data subject from other web browsers that contain different cookies. A specific web browser can be recognized and identified via the unique cookie ID. By using cookies, 100Worte can provide users of this website with more user-friendly services that would not be possible without setting cookies.

Storage Duration and Objection Regarding Cookies:

The data subject can prevent the setting of cookies by our website at any time by setting the used web browser accordingly, thereby permanently objecting to the setting of cookies. Furthermore, already set cookies can be deleted at any time via a web browser or other software programs. This is possible in all common web browsers. If the data subject deactivates the setting of cookies in the used web browser, not all functions of our website may be fully usable. If a cookie is set, it is valid as long as this is sensible for the purpose of the cookie and in balancing with the rights of the data subject.

You can individually object to the setting of cookies by external providers via the links provided in sections C1 and C2.

B1.1.b) Log Files

The websites and software tools of 100Worte record a series of log data each time a data subject or an automated system accesses them. These are stored in the so-called “log files” of the respective server. The data and information thus collected are evaluated with the aim of ensuring operation and data protection and increasing the security of our systems. Only in this way can we ensure an optimal level of protection for the personal data we process. The storage duration depends on the category of the data collected and can range from a few hours to several months. The analysis of data from non-registered users is carried out in aggregated and/or anonymized form.

B1.1.c) Counting Pixels

100Worte uses counting pixels on its website for statistical purposes. For example, these are used to determine whether variant A or variant B leads to greater user satisfaction when optimizing websites.

A counting pixel is a miniature graphic embedded in a webpage to enable log file recording (see B1.1.b) and log file analysis to subsequently perform statistical evaluations.

B1.1.d) Pseudonymized User IDs

With the help of pseudonymized user IDs, it is possible to assign data, sessions, and interactions across multiple devices to a user and thus analyze their activities across devices. The pseudonymized user IDs are added to a cookie. Currently, this technique is only used by our advertising service providers, for example, to display 100Worte advertising to visitors of our site elsewhere at a later time.

B1.2) Advertising Service Providers

100Worte conducts advertising on the internet to draw attention to its own solutions and services. Examples include ads in search engines and in various advertising networks. If a data subject arrives at our website via an advertising ad, a so-called conversion cookie is set on the data subject’s information technology system by the advertising service provider or by 100Worte. Additionally, statistics can be collected using a counting pixel as described in B1.1.c. Various data are processed for different purposes during data collection:

Purpose:

The collected data is used, among other things, to:

  1. Display personalized advertising.
  2. Hide irrelevant advertising.
  3. Display advertising only to potential prospects.
  4. Measure the success of an advertising campaign.
  5. Improve future advertisements.
  6. Display interest-relevant advertising on third-party websites.

Collected Data:

In addition to the data already described in B1.1 (1) – (8), also (9) entry pages / exit pages and click paths, (10) the duration of visits to subpages, and (11) the frequency of recurring visits are collected.

Legal Basis:

The legal basis for the processing described here is Art. 6 para. 1 f GDPR. According to this, we have a legitimate interest in advertising for our company and using the described techniques. Our legitimate interest in processing the collected data arises from the outlined purposes of use.

Storage Duration and Objection:

In addition to the general rules described above, the following applies: A conversion cookie loses its validity after thirty days and does not serve to identify the data subject. The data subject can prevent the setting of cookies by our website at any time by setting the web browser accordingly, thereby permanently objecting to the setting of cookies.

B1.3) Content Delivery Networks (CDNs)

100Worte uses Content Delivery Networks (CDNs) to enable users to load the website faster and have a uniform display (purpose). Various standardized content, including:

  • Webfonts / fonts
  • Icons / icon fonts
  • JavaScript / CSS / and other so-called libraries

are provided by external CDN providers. When a page is accessed, your browser loads the necessary content into your browser cache to correctly display texts, icons, fonts, and interactive elements. The legal basis is also Art. 6 para. 1 lit. f GDPR.

With which external providers we work, what their serviceable addresses are, and what data is collected in the process (usually your IP address and the time of access), can be found in section C4.

B1.5) Video Player / Screensharing

We offer video content and screen sharing options on our website, for example, to show prospects a demonstration of our software or to provide applicants with an insight into our company (purpose). To do this, it is necessary for us to work with video platform providers. With which external video providers we work, what their serviceable addresses are, and what data is collected in the process (usually your IP address and the time of access), can be found in section C5. The legal basis is Art. 6 para. 1 lit. f GDPR.

B1.6) Use of Apps and Plugins

100Worte also offers its services via various external partners and platforms. In this case, registration is required to use them (see the regulations and legal bases from B3).

Below, we provide a brief overview of the classes:

B1.6.a) Browser Plugins

We offer our users the option to install 100Worte as an add-on/plugin directly into their browser (e.g., Chrome or Edge). This allows for a better user experience, as additional information from 100Worte can be loaded directly for the website currently accessed by the user (purpose). To make this possible, the user grants 100Worte access to data from their browser (e.g., the URLs of the accessed websites and tabs) with the installation. The legal basis is the user's consent upon installation in accordance with Art. 6 para. 1 lit. a GDPR. For data protection in their browser, please refer to the respective manufacturer (e.g., Google or Microsoft).

B1.6.b) Software Integrations

100Worte collaborates with various partners to enable the integration of 100Worte into their software (e.g., CRM systems like Salesforce or Microsoft Dynamics). If you install such an integration, we can display 100Worte information directly within these systems (purpose). To make this possible, the user grants 100Worte access to data from the software (e.g., communication information of the contact stored in the CRM). No personal data from the partner systems are stored by 100Worte. The legal basis is the user's consent upon installation in accordance with Art. 6 para. 1 lit. a GDPR. For data protection of the partner software itself, please refer to the manufacturer (e.g., Salesforce or Microsoft).

B2) Prospects Who Transmit Data to Us as Part of an Inquiry

If you contact 100Worte, send us an inquiry, or wish to use certain offers and services of our company, the processing of your personal data may be necessary. Examples include (but are not limited to):

  • Requesting a Whitepaper, Price List, or Other Document: You download a whitepaper from 100Worte, request a price list, or install one of our apps (purpose). You must fill out a web form and provide personal data. The personal data transmitted to 100Worte when submitting a form are determined by your entries in the respective form. Typically, we require certain personal and contact data as mandatory fields (name, email, phone, and your company).

    Additionally, information from web analytics (B1.1) is transmitted and attached to your inquiry (e.g., on which page you submitted the form, or whether you previously conducted a Google search). When submitting the form, you must consent to the processing of this data in accordance with the legal basis GDPR Art. 6 para. 1 a.

  • Subscribing to Our Newsletter: Users of 100Worte are given the option to subscribe to the company's newsletter. Personal data transmitted during newsletter subscription are determined by the signup form used. The newsletter informs customers, prospects, and business partners regularly about offers and current developments of the company (purpose).

  • Contacting Our Service or Sales Team: You contact our service team or sales team via email, phone, or other means, providing necessary personal data to facilitate communication and service provision.

  • Applying for a Job: You apply for one of our job postings by submitting your application documents, including your resume (purpose).

  • Testing Software or an App: You test our software or app and share your data with us to facilitate feedback and improvements (purpose).

When making such an inquiry by voluntarily providing personal data, you consent to the processing of your data based on the legal basis Art. 6 para. 1 a GDPR for the purpose of providing you with the requested content, information, or services. Furthermore, we may rely on Art. 6 para. 1 b GDPR for carrying out pre-contractual measures.

B2.1) Ways of Contacting

B2.1.a) Via Web Form

When you download a whitepaper, request a price list, or install one of our apps (purpose), you must fill out a web form and provide personal data. The personal data transmitted to 100Worte when submitting a form are determined by your entries in the respective form. Typically, we require certain personal and contact data as mandatory fields (name, email, phone, and your company).

Additionally, information from web analytics (B1.1) is transmitted and attached to your inquiry (e.g., on which page you submitted the form, or whether you previously conducted a Google search). When submitting the form, you must consent to the processing of this data in accordance with the legal basis GDPR Art. 6 para. 1 a.

B2.1.b) Via Email

If you communicate with 100Worte via email, e.g., through a central mailbox like info@100Worte.de or with a specific person in the company (person@100Worte.de), you transmit data such as your sender address, information contained in the content or your signature (e.g., your position and contact details), general data like the time of dispatch, and specific data you may transmit in an attachment (e.g., your resume in the case of job applications). Data transmitted to us in this way are processed electronically by 100Worte for the purpose of responding to and handling your inquiry in systems according to B2.3. We rely on Art. 6 para. 1 b GDPR and Art. 6 para. 1 f GDPR as the legal basis. Our legitimate interest is to ensure efficient service.

B2.1.c) Via Phone

If you talk to 100Worte or one of our employees by phone, we collect certain traffic and communication data such as the phone number used to connect. Our employees are also required to briefly log the content of the conversation in our systems (see B2.3). We rely on Art. 6 para. 1 f GDPR as the legal basis. The purpose and our legitimate interest in this data collection is to make our service more efficient.

B2.1.d) Via Mail

If you correspond with 100Worte by mail, we collect data on your sender address and can digitize the sent documents for faster processing (purpose) and store them in cloud storage systems (see B2.4). We rely on Art. 6 para. 1 f GDPR as the legal basis.

B2.1.e) Via Personal Contact

You can come into contact with 100Worte at events, lectures, or trade fairs and leave your data with us, for example, in the form of a business card. The data collected in this way are digitized by us by transferring them into our CRM system to record your visit and, if applicable, the content of the related conversation (purpose). We rely on Art. 6 para. 1 b GDPR and Art. 6 para. 1 f GDPR as the legal basis. Our legitimate interest is to be able to use the content of your visit when continuing the conversations later.

B2.1.f) Chat System or Social Media Channel

Furthermore, we offer the possibility to contact our advisors via a chat system or social networks. In doing so, we can receive various data about you, e.g., the IP address, the user profile, or the device number from which your inquiry originates, as well as data you provide in the content of your inquiry. 100Worte is entitled under Art. 6 para. 1 f GDPR to process this data and link it with already stored data (e.g., by saving the link to your XING profile) for the purpose of providing quick and consistent consulting quality across all channels. A detailed list of the external providers we use is available in section C.

B2.2) Verification and Enrichment of Your Data

To best answer inquiries and to verify and update our data records (purpose), 100Worte may, in accordance with GDPR Art. 6 para. 1 f, supplement personal data by research and enrichment (e.g., by adding the salutation or assigning a position or department). We use publicly available data obtained from third parties as sources for this purpose. The use of such enriched data only occurs within the purposes mentioned in sections B2 and B3. Use for advertising purposes only occurs if we have appropriate authorization.

B2.3) Systems for Data Processing

B2.3.a) Email Systems

To process inquiries as per B2.1.b and for further communication with customers, users, prospects, and partners, we use various systems for receiving and sending emails, as any other company would. We inform you about the application of this privacy policy in email communications. A list of the external providers used is available in section C6.

B2.3.b) CRM Systems

Within the scope of legitimate data processing as per B2 and B3, 100Worte may manage this data in a database or CRM system. Information about which external provider we use for this is available in section C7. At regular intervals (usually once a year), the data protection officer checks which legacy data of personal data are no longer needed for the purpose and initiates their deletion.

B2.3.c) Ticket Systems / Support Systems

A ticket or support system is specialized for handling support inquiries. If your data (usually by sending an email) is captured by such a system, you receive a confirmation and a ticket number. We inform you about the application of this privacy policy in these systems. A list of the external systems we use is also available in section C6. Since contractual communication (e.g., regarding the status of performance fulfillment) is also conducted via these systems, the storage duration is subject to statutory retention obligations and can be up to 10 years.

B2.4.d) Cloud Storage

In certain cases, it may be necessary to store your data on cloud storage, e.g., we use this in the case of individual order processing or for version-secure archiving of invoices. A list of the external cloud storage services we use is also available in section C10. Since contractual documents are also stored via these systems, the storage duration is subject to statutory retention obligations and can be up to 10 years.

B2.4) Newsletter

Users of 100Worte are given the option to subscribe to the company's newsletter. Which personal data are transmitted when ordering the newsletter depends on the signup form you use. 100Worte informs customers, prospects, and business partners regularly via a newsletter about offers and current developments of the company (purpose).

  • Subscription Requirements:

    • The newsletter can generally only be received by the data subject if:
      1. The data subject has a valid email address.
      2. The data subject has registered for the newsletter dispatch.
    • For legal reasons, a confirmation email is sent to the initially registered email address using the double opt-in procedure. This confirmation email serves to verify whether the holder of the email address has authorized the reception of the newsletter.

  • Data Collected:

    • Upon signing up for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of these data is necessary to trace any possible misuse of the data subject's email address at a later time and thus serves the legal protection of the controller.

  • Legal Basis:

    • Consent pursuant to Art. 6 para. 1 lit. a GDPR.
    • Additionally, newsletter subscribers may be informed by email if this is necessary for operating the newsletter service.

  • Storage Duration:

    • The data is stored as long as the data subject's consent for newsletter dispatch exists.
    • If the data subject withdraws their consent, the data is deleted as quickly as possible, provided no other legal basis exists for further data storage (e.g., an existing customer relationship).
    • A list of the external systems we use for sending email communications, including their serviceable addresses and options for individual objection, can be found in section C6.

  • Withdrawal of Consent:

    • Each newsletter contains a corresponding link for revoking consent (Unsubscribe / Abmeldung).
    • We also accept this request at any time via other means (e.g., by email).

B2.5) Applications and Application Procedures

We collect and process personal data from applicants for the purpose of managing the application process. The processing usually takes place electronically. This is particularly the case when an applicant transmits application documents electronically, for example, by email (see B2.3.a). In our job postings and on the careers/jobs page, we inform applicants about data processing according to this privacy policy.

  • Legal Basis:

    • Art. 6 para. 1 b GDPR.
    • By sending their personal data for the purpose of application, the data subject has initiated a pre-contractual measure.

  • Data Management:

    • For managing incoming applications, we use external systems; more information can be found in section C8.

  • Objection and Storage:

    • If an employment contract is concluded with an applicant, the transmitted data is stored for the purpose of managing the employment relationship in compliance with legal provisions.
    • If no employment contract is concluded with the applicant, the data is stored for an additional six months in accordance with § 61 b para. 1 ArbGG in conjunction with § 15 AGG.
    • We may request separate consent to extend the storage duration to two years.
    • If contact is established via a mediator/agency, the data is stored until the contract expires for the purpose of verifying commission claims.

      B2.6) Contacting for Marketing and Sales Purposes

      A legitimate interest of 100Worte includes, among other things, promoting and selling its products and services. Therefore, pursuant to Art. 6(1)(f) GDPR and Recital 47 GDPR, there is a legal justification to use the previously collected personal data to advise data subjects about our services through the channels described in B2.1, to create needs-based individual offers for them, and to use our systems (B2.3) to facilitate pleasant communication, particularly to prevent overly frequent or irrelevant contacts (purpose).

      As part of the balancing of interests required by law, the controller responsible for data processing will only use the data for marketing and sales purposes if (1) a request from the data subject has preceded that suggests an interest, or (2) the data subject has made a contact option publicly accessible to the general public (see GDPR Art. 14(2)(f)) and an interest in using that contact option can be derived from their role or activity, or if (3) there is a current reason that establishes a concrete legitimate interest for the controller to make contact.

      In the form and use of contact channels, the controller adheres to the respective legal requirements. In its activities and thus also in its sales approach, 100Worte exclusively targets businesses (B2B) — consumers and end customers are not contacted by 100Worte.

      Duration:

      The data is stored for the aforementioned purpose as long as it is necessary for the fulfillment or initiation of the contract or as long as a legitimate interest in continued storage persists. As a data subject, you can obtain information about the data stored about you at any time and object to the storage and use of your personal data (see also the document "Rights of Data Subjects" in our Data Protection Center).

      B3) Registered Customers / Registered Users of 100Worte

      100Worte refers to registered customers or registered users as those data subjects who have requested a 100Worte login through registration and have received a 100Worte user account. Registration is possible through various means: online via a form on the website, by email, through an app, a plugin, or a software integration (see also B1.6), as well as by accepting a received offer or through an invitation from an authorized colleague.

      We limit data collection to the data necessary for your use of the 100Worte software (purpose), which includes: name, salutation, contact details (phone, email), language settings, time zone, and affiliation with the company. Additionally, data about the respective company (name, address, industry, size) are collected. If registration occurs online, additional information from web analytics (B1.1) may be transmitted and attached to the request (e.g., on which page you submitted the registration, or whether you previously conducted a Google search).

      In the case of a paid order placement, the user designated as the administrator is also required to provide billing recipient information. However, a department or branch office can also be specified.

      The formation of the registration is contingent upon the user accepting the General Terms and Conditions (GTC) of 100Worte and consenting to the processing of their data in accordance with this privacy policy. To prove this, 100Worte uses a digital double opt-in procedure similar to the newsletter signup (see B2.4).

      If registration occurs as part of an order placement, consent to the GTC and data processing in accordance with this privacy policy for all affected users of the company can also be centrally obtained by the client and collectively confirmed to 100Worte. Whether an order was placed for a fee or not is irrelevant. A free trial account for a limited period or a registration to access certain protected content of 100Worte constitutes a valid contract and thus a valid registration.

      The legal basis for processing personal data of registered users, particularly the subpoints described below, is Art. 6(1)(a) & (b) GDPR. Therefore, this legal basis also replaces other articles mentioned in referenced sections, such as Art. 6(1)(f) GDPR, since an explicit consent and a contract, at least a contract initiation, now exist.

      Storage Duration and Objection:

      All personal data of registered users are stored as long as the user account exists or, according to § 257(4) HGB, for six years after the last communication/login of the user. The data is deleted by 100Worte when it is no longer necessary for the purpose for which it was collected.

      B3.1) 100Worte Account Manager (100WAM)

      Every registered user of 100Worte receives access to a password-protected work environment in accordance with section 3.2 of the 100Worte GTC. This environment includes, besides 100Worte products, the so-called 100Worte Account Manager (hereinafter “100WAM”). In this login area, the user can view and change data about themselves that were stored during registration at any time. The 100WAM is operated by 100Worte itself and adheres to the regulations specified in A7. Data storage is carried out by our hosting providers (C11).

      B3.2) Customer Support / Customer Service

      Professional customer support for registered customers and users is very important to us and is part of the contractual relationship between you and 100Worte. To efficiently assist you with inquiries, problems, and contacts (purpose), it is necessary to process certain data. These include, in addition to your contact details and possibly enriched information according to B2.2, documentation of consultations conducted and the collection of usage data (e.g., which inquiry you made when a specific error occurred). We use the systems described in section B2.3 to process your data and the communication channels described in B2.1, which may also be offered by external service providers. A list of the exact processors, including their serviceable addresses and details on objections, can be found in section C.

      B3.3) Additional Offers to Registered Users and Customers

      Analogous to B2.6 but based on the legal basis mentioned in B3, 100Worte will also use the data of registered customers and users to inform them about additional offers, trainings, and events conducted by 100Worte that match the contract chosen by the user or are deemed relevant to the data subject based on previous usage. The purpose is to expand the contractual relationship and facilitate more pleasant communication by selecting offers that better suit the user. The data subject can object to the use of their data for this extended purpose at any time through a simple statement (e.g., by email or communication to a 100Worte employee).

      B3.5) Invoicing

      When suppliers send us an invoice or when we send customers an invoice in connection with contract execution, personal data such as the invoice recipient or a contact person in management or accounting may also be stored. Since the proper processing of invoices is a legal obligation of 100Worte, the legal basis in this case is Article 6(1)(c) GDPR.

      Storage:

      The duration of invoice storage is determined by the statutory retention period. According to § 257 HGB paragraph 4, these must be stored for ten years. The processing of the data takes place in separate systems at 100Worte and is comprehensively protected by measures according to the current state of technology. Incoming invoices are digitized by 100Worte and archived in a version-secure manner via cloud storage (see C10). For the subsequent accounting processes, we work with external service providers, see C9.

      C) Processors

      Below you will find a list of all external service providers that are integrated into our website or are used by us as processors and whose described techniques are referenced in this privacy policy. If necessary, there is a corresponding data processing agreement with all mentioned providers and 100Worte. For many of the following systems, the general rule applies: You can prevent the setting of cookies, as already described in B1.1.a, by configuring your browser accordingly and delete already set cookies. If you do this, please note that you may not be able to use all 100Worte functions fully. If you change your device, you must perform the described steps again.

      C1) Web Analytics Service Providers

      Google Analytics

      • Operating Company: Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA – hereinafter referred to as “Google”.

      • Data and Techniques: Google Analytics uses cookies (see also B1.1.a). The information generated by your use of the website is usually transmitted to a Google server in the USA and stored there. The IP address transmitted by your browser in the context of Google Analytics is not merged with other data from Google. Additionally, we have extended Google Analytics on this website with the “anonymizeIP” code. This ensures the masking of your IP address so that all data is collected anonymously. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage to the website operator.

      • Objection: You can prevent the collection by Google Analytics by installing a browser add-on. Follow the instructions at: https://tools.google.com/dlpage/gaoptout?hl=de.

      • Data Protection: https://support.google.com/analytics/answer/6004245?hl=de or https://policies.google.com/?hl=de

      • Data Transfer to Third Countries: In the context of using Google products, data is stored on servers in the USA. This data is anonymized as described above. Google commits to adhering to European data protection regulations through the standard data protection clauses within their data processing agreements. More information can be found at: https://policies.google.com/privacy/frameworks?hl=de.

    • LinkedIn Insight Tag

      • Operating Company: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA

      • Data and Techniques: The LinkedIn Insight Tag is a small JavaScript snippet that we have added to our website. The LinkedIn Insight Tag enables the collection of data about visits to our website, including URL, referrer URL, IP address, device and browser properties, timestamps, and page views. This data is encrypted, anonymized within seven days, and the anonymized data is deleted within 90 days. LinkedIn does not share personal data with us but only provides aggregated reports about the website's target audience and advertising performance.

      • Data Transfer to Third Countries: No personal data is stored in third countries as part of the use of the LinkedIn Insight Tag.

      • Objection: Follow the instructions at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

      • Data Protection: https://www.linkedin.com/legal/privacy-policy

      Google Tag Manager

      • Operating Company: Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA – hereinafter referred to as “Google”.

      • Data and Techniques: Google Tag Manager is a tag management system for websites that helps in loading additional tools. Google states: "To monitor the stability and performance of the system, aggregated data on tag firing may be collected with Google Tag Manager. This data does not include IP addresses or other user-specific identifiers that could be associated with an individual. Unlike data in standard HTTP request logs, which are deleted within 14 days of receipt, no information about visitors to our customers' properties is captured, stored, or shared with Google Tag Manager. This also applies to the URLs of visited pages."

      • Data Protection: https://support.google.com/tagmanager/answer/9323295?hl=de or https://policies.google.com/?hl=de

      C2) Advertising Service Providers

      Google AdWords

      • Operating Company: Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

      • Data and Techniques: We have integrated Google AdWords into our website. Google AdWords is an internet advertising service that allows advertisers to display ads both in Google's search engine results and within the Google Advertising Network. Google AdWords enables an advertiser to predefine specific keywords, through which an ad is displayed in Google’s search engine results only when a user retrieves a keyword-relevant search result.

        A so-called "conversion cookie" is set in this process. Through the conversion cookie, both we and Google can track which subpages a data subject, who arrived at our website via an AdWords ad, has visited. Additionally, statistics are created that make the success of an AdWords ad trackable and allow for optimizations for subsequent campaigns based on these statistics.

        Using the conversion cookie, personal information, such as the specific web pages visited by the data subject, are stored. With each visit to our websites, personal data, including the IP address of the data subject’s internet connection, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may, under certain circumstances, share the personal data collected through this technical process with third parties.

      • Objection: A cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs. Furthermore, the data subject has the option to object to interest-based advertising by Google. To do this, the data subject must access the link www.google.de/settings/ads from each internet browser they use and make the desired settings.

      • Data Protection: https://www.google.de/intl/de/policies/privacy

      • Data Transfer to Third Countries: In the context of using Google products, data is stored on servers in the USA. This data is anonymized as described above. Google commits to complying with European data protection regulations through the standard data protection clauses within their data processing agreements. More information can be found at: https://policies.google.com/privacy/frameworks?hl=de

      Bing Ads

      • Operating Company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

      • Data and Techniques: On our websites, we use the "Conversion Tracking Bing Ads." The functionality is the same as already explained for Google AdWords and will therefore not be elaborated on again for simplicity.

      • Objection: A cookie already set by Bing Ads can be deleted at any time via the internet browser or other software programs. Additionally, you can declare your objection to interest-based advertising by Microsoft at http://choice.microsoft.com/de-DE/opt-out.

      • Data Protection: https://privacy.microsoft.com/de-de/privacystatement

      • Data Transfer to Third Countries: In the context of using Microsoft products, data is stored on servers in the USA. This data is anonymized as described above. Microsoft commits to complying with European data protection regulations through the standard data protection clauses. More information can be found at: https://docs.microsoft.com/de-de/microsoft-365/compliance/offering-eu-model-clauses?view=o365-worldwide.

      Facebook Ads / Facebook Pixel

      • Operating Company: Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

      • Data and Techniques: Within our online offerings, the so-called "Facebook Pixel" of the social network Facebook is used. With the help of the Facebook Pixel, Facebook can determine the visitors of our online offerings as a target audience for displaying advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to display the Facebook Ads we have placed only to those Facebook users who have shown an interest in our online offerings or who have certain characteristics (e.g., interests in specific topics or products determined based on visited websites) that we transmit to Facebook. The tracking in this process is carried out via a cookie. For specific information and details about the Facebook Pixel and its functionality, please refer to Facebook's help section: https://www.facebook.com/business/help/651294705016616.

      • Objection: You can object to the collection by the Facebook Pixel and the use of your data for displaying Facebook Ads. To set which types of advertisements are shown to you within Facebook, you can access the page set up by Facebook and follow the instructions for adjusting interest-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, meaning they apply to all devices, such as desktop computers or mobile devices.

      • Data Protection: https://www.facebook.com/policy.php

      • Data Transfer to Third Countries: In the context of using Facebook products, data is stored on servers in the USA. This data is anonymized as described above. Facebook commits to complying with European data protection regulations through the standard data protection clauses. More information about data protection at Facebook can be found at: https://www.facebook.com/business/gdpr

      C3) CDN / Content Delivery Networks

      Google Web Fonts

      Accelerated Mobile Pages (AMP)

      C5) Video Player / Screensharing

      YouTube

      • Operating Company: YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

      • Data and Techniques: With each access to a YouTube component (YouTube video), the internet browser on the data subject’s system is automatically triggered to download a script code from YouTube. This allows YouTube and Google to know which specific subpage is being visited by the data subject. If the data subject is simultaneously logged into YouTube, YouTube can associate the page visit with the data subject’s account; this is independent of whether the data subject clicks on a YouTube video or not.

      • Data Protection: https://support.google.com/youtube/answer/2801895?hl=de&ref_topic=2803240 and https://support.google.com/youtube/answer/7585465?visit_id=1-636626676584164516-780080012&rd=1

      • Data Transfer to Third Countries: In the context of using Google products, data is stored on servers in the USA. This data is anonymized as described above. Google commits to complying with European data protection regulations through the standard data protection clauses within their data processing agreements. More information can be found at: https://policies.google.com/privacy/frameworks?hl=de

      C) Processors

      Below you will find a list of all external service providers that are integrated into our website or are used by us as processors and whose described techniques are referenced in this privacy policy. If necessary, there is a corresponding data processing agreement with all mentioned providers and 100Worte. For many of the following systems, the general rule applies: You can prevent the setting of cookies, as already described in B1.1.a, by configuring your browser accordingly and delete already set cookies. If you do this, please note that you may not be able to use all 100Worte functions fully. If you change your device, you must perform the described steps again.

      C6) Communication Tools

      Microsoft Office 365 / Outlook

      C7) Contact Data Management Tools / CRM

      HubSpot

      • Operating Company: HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA

      • Data and Techniques: 100Worte uses HubSpot solutions to store contact and customer data. See also B2.3.b CRM Systems. More information about HubSpot: https://hubspot.de/

      • Data Protection: https://legal.hubspot.com/de/dpa

      • Data Transfer to Third Countries: Data is generally processed within the EU according to the settings made by 100Worte. If data is transferred to the USA, HubSpot commits to complying with European data protection regulations through the standard data protection clauses. More information can be found at: https://legal.hubspot.com/de/dpa

      C9) Invoicing Tools

      DATEV

      • Operating Company: DATEV eG, Paumgartnerstr. 6–14, 90429 Nürnberg, Germany

      • Data and Techniques: 100Worte uses DATEV for invoicing as described in B3.5) Invoicing. Invoice recipients are stored as clients in DATEV.

      • Data Protection: https://www.datev.de/web/de/m/ueber-datev/datenschutz/

      • Data Transfer to Third Countries: Not provided by the provider.

      C11) Hosting Provider

      T-Systems Deutschland GmbH (OTC)

      • Operating Company: T-Systems International GmbH, 60528 Frankfurt am Main, Hahnstraße 43d, Germany

      • Data and Techniques: 100Worte uses OTC for operating web servers and infrastructure, e.g., for its own websites and services.

      • Data Protection: https://open-telekom-cloud.com/de/sicherheit/datenschutz-compliance

      • Data Transfer to Third Countries: No, the servers are operated in Germany.