PohlCon GmbH

Data protection declaration

In this privacy policy we inform you about which personal data we process. Please read the privacy policy carefully.

1. Responsibility

Responsible for this online offer and its contents is

PohlCon GmbH
Nobelstraße 51, 12057 Berlin
Phone: +49 30 68283-04
Fax: +49 30 68283383
Email: contact@pohlcon.com

2. Contact details of the data protection officer

We have appointed a data protection officer who can be contacted at

Hendrik Klünder, lawyer
Schwanebecker Chaussee 5, 13125 Berlin
Phone: +49 30 60933556
Fax: +49 30 60933558
Email: pohlcon@datenschutz.contact

3. your rights

If you wish to exercise one of your rights listed below, you can contact us at any time using one of the contact options listed above.

a. Right to information

You have the right to know whether we are processing your personal data. If so, you will receive information on: Processing purposes, data categories, recipients (including in third countries), storage duration, rights to rectification, erasure, restriction, objection, right to lodge a complaint with the supervisory authority, origin of the data (if not collected from you), automated decision-making (incl. profiling) and data transfers abroad. We will provide you with a copy of your data on request. We may charge a reasonable fee for further copies. The rights of other persons remain unaffected.

b. Right to rectification

You can request the immediate correction of incorrect data or the completion of incomplete data.

c. Right to erasure

You can request the erasure of your personal data if it is no longer required or if you have withdrawn your consent and there is no other legal basis. Exceptions exist, for example, in the case of legal obligations, public interests, archiving or research purposes or for legal defence.

d. Right to restriction of processing

You can request the restriction of processing if, for example, the accuracy of the data is disputed, the processing is unlawful, the data is no longer required but is needed for legal claims, or if you have lodged an objection and the decision is still pending. We will inform you when the restriction is lifted.

e. Right to object

You can object to the processing of your data based on our legitimate interest at any time on grounds relating to your particular situation. In the case of direct marketing, you can object without giving reasons. This also applies to profiling in connection with direct advertising. You can also object to processing for research purposes, provided there are no compelling reasons.

f. Right to data portability

You have the right to receive the personal data you have provided to us in a commonly used, machine-readable format and to have it transmitted to another controller, provided that the processing is based on consent or a contract and is carried out by automated means. This right does not apply to public tasks and must not affect the rights of third parties.

g. Right to withdraw consent

You can revoke your consent given within the meaning of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR at any time with effect for the future. The lawfulness of the processing until the revocation remains unaffected.

h. Right to lodge a complaint

You can lodge a complaint with a data protection supervisory authority if you believe that we are not processing your data lawfully. The complaint can be lodged with the authority of your place of residence, workplace or the suspected infringement.

4. Legal bases for the processing of personal data

We process personal data on the basis of various legal bases. We refer to the respective legal basis in this privacy policy. In principle, the following legal bases come into consideration

Art. 6 para. 1 lit. a GDPR
Consent for processing,

Article 6(1)(b) GDPR
fulfilment of a contract to which the data subject is a party or implementation of pre-contractual measures, e.g. in the case of enquiries about products or services

Art.6 para.1 lit.c GDPR
Fulfilment of a legal obligation to which we are subject,

Art.6 para.1 lit.d GDPR
Protection of vital interests of the data subject or another natural person,

Article 6(1)(f) GDPR
Protection of our own legitimate interests or those of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

5. Erasure and blocking of personal data

We only process personal data for the period required to achieve the purpose of storage or as required by law. The personal data will then be deleted or, if we are subject to retention periods, blocked for further processing.

6. further links

Our website contains links to external offers. After clicking on the links, you will be redirected to the website of the respective provider. For information on the handling of your personal data when using these websites, please refer to the respective data protection regulations of the providers.

7. Use of contract processors

Please note that we use various processors for the realisation of our website. We have obligated all processors with the agreements required under data protection law. In the context of this data protection declaration, we point out which processing operations are carried out by our processors.

8. Collection of general data and information

Each time the website is accessed, the following data may be stored in the server logs by the servers of our processors or our server:

• Browser used and its version
• Operating system of the accessing system
• Website from which the accessing system accesses the website (referrer)
• Host name of the accessing system
• Websites that the accessing system visits on the website
• Date and time of access
• Internet protocol address of the accessing system (IP address)
• Internet service provider of the accessing system (ISP).

The data is collected and stored in order to

• properly deliver the content of the website
• optimise the content of the website
• ensure the proper operation of our systems
• in the event of an attack on our system, to avert dangers and to provide law enforcement authorities with the information necessary for prosecution.

The collected data is statistically evaluated in order to optimise the data security of the systems and the level of protection of the processed personal data. The server log file data is stored separately from all personal data provided by a data subject.

The server logs are deleted after 180 days at the latest.

9. Hosting

Our website is hosted by ALL-INKL.COM - Neue Medien Münnich (‘All-Inkl’). We have concluded a data processing agreement (DPA) with All-Inkl in accordance with Art. 28 GDPR.
This agreement ensures that All-Inkl processes the personal data of our website visitors exclusively in accordance with our instructions and in compliance with the provisions of the GDPR.

10. Newsletter

When you register to receive our newsletter, the data you provide in the registration form will be processed for the purpose of sending the newsletter. You will also receive information by e-mail that is relevant to the service or your registration (e.g. changes to the newsletter offer or technical circumstances). When you register to receive the newsletter, the IP address of the accessing system as well as the date and time are also stored in order to be able to trace the possible misuse of a registered e-mail address.

The ‘double opt-in’ procedure is used to check that a registration is actually made by the owner of an e-mail address. For this purpose, the subscription to the newsletter, the sending of a confirmation email and the receipt of the requested reply are logged.

You can revoke your consent to receive our newsletter and the associated data processing at any time with effect for the future. There is a corresponding link in every newsletter. You can also unsubscribe directly on this website at any time or inform us of your wish to do so via the contact option provided at the end of this data protection notice.

The legal basis for sending the newsletter is your consent in accordance with Art. 6 para. 1 lit. a GDPR. The logging of the registration process is based on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Our interest here is in the use of a secure newsletter dispatch procedure which, among other things, makes it possible to prove your consent.

Your email address, your declaration of consent and the declaration of revocation will be stored for a further three years even after your consent has been revoked in order to prove that you have given us your consent. The storage is based on our legitimate interests in the defence or enforcement of any legal claims. The data will then be deleted.

If you do not complete your registration for the newsletter, we will delete your data after one week.

We use the services of Sendinblue GmbH (‘brevo’) to send the newsletter. We have concluded an order processing agreement (AVV) with brevo in accordance with Art. 28 GDPR. This agreement ensures that brevo processes the personal data of our newsletter subscribers exclusively in accordance with our instructions and in compliance with the provisions of the GDPR.

11. Contact form, callback request

If you contact us via the contact form or leave a callback request, the information you provide will be processed to process and answer your enquiry, for possible follow-up questions and for communication purposes. Depending on your request, the legal basis for data processing may be Art. 6 para. 1 lit. b GDPR (contractual or pre-contractual measures) or Art. 6 para. 1 lit. f GDPR (legitimate interests). The legitimate interests pursued by us are responding to your enquiry and communicating with you for this purpose.

Your data will be deleted no later than 180 days after the last communication or contact, unless a contract is concluded. In this case, we may be subject to different storage and retention periods, about which we will inform you separately if necessary.

12. Online job adverts

You can find out about job vacancies on our website. The job vacancies are made available to you via a widget of the processor we use, softgarden e-recruiting GmbH (‘softgarden’). We have concluded a data processing agreement (DPA) with softgarden in accordance with Art. 28 GDPR. This agreement ensures that softgarden processes the personal data of our website visitors exclusively in accordance with our instructions and in compliance with the provisions of the GDPR.

If you decide to submit an online application, please note the additional data protection information that will be provided to you as part of the application process.

13. Whistleblower protection portal

You can use the whistleblower protection portal via our website. This is made available to you via a widget of the processor we use, SAVISCON GmbH (‘Saviscon’). We have concluded a data processing agreement (DPA) with Saviscon in accordance with Art. 28 GDPR. This agreement ensures that Saviscon processes the personal data of our website visitors exclusively in accordance with our instructions and in compliance with the provisions of the GDPR.
If you decide to use the whistleblower protection portal, please note the additional data protection information that will be provided to you when you use the portal.

14. OpenStreetMap

On our website, we use the OpenStreetMap (OSM) map service, a service provided by the OpenStreetMap Foundation (OSMF), St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom, to display interactive maps. The OSMF is based in the United Kingdom. According to the adequacy decision of the EU Commission, Great Britain is considered a safe third country within the meaning of Art. 45 GDPR.

In order to protect your data in the best possible way, we use a two-click solution: The map content from OSM is only loaded once you have expressly consented to its use. Only after you have given your consent will a connection to the OSMF servers be established and any personal data transmitted. Until this point, only a placeholder is displayed, which informs you of the data protection aspects and offers you the opportunity to give your consent.

Once you have given your consent, OSMF may in particular process your IP address, information about your browser type and operating system, the sub-page accessed with map integration, location data if you have authorised this, cookies and comparable technologies for user recognition. This data processing is carried out by OSMF under its own responsibility under data protection law.

The integration of OSM is based on your express consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future via the settings in our consent tool.

15. YouTube videos

Videos from YouTube are integrated on our website. This is an offer from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (‘YouTube’), a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To protect your data, we use a so-called two-click solution. YouTube videos are not initially loaded automatically on our website. Instead, you will only see a preview image with an information text. Only when you actively click on the preview image and thus expressly consent to this will a connection to the YouTube servers be established and the video played.

In addition, YouTube content is only integrated in ‘extended data protection mode’. This is provided by YouTube itself and ensures that YouTube does not initially store any cookies on your device. However, when the relevant pages are accessed, the IP address and other data are transmitted and thus, in particular, which of our Internet pages you have visited. However, this information cannot be assigned to you unless you have logged in to YouTube or another Google service before accessing the page or are permanently logged in. As soon as you start playing an embedded video by clicking on it, YouTube only stores cookies on your device through the extended data protection mode, which do not contain any personally identifiable data, unless you are currently logged in to a Google service. These cookies can be prevented using the appropriate browser settings and extensions.

By activating the video, you also consent to personal data (e.g. your IP address and usage information) being transmitted to YouTube and possibly processed on servers in the USA. The USA is considered an unsafe third country under data protection law.

The legal basis for the integration is your express consent in accordance with Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG insofar as cookies or similar technologies are used by YouTube (e.g. device fingerprinting). You can revoke your consent at any time with effect for the future via the settings in our consent tool.

Please also note the information below on the cookies used by YouTube.

16. Cookies

We use cookies on our website, which are used for various purposes. You can set your browser so that it informs you about the placement of cookies. This makes the use of cookies transparent for you. Of course, you can also have your browser block the placement of cookies. However, this may mean that you can no longer use our website to its full extent.

Cookies that are required, for example, to carry out and secure the electronic communication process or to provide certain functions that you have requested (e.g. watch list) (technically necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless otherwise stated. Our legitimate interest is, among other things, the technically error-free and secure provision of our website.

a. Technically necessary cookies

Without the use of technically necessary cookies, you cannot use our website as intended. They are used exclusively by us and are only stored on your computer during the current browser session. These cookies are used to customise the functionality of the website so that you are shown a version that your computer and your connection can process. They also support the change from an http (unencrypted) session to an https (encrypted) session, thereby increasing the security of your visit to our website.

The necessary cookies we use include

b. Other Cookies

If you have given your consent to the storage of the following cookies or technologies, processing will take place solely on the basis of your consent (Art. 6(1)(a) GDPR and § 25(1) of the TDDDG). You may withdraw your consent at any time with future effect.

17. Use of Plausible Analytics

We use the web analytics software Plausible Analytics on our website to anonymously evaluate visitor usage behavior, measure the effectiveness of our advertising efforts, and continuously improve our offerings. For this purpose, we track the number of visitors to our website, their geographical origin and referrers, the devices, operating systems, and browsers they use, the duration of their sessions, the bounce rate, and the pages they visit.

Plausible Analytics completely refrains from using cookies and does not process personal data in the traditional sense (e.g., no IP addresses, no user IDs, and no browser fingerprints). Instead, the analysis is based on aggregated data that does not allow conclusions to be drawn about individual persons.

Data processing is carried out based on legitimate interests pursuant to Art. 6(1)(f) GDPR. Our legitimate interest lies in the statistical analysis of website usage to improve its functionality and make it more user-friendly. Since no personal data is stored or transmitted, we believe that there is no significant impact on the rights and freedoms of the data subjects.

Plausible is operated by Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estonia. Data processing takes place within the European Union; no data is transferred to third countries. Further information can be found at: https://plausible.io/data-policy

We have entered into the necessary data protection agreements with Plausible Insights OÜ as our data processor.

18. Information on the Use of Our Presence on Social Networks and Platforms

We operate presences on social networks and platforms in order to communicate with users active there and to provide information about us. In doing so, user data may be processed.

Please note that this data may also be processed outside the European Union. This can potentially pose risks to users, for example, by making it more difficult to enforce user rights.

In addition, user data on social networks is often processed for market research and advertising purposes. Based on user behavior and interests, profiles can be created to serve targeted advertisements—both within and outside the platforms—that presumably match users’ interests. For this purpose, cookies are typically stored on users' devices, which record their behavior and interests. Such profiles may also be created across devices, especially when users are members of multiple platforms and remain logged in to them.

For further information on specific processing activities and your options to object (opt-out), we refer you to the privacy policies of the respective network or platform operators.

If you wish to request information or assert your data subject rights, we recommend contacting the platform operators directly, as only they have access to user data and can take appropriate action. Of course, we are happy to support you if you need assistance with this.

When using our online presences on social networks and platforms, the following types of data may be processed: names, first names, contact data (e.g., addresses, email addresses, phone numbers), content data (e.g., messages, posts), usage data (e.g., page views, duration of visits, click paths, usage patterns, devices, operating systems, interactions, functions). The legal basis for processing your data is generally our legitimate interest pursuant to Art. 6(1)(f) GDPR in communication and public relations, as well as enabling user feedback via our social media presences.

We delete your aforementioned data in accordance with legal requirements as soon as it is no longer needed for its intended purpose and there is no legal basis for further processing. Exceptions apply where legal retention obligations or special interests require longer storage. This particularly applies to data that must be retained for commercial or tax-related reasons, or that is necessary for the establishment, exercise, or defense of legal claims, or to protect the rights of other natural or legal persons.

a. LinkedIn

We maintain a company page on LinkedIn to communicate with prospects, customers, and business partners and to present our services. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

Joint Responsibility: We are jointly responsible with LinkedIn for data processing in connection with our LinkedIn page (Art. 26 GDPR). The agreement can be found here: https://legal.linkedin.com/pages-joint-controller-addendum. LinkedIn’s privacy information can be found at: https://www.linkedin.com/legal/privacy-policy

Data Processing by LinkedIn: When you visit our LinkedIn page, LinkedIn processes personal data (e.g., IP address, usage behavior) for the following purposes: creation of statistical analyses (Page Insights), personalized advertising and user analytics, linking to your profile if you are logged in.

Legal Basis for Processing: The processing of personal data is based on Art. 6(1)(f) GDPR (legitimate interest in communication, analytics, and public relations) and Art. 6(1)(a) GDPR (consent given to LinkedIn). You may withdraw your consent at any time with future effect directly from LinkedIn.

Contact via LinkedIn: If you contact us via LinkedIn, we use the personal data provided to process your request. The data is then deleted unless retention obligations apply.

Data Transfer to Third Countries: Personal data may be transferred to the USA by LinkedIn (LinkedIn Corp., USA). LinkedIn relies on the EU Commission’s Standard Contractual Clauses for such transfers.

b. Facebook

We operate a company page on Facebook to present our products and services and to communicate with prospects and customers. The provider is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

Joint Responsibility: We are jointly responsible with Meta for the processing of personal data related to our Facebook page. The joint controller agreement under Art. 26 GDPR can be accessed at: https://www.facebook.com/legal/terms/page_controller_addendum

Data Processing by Meta: When you visit our Facebook page, Meta processes personal data (e.g., IP address, usage behavior, interactions) for purposes such as reach measurement, creation of statistical analyses (Facebook Insights), personalized advertising within and outside of Facebook, and profile building for market research. If you are logged into your Facebook account during your visit, Meta can associate the data with your account.

Legal Basis for Processing: The processing of personal data is based on Art. 6(1)(f) GDPR (legitimate interest in analysis and communication) and Art. 6(1)(a) GDPR (consent given to Meta, e.g., for personalized advertising). You can withdraw your consent at any time with future effect directly from Meta.

Contact via Facebook: If a user contacts us via Facebook (e.g., via message or comment), the provided data is used to handle the request and is then deleted unless legal retention obligations apply.

Cookies and Tracking: Meta uses cookies and similar technologies. Their use can be limited or disabled via your browser settings or directly through Meta.

Data Transfer to Third Countries: It is possible that personal data may be transferred to the USA to Meta Platforms, Inc. In such cases, there may be additional risks due to the lack of an adequate level of data protection.

Further information on data processing by Facebook is available here: https://www.facebook.com/policy.php

c. YouTube

We operate a corporate channel on YouTube to present our products, services, and content in video format and to communicate with prospects, customers, and partners. The platform is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (a company of Alphabet Inc., USA).

Further information on Google’s data processing can be found at: https://policies.google.com/privacy. The terms of use for YouTube and Google services can be found here: https://www.youtube.com/t/terms.

Data Processing by Google (YouTube): When visiting our YouTube channel, Google processes various personal data, including IP address, device information (e.g., browser type, operating system), location data (if enabled), usage behavior (e.g., watched videos, interactions, comments), and search history on YouTube. If you are logged into your Google account at the time of the visit, this data can be directly associated with your account. YouTube uses this data in particular for the following purposes: creation of aggregated channel statistics (e.g., audience analysis), personalized advertising within and outside Google services, platform optimization (e.g., recommendation algorithms), and profiling for marketing and market research. Google also uses cookies and similar technologies (e.g., pixels, local storage) to track user activity across devices.

Contact via YouTube: If you contact us via YouTube (e.g., through comments or direct messages), we use the personal data provided solely to process your inquiry. The data is deleted after completion of the request unless legal retention obligations apply.

Cookies and Tracking Technologies: Google uses various cookies and similar technologies for data collection. You can partially object to their use or manage data settings in your Google account or browser:

• Google data settings: https://myaccount.google.com/data-and-personalization
• Personalized ad settings: https://adssettings.google.com

Data Transfers to Third Countries: It is possible that data may be transferred to servers in the USA or other third countries by Google. Google relies on the EU Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR) for such transfers. However, there remains a residual risk due to a potentially inadequate level of data protection, especially if no additional safeguards are in place.

d. Instagram

To present our products and services and to communicate with customers and prospects, we operate a company page on the Instagram platform. This service is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

Joint Responsibility:
We are jointly responsible with Meta for the processing of personal data in connection with our Instagram presence. The agreement on joint responsibility in accordance with Art. 26 GDPR can be accessed at: https://www.facebook.com/legal/terms/page_controller_addendum

Data Processing by Meta: When visiting our Instagram page, Meta processes users' personal data (e.g., IP address, device information, interactions). This data may be used for the following purposes: generation of anonymized usage statistics (Insights), market research and advertising, creation of user profiles for interest-based advertising (including outside Instagram).

If you are logged into your Instagram account during the visit, Meta may directly associate this data with your user account.

Legal Basis for Processing: The processing of personal data is based on Art. 6(1)(f) GDPR (legitimate interest in analysis, communication, and marketing) and Art. 6(1)(a) GDPR (consent given to Meta, e.g., for tracking, cookies, personalized ads). You may withdraw your consent at any time with future effect directly from Meta.

Contact via Instagram: If you contact us via Instagram (e.g., via direct message or comment), we process the data you provide solely to handle your inquiry. After completing the process and if no legal retention obligations apply, we delete your data.

Cookies and Tracking by Meta: Meta may store cookies or similar technologies on your device when using Instagram. These are used, among other things, for user recognition, profiling, and analysis. You can prevent cookies through appropriate browser settings, although this may limit platform functionality. Further details: Instagram's data policy can be found at: https://help.instagram.com/519522125107875

Data Transfers to Third Countries: It cannot be ruled out that Meta may also transfer personal data to the USA to Meta Platforms, Inc., 1601 Willow Road, Menlo Park, California 94025. Currently, there is no adequate level of data protection in the USA as defined by the GDPR. Therefore, such transfers may involve increased risks.

e. XING

We operate a company page on XING to provide information about our company and our services. The provider is New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.

Responsibility: With regard to the processing of personal data in connection with visits to our XING page, we and New Work SE are each independently responsible. Further information on data protection at XING can be found at: https://privacy.xing.com/en/privacy-policy

Legal Basis for Our Processing: We process personal data based on Art. 6(1)(f) GDPR (legitimate interest in professional networking and corporate representation).

Contact via XING: If a user contacts us via XING, we use the data provided to process the inquiry and delete it after completion, provided there are no legal retention requirements.

Data Processing by XING: When visiting our company page, XING processes personal data (e.g., IP address, user activity) for the following purposes: displaying page statistics, improving the platform, and showing job-related advertisements. Data may be linked to a user profile if you are logged in during the visit.

19. Provision of Your Data

You are generally not obligated to provide your personal data. However, many of the services and features offered on our website will not work—or not work as desired or expected—without the provision of such data (e.g., contact forms, callback requests).

20. No Automated Decision-Making

We do not use automated decision-making or profiling of website visitors.

21. Changes to Our Privacy Policy

We reserve the right to modify this privacy policy to ensure that it always complies with current legal requirements or to reflect changes in our services, for example, when introducing new features. The version of the privacy policy that applies is the one in effect at the time of your next visit.