Responsible
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States, as well as other data protection provisions, is:
Priedemann Holding GmbH
Am Wall 17
14979 Großbeeren/Berlin
Deutschland
T +49 33701 32 79-00
F +49 33701 32 79-10
berlin@priedemann.net
www.priedemann.net
Contacting the Data Protection Officer
The data protection officer of the controller is::
DataCo GmbH
Sandstr. 33
80335 München
Deutschland
T +49 89 7400 458 40
www.dataguard.de
How we collect and use your personal data depends on how you interact with us or which services you use. We only collect, use or share your personal data if we have a legitimate purpose and a legal basis for doing so.
What is meant by legal basis?
Consent (Art. 6 (1) sentence 1 lit. a GDPR) – You have given us your consent to process your personal data for the specific purpose previously explained to you. You have the right to withdraw your consent at any time.
You can find more information on this in the “Exercising your rights” section of this privacy policy.
Contract (Art. 6 (1) sentence 1 lit. b GDPR) – We need to use your data to fulfill a contract you have with us. Alternatively, it is necessary to use your data because you have asked us to take certain steps before entering into this contract.
Legal obligation (Art. 6 (1) sentence 1 lit. c GDPR) – We must use your data to comply with the law.
Vital interests (Art. 6 (1) sentence 1 lit. d GDPR) – Processing your data is necessary to protect your vital interests or those of another person. For example, to protect you from serious physical harm.
Public task (Art. 6 (1) sentence 1 lit. e GDPR) – Processing your data is necessary for the performance of a task carried out in the public interest or covered by law, such as an official function.
Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR) – Processing your data is necessary to support a legitimate interest that we or another party have, only if your own interests do not override it.
Please note that we may not be able to provide you with our website services if your data is required to fulfill a contract or a legal obligation and you do not provide the requested data.
As explained in this privacy policy, we use various service providers who help us deliver our services and ensure the security of your data. When we engage these service providers, it is necessary to share your personal data with them.
As explained in this privacy policy, we use various service providers who help us deliver our services and ensure the security of your data.
When we engage these service providers, it is necessary to share your personal data with them.
We have agreements in place with all service providers to whom we disclose your data, which oblige them to protect your data.
Suppose your personal data is transferred outside the EU. In that case, we ensure that your personal data receives an equivalent level of protection, either because the country to which your data is transferred has an “adequate” level of data protection according to the European Commission, or by applying another safeguard, such as enhanced contractual agreements, i.e. the Standard Contractual Clauses (SCCs) adopted by the European Commission.
For example, when we use service providers in the USA, we rely on SCCs or the EU-US Data Privacy Framework, depending on the provider. You may request a copy of the SCCs we have concluded with our service providers by sending an email to the email address provided in this privacy policy.
If your personal data is processed, you are a data subject within the meaning of the GDPR, and you have the following rights against the controller:
1. Right of access (Art. 15 GDPR)
You have the right to request confirmation from us as to whether personal data concerning you is being processed. If this is the case, you have the right to access this data and the following information:2. Right to rectification (Art. 16 GDPR)
If your personal data is incorrect or incomplete, you have the right to obtain from us without undue delay the rectification of inaccurate or completion of incomplete personal data.
3. Right to restriction of processing (Art. 18 GDPR)
You have the right to request restriction of processing where one of the following applies:4. Right to erasure (“Right to be forgotten”) (Art. 17 GDPR)
You have the right to obtain the erasure of your personal data without undue delay if one of the following applies:5. Right to data portability (Art. 20 GDPR)
You have the right to receive your personal data in a structured, commonly used and machine-readable format and to have those data transmitted to another controller.
6. Right to object (Art. 21 GDPR)
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 (1) sentence 1 lit. e or f GDPR, including profiling.
Suppose your personal data are processed for direct marketing purposes. In that case, you have the right to object at any time to such processing, including profiling to the extent that it is related to direct marketing.
7. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.
The supervisory authority shall inform you of the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
A list of competent supervisory authorities in Germany can be found at: https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html
1. Description and scope of data processing
Every time our website is called up, our system automatically records data and information from the computer system of the calling computer.
The following data is collected in this process:These data are stored in the logfiles of our system.
Not affected by this are the IP addresses of the user or other data that make it possible to assign the data to a user. Storage of these data together with other personal data of the user does not take place.
2. Purpose of data processing
Storage in logfiles takes place in order to ensure the functionality of the website. In addition, the data serve us for the optimization of the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
3. Legal basis for data processing
The legal basis for the temporary storage of the data and the logfiles is Art. 6 para. 1 sentence 1 lit. f) GDPR.
4. Duration of storage
The data are deleted as soon as they are no longer required to achieve the purpose of their collection. In the case of collection of the data for provision of the website, this is the case when the respective session is ended. In the case of storage of the data in logfiles, this is the case after at the latest seven days. Longer storage is possible. In this case, the IP addresses of the users are deleted or altered, so that an assignment of the calling client is no longer possible.
5. Exercise of your rights
The collection of the data for provision of the website and the storage of the data in logfiles are absolutely necessary for the operation of the website. The user can object to this. Whether the objection is successful must be determined within the framework of a balancing of interests.
1. Description and scope of data processing
During your visit to our website, we use technical tools for various functions, in particular cookies, which can be stored on your end device. When you access our website and at any later time, you have the choice whether you want to generally allow the setting of cookies or which individual additional functions you wish to select. You can make changes in your browser settings or via our consent manager.
Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you use, so that certain information can flow to the party that sets the cookie. Below, we describe which types of cookies we use:
We use technically necessary cookies which are required for the technical structure of the website. Without these cookies, our website cannot be displayed (completely correctly), or the support functions are not possible.
The following data are stored and transmitted by the technically necessary cookies:We use cookies on our website, which are not technically necessary. As technically not necessary cookies are considered text files which do not solely serve the functionality of the website but also collect other data.
2. Purpose of data processing
The purpose of the use of technically necessary cookies is to guarantee the functionality of our website. Some functions of our website cannot be offered without the use of cookies. For these, it is required that the browser is also recognized again after a page change.
For the following applications, we need the technically necessary cookies:3. Legal basis for data processing
For the storage of information in the terminal device of the end user and/or the access to information already stored in the terminal device of the end user, the provisions of the Telekommunikation-Telemedien-Datenschutz-Gesetz (TTDSG) apply. If the setting and reading of cookies is technically required, this is done in order to ensure the functionality of our website. In this case, the storage of and access to cookies on your end device is based on § 25 para. 2 no. 2 TTDSG. This storage and access to the information in your end device serve to make it easier for you to use our website and to be able to offer you our services as you wish. Some functions of our website also do not work without the use of these cookies and therefore could not be offered. The cookies are generally deleted after the end of the session (e.g. logout or closing the browser) or after the expiry of a predetermined duration. Information about deviating storage periods for cookies can be taken from the following sections of this privacy policy.
Insofar as cookies are used which are not technically necessary, this takes place on the basis of your express consent, which you can give via the cookie banner. The basis for the storage and access to information is in this case § 25 para. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a), Art. 7 GDPR. You can withdraw your consent at any time with effect for the future or grant it again afterwards by configuring your settings regarding cookies accordingly. Alternatively, you can prevent the storage of cookies by making corresponding settings in your browser software. Please note that the browser settings made always only apply to the browser used in each case. If personal data are processed following the storage of and the access to the information on your end device, the provisions of the GDPR apply. Information on this can be found in the following sections of this privacy policy.
4. Exercise of your rights
You can withdraw your consent to the use of cookies at any time and manage your consent preferences at the bottom of the page in the footer by clicking on Cookie Settings.
1. Description and scope of data processing
On our website, it is possible to make contact via the provided e-mail address. In this case, the personal data of the user transmitted with the e-mail are stored. The data are used exclusively for processing the conversation.
2. Purpose of data processing
In the case of contact by e-mail, the required legitimate interest in the processing of the data also lies in this.
3. Legal basis for data processing
The legal basis for the processing of the data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. Our legitimate interest consists in optimally answering your inquiry, which you send by e-mail. If the e-mail contact aims at the conclusion of a contract, then an additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.
4. Duration of storage
The data are deleted as soon as they are no longer required to achieve the purpose of their collection. For the personal data transmitted by e-mail, this is the case when the respective conversation with the user is ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been finally clarified. The personal data additionally collected during the sending process are deleted at the latest after a period of seven days.
5. Exercise of your rights
If the user makes contact with us by e-mail, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. All personal data that were stored in the course of contacting will in this case be deleted.
1. Description and scope of data processing
On our website, there is a contact form that can be used for electronic contact. If a user uses this option, the data entered in the input mask are transmitted to us and stored.
At the time of sending the message, the following data are stored:2. Purpose of data processing
The processing of personal data from the input mask of the contact form or via the provided e-mail address serves solely to handle the contact request.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
3. Legal basis for data processing
The legal basis for processing the data transmitted in the course of sending an e-mail is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest consists in optimally answering your inquiry, which you submit via the contact form. If the e-mail contact aims at the conclusion of a contract, an additional legal basis for processing is Art. 6 para. 1 sentence 1 lit. b GDPR.
4. Duration of storage
The data are deleted as soon as they are no longer required to achieve the purpose of their collection. For personal data from the input mask of the contact form and those transmitted by e-mail, this is the case when the respective conversation with the user is ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been finally clarified. The personal data additionally collected during the sending process are deleted at the latest after seven days
5. Exercise your rights
If the user contacts us via the input mask in the contact form, they can object to the storage of their personal data at any time, in the following way: The objection can be made informally by e-mail to privacy@priedemann.net. All personal data that were stored in the course of contacting will be deleted in this case.
1. On our website, there is an application form that can be used for electronic applications. If an applicant uses this option, the data entered in the input mask are transmitted to us and stored.
These data are:Alternatively, you can also send us your application by e-mail. In this case, we collect your e-mail address and the data you provide in the e-mail. After sending your application, you will receive a confirmation of receipt of your application documents by e-mail from us. Your data will not be passed on to third parties. The data are used exclusively for processing your application.
2. Purpose of processing
The processing of personal data from the application form serves solely to handle your application. In the case of contact via e-mail, the required legitimate interest in the processing of the data also exists. s.
Other personal data processed during the sending process serve to prevent misuse of the application form and to ensure the security of our information technology system
3. Legal basis for data processing
The legal basis for processing your data is the initiation of a contract on request of the data subject, Art. 6 para. 1 sentence 1 lit. b Alt. 1 GDPR and § 26 para. 1 sentence 1 BDSG.
4. Legal basis for data processing
After the completion of the application process, the data are stored for up to 6 months. At the latest after the expiry of 6 months, your data will be deleted. In the case of a legal obligation, the data will be stored within the framework of the applicable provisions. The personal data additionally collected during the sending process are deleted at the latest after seven days.
YouTube:
YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States
On our corporate page, we provide information and offer YouTube users the opportunity for communication. If you perform an action on our YouTube corporate profile (e.g., comments, posts, likes, etc.), you may thereby make personal data (e.g., your real name or profile photo) public.
However, since we usually or largely have no influence on the processing of your personal data by YouTube, we cannot make binding statements about the purpose and scope of the processing of your data.
Every user is free to publish personal data through activities.
If we process your personal data to evaluate your online behavior, offer you competitions, or carry out lead campaigns, this is done on the basis of your express consent, Art. 6 para. 1 sentence 1 lit. a, Art. 7 GDPR.
The legal basis for processing personal data for the purpose of communication with customers and interested parties is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in optimally answering your inquiry or providing the requested information.
If the contact aims at concluding a contract, an additional legal basis for processing is Art. 6 para. 1 lit. b GDPR.
For the processing of your personal data in third countries, we have provided appropriate safeguards in the form of standard data protection clauses pursuant to Art. 46 para. 2 lit. c GDPR. A copy of the standard data protection clauses can be requested from us.
You can object to the processing of your personal data that we collect within the framework of your use of our corporate presence at any time and assert your rights as a data subject as set out in the section “Your Rights” in this privacy policy.
Send us an informal e-mail to privacy@priedemann.net for this purpose.
For the processing of your personal data by YouTube and the corresponding objection options, please find more information here:
YouTube: https://policies.google.com/privacy?gl=DE&hl=en
1. Scope of data processing
The corporate profile is used for applications, information/PR, and active sourcing. We have no information on the processing of your personal data by the companies responsible for the corporate profile.
Further information can be found in the privacy policies of:On our page, we provide information and offer users the opportunity for communication.
The corporate profile is used for applications, information/PR, and active sourcing.
We have no information on the processing of your personal data by the companies responsible for the corporate profile.
Further information can be found in the privacy policies of:
LinkedIn: https://www.linkedin.com/legal/privacy-policy
XING: https://privacy.xing.com/de
If you perform an action on our corporate profile (e.g., comments, posts, likes, etc.), you may thereby make personal data (e.g., your real name or profile photo) public.
2. Legal basis for data processing
The legal basis for processing personal data for the purpose of communication with customers and interested parties is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in optimally answering your inquiry or providing the requested information. If the contact aims at concluding a contract, an additional legal basis for processing is Art. 6 para. 1 lit. b GDPR.
3. Purpose of processing
Our corporate profile serves to inform users about our services. Every user is free to publish personal data through activities
4. Duration of processing
Data generated through the corporate profile are not stored in our own systems.
5. Exercise of your rights
You can object to the processing of your personal data that we collect in the context of your use of our corporate presence at any time and assert your rights as a data subject, as set out in the section “Your Rights” in this privacy policy. Send us an informal e-mail to the e-mail address provided in this privacy policy.
Further information on exercising your rights can be found here:
LinkedIn: https://www.linkedin.com/legal/privacy-policy
XING: https://privacy.xing.com/en
The website is hosted on servers of a service provider commissioned by us.
Our service provider is: die Netzwerker (https://dnw.ag/) of the provider Die Netz-Werker AG, Kiefholzstraße 3, 12435 Berlin. Further information can be found in the provider’s privacy policy: https://dnw.ag/datenschutz
The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when visiting the website.
A merging of this data with other data sources does not take place. The collection of this data is based on Art. 6 para. 1 lit. f GDPR. Our legitimate interest in processing this data is to display our website correctly and optimize its functions.
The location of the website server is geographically in Germany.
We use various service providers to provide the services offered on the website.
In general, we have a legitimate interest in sharing your data with the corresponding service providers if these services are essential for providing the basic service offered on the website.
If such services are required for additional services, extended functions, or additional purposes, your personal data will only be shared with service providers if you give your consent.
You can revoke your consent to the use of integrated third-party services at any time and manage your consent settings at the bottom of the page in the footer by clicking on Cookie Settings.
1. Scope of personal data processing
We use the open-source framework Bootstrap, which is loaded via the content delivery network of bootstrapcdn.com. Provider of this service is MaxCDN DBA StackPath, 2021 McKinney Ave., Suite 1100, Dallas, TX 75201, USA (hereinafter: StackPath).
By using BootstrapCDN, cookies are set on your computer and usage data are stored. Personal data may be stored and evaluated, especially user activity (e.g., which pages were visited and which elements were clicked) as well as device and browser information (especially IP address and operating system).
Further information on data processing by StackPath can be found here:
https://www.bootstrapcdn.com/privacy-policy/
2. Purpose of data processing
The use of Bootstrap serves to improve our online presence and its user-friendliness.
3. Legal basis for processing personal data
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in the purposes mentioned under 2.
4. Duration of storage
Your personal information is stored as long as necessary to fulfill the purposes described in this privacy policy or as legally required, e.g., for tax and accounting purposes.
5. Exercise your rights
You can prevent the collection and processing of your personal data by StackPath by blocking third-party cookies on your computer, using the “Do Not Track” function of a supporting browser, disabling script execution in your browser, or using a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com).
Further information on objection and removal options regarding StackPath can be found at: https://www.bootstrapcdn.com/privacy-policy/
1. Scope of personal data processing
We use the online map service Google Maps of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and the EU representative Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter: Google).
We use the Google Maps plugin to visually display geographical data and embed it in our online presence. By using Google Maps on our online presence, information about your use of our online presence, your IP address, and addresses entered for the route planner function are transmitted to a Google server and stored there.
Further information on data processing by Google can be found here: https://policies.google.com/privacy?gl=DE&hl=d e e
2. Purpose of processing
The use of the Google Maps plugin serves to improve user-friendliness and an appealing presentation of our online presence.
3. Legal basis for processing personal data
The legal basis for processing the personal data of users is generally the user’s consent according to Art. 6 para. 1 sentence 1 lit. a GDPR.
4. Duration of storage
Your personal information is stored as long as necessary to fulfill the purposes described in this privacy policy or as legally required.
5. Exercise of your rights
You have the right to revoke your data protection consent at any time. Revocation of consent does not affect the legality of processing carried out on the basis of consent up to the revocation.
You can prevent the collection and processing of your personal data by Google by blocking third-party cookies on your computer, using the “Do Not Track” function of a supporting browser, disabling script execution in your browser, or using a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com).
You can deactivate the use of your personal data by Google at the following link: https://adssettings.google.de
Further information on objection and removal options regarding Google can be found at: https://policies.google.com/privacy?gl=DE&hl=de
1. Scope of personal data processing
We use the open-source tracking tool Matomo (https://matomo.org/) to analyze the surfing behavior of our users. Matomo sets a cookie on your computer.
Personal data may be stored and evaluated, especially user activity (which pages were visited and which elements were clicked), device and browser information (especially IP address and operating system), data about displayed advertisements (which ads were shown and whether the user clicked on them), and data from advertising partners (pseudonymized user IDs).
The software is configured so that IP addresses are not stored completely but anonymized by masking 2 bytes of the IP address (e.g., 192.168.xxx.xxx). This prevents assignment of the shortened IP address to the accessing device. Data are stored in our MySQL database; protocol or report data are not sent to Matomo servers.
Further information on data processing by Matomo can be found here: https://matomo.org/privacy-policy/
2. Purpose of data processing
Processing personal data of users allows us to analyze user behavior. By evaluating the collected data, we can compile information on the use of individual components of our online presence. This helps us to continuously improve our online presence and its user-friendliness.
3. Legal basis for processing personal data
The legal basis for processing personal data of users is generally the user’s consent according to Art. 6 para. 1 sentence 1 lit. a GDPR.
4. Duration of storage
Your personal information is stored as long as necessary to fulfill the purposes described in this privacy policy or as legally required, e.g., for tax and accounting purposes.
5. Exercise your rights
You have the right to revoke your data protection consent at any time. Revocation of consent does not affect the legality of processing carried out on the basis of consent up to the revocation.
You can prevent the collection and processing of your personal data by Matomo by blocking third-party cookies on your computer, using the “Do Not Track” function of a supporting browser, disabling script execution in your browser, or using a script blocker such as NoScript (“https://noscript.net/“https://noscript.net/) or Ghostery (https://www.ghostery.com).
You can deactivate the processing of your personal data by Matomo at the following link: https://matomo.org/privacy-policy/
Further information on objection and removal options regarding Matomo can be found at: https://matomo.org/privacy-policy/
1. Scope of personal data processing
We use the Google-operated YouTube plugin of YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, and its EU representative Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google).
We use the YouTube plugin to embed YouTube videos in our online presence. When visiting our online presence, your browser establishes a connection with YouTube servers. Personal data may be stored and evaluated, especially user activity (which pages were visited and which elements were clicked), device and browser information (especially IP address and operating system
We have no influence on the content of the plugin. If you are logged into your YouTube account during the visit, YouTube may assign your online presence visit to this account. Interaction with this plugin sends this information directly to YouTube and stores it there.
Further information on data processing by Google can be found here: “ttps://policies.google.com/privacy?gl=DE&hl=de”:ttps://policies.google.com/privacy?gl=DE&hl=de
2. Purpose of data processing
The use of the YouTube plugin serves to improve user-friendliness and an appealing presentation of our online presence.
3. Legal basis for processing personal data
The legal basis for processing personal data of users is generally the user’s consent according to Art. 6 para. 1 sentence 1 lit. a GDPR.
4. Duration of storage
Your personal information is stored as long as necessary to fulfill the purposes described in this privacy policy or as legally required.
5. Exercise of your rights
You have the right to revoke your data protection consent at any time. Revocation does not affect the legality of processing carried out based on consent up to the revocation.
You can prevent the collection and processing of your personal data by Google by blocking third-party cookies on your computer, using the “Do Not Track” function of a supporting browser, disabling script execution in your browser, or using a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com).
You can deactivate the use of your personal data by Google at: https://adssettings.google.de
Further information on objection and removal options regarding Google can be found at: https://policies.google.com/privacy?gl=DE&hl=de
1. Processing of your personal data
If you apply for one of our job offers, we process your personal data via the service provider JOIN (JOIN Solutions AG, Schönhauser Allee 36, 10435 Berlin or Talacker 41, 8001 Zurich, Switzerland).
JOIN provides us with an applicant management tool, which we use to organize and conduct the application process.
Processed data include:JOIN acts as a data processor pursuant to Art. 28 GDPR, i.e., JOIN processes your data exclusively on our instructions and within the scope of a data processing agreement.
2. Purposes of processing and legal basis
Processing of your personal data is for conducting the application process, in particular to assess your suitability, communicate with you, and decide on potential employment. Legal basis is Art. 6 para. 1 lit. b GDPR (initiation of employment). If data are stored in a talent pool, this is based on your voluntary consent under Art. 6 para. 1 lit. a GDPR. Art. 6 para. 1 lit. f GDPR (legitimate interest) may also apply, e.g., for defense against legal claims.
3. Special categories of personal data
Special categories of personal data under Art. 9 para. 1 GDPR (e.g., health data, religious affiliation) are only processed if you voluntarily provide them and explicitly consent to their processing (Art. 9 para. 2 lit. a GDPR). There is no obligation to provide such data.
4. Duration of storage and data deletion
Your data are processed for the duration of the application process and deleted no later than 6 months after completion (e.g., rejection), unless legal retention obligations exist or there is a legitimate interest in further storage (e.g., defense against legal claims). With consent for longer storage (e.g., talent pool), data are stored for the agreed period. JOIN is contractually obliged to delete or return personal data according to our instructions.
5. Withdrawal and objection
You can withdraw your consent to the processing of your personal data (e.g., for the talent pool) at any time with future effect. If the processing is based on Art. 6 para. 1 lit. f GDPR, you have the right to object to the processing if there are reasons arising from your particular situation.
Revocation or objection can be sent by e-mail to: privacy@priedemann.net.
In case of revocation or objection, the relevant data are deleted unless legal retention obligations apply.
This privacy policy was created with the support of DataGuard.