networker variant

Privacy Policy

Privacy Policy


A. General Information


As networker variant GmbH (hereinafter “networker” or “we”), we process personal data in accordance with Art. 26 of the General Data Protection Regulation (GDPR). In the following privacy notice, we provide an overview of the data processing activities we carry out.



B. Principles


The data processing carried out by our GmbH, based in the European Union (“EU”) and the European Economic Area (“EEA”), also includes disclosure through transfer to third parties and, where applicable, to third countries outside the EU and the EEA. Where we transfer data to countries outside the EU or the EEA, this is expressly indicated below.



C. Controller


1. Contact Information


The controller within the meaning of the GDPR and the new Federal Data Protection Act (BDSG-neu) responsible for the processing of your personal data is:


networker variant GmbH
Friesenring 5D
25996 Wenningstedt-Braderup
Germany
Phone: +49 4651 9323 003
E-Mail: [email protected]


The controller for the processing of personal data is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.



2. Data Processing


The specific data subject to joint processing, the purposes of processing, the legal bases, the recipients, and, where applicable, transfers to third countries are listed below:



2.1 Contact


When you contact us, we process the following data provided by you for the purpose of handling and responding to your inquiry: name, contact details (if provided), and your message.


Legal basis: fulfillment of contractual obligations and/or pre-contractual obligations under Art. 6 (1)(b) GDPR and/or our overriding legitimate interest in handling your inquiry under Art. 6 (1)(f) GDPR.



2.2 Log Files When Visiting Our Website


When visiting our websites, we log your visit. The following data is processed:



  • Name(s) of the accessed webpage(s)

  • Date and time of access

  • Amount of data transferred

  • Browser type and version

  • Operating system used

  • Referrer URL (previously visited webpage)

  • Your IP address

  • The requesting provider


Legal basis: our overriding legitimate interest in ensuring the continuous provision and security of our website under Art. 6 (1)(f) GDPR.


Log files are deleted after seven days unless needed to investigate or prove specific legal violations discovered within the retention period.



2.3 Hosting via IONOS


To provide our online presence, we use services of web hosting providers, who process the above-mentioned and all related data (log files) on our behalf.


Legal basis: our overriding legitimate interest in providing our website under Art. 6 (1)(f) GDPR.


Details: IONOS Privacy Policy / Terms & Conditions.



2.4 Newsletter


To provide you with regular updates about our company and offers, we offer an email newsletter. When you register, we process the data entered by you (email address and any voluntary information).


To prevent misuse, we use the double opt-in procedure: you will receive a confirmation email, requiring you to verify your registration. Your registration is logged for compliance purposes (time of registration and confirmation, and your IP address).


Legal basis: your consent pursuant to Art. 6 (1)(a) GDPR.
The confirmation email and associated logging are based on our legitimate interest under Art. 6 (1)(f) GDPR to prove lawful registration.


If you consent, we also analyze newsletter engagement (opens, clicks, scroll behavior) to tailor content and improve our newsletter.


We use service providers for sending newsletters, transferring your data to their servers in Ireland:


HubSpot, Inc.
25 First Street, 2nd Floor, Cambridge, MA 02141, USA
European office: 2nd Floor, 30 North Wall Quay, Dublin 1, Ireland
Phone: +353 1 5187500


HubSpot is certified under the EU-U.S. Data Privacy Framework and covered by the EU adequacy decision.


Direct Marketing to Existing Customers
Unless you have objected, we send direct marketing related to products/services you have purchased, using your contract email address. You can object at any time without incurring costs beyond standard transmission rates.


Legal basis: Art. 6 (1)(f) GDPR; for Germany, § 7 (3) UWG in conjunction with Art. 95 GDPR; for Switzerland, the Swiss Data Protection Act and Art. 3 lit. o UWG Switzerland.


We also use HubSpot for this purpose (data processed on servers in Ireland; see above).



2.5 Live Chat


We use chat tools on our website to provide live chat functionality.


Legal basis: your consent under Art. 6 (1)(a) GDPR.



2.5.1 HubSpot Chat

We use HubSpot’s chat tool (see address above). Integration occurs via JavaScript and uses cookies. Details about cookies are available in our consent banner, which you can access anytime.


Data processed includes: chat content, date/time, browser type/version, operating system, referrer URL, user ID, number of visits, data volume.


Data is processed on HubSpot servers in Ireland. HubSpot is certified under the EU-U.S. Data Privacy Framework.


Cookie information can be accessed via our consent management platform.



2.6 Cookies


Our website uses cookies (small text files stored on your device).


Details on specific cookies, providers, and purposes are available in our consent banner, accessible anytime in the privacy settings (bottom-right of the site). You can give, withdraw, or adjust your consent in accordance with § 25 (1) TDDDG.



2.6.1 Consent Banner

We use a consent banner to document your preferences and meet our legal obligations. Your cookie preferences are stored in a cookie.


Legal basis: compliance with legal obligations under Art. 6 (1)(c) GDPR.



2.7 Analytics / Marketing


2.7.1 Google Services

We use services of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Data may also be transferred to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.


Google is certified under the EU-U.S. Data Privacy Framework.


(a) Google Analytics
Used for analyzing website usage, reporting, and improving user experience. Interactions are tracked primarily via cookies.


We use anonymizeIp(), truncating IP addresses within the EU/EEA. Full IP addresses are only exceptionally transferred to the USA, then truncated. Direct personal identification is generally excluded.


Data processed: anonymized IP address, visited website, referrer URL, subpages, time spent, frequency of visits.


Google states it will not link IP addresses with other Google data.


(b) Google Tags / Remarketing
Tracking cookies allow personalized advertising based on your viewed products and entry points.


(c) Google Ads
We use conversion tracking: if you click a Google ad, a cookie (valid 30 days) is set. This tracks ad performance statistics.


(d) Legal Basis / Withdrawal
Processing is based on your consent under Art. 6 (1)(a) GDPR. You may withdraw consent at any time via our consent banner.



2.7.2 HubSpot Tracking

We use HubSpot tracking tools (see address above) for website analytics and reports, mainly via cookies.


Legal basis: your consent under Art. 6 (1)(a) GDPR.


You may withdraw consent anytime via our consent management platform. Data is processed on HubSpot servers in Ireland. HubSpot is certified under the EU-U.S. Data Privacy Framework.



2.8 Webinars


For webinar participation, we process:



  • Communication data (e.g., email, if provided)

  • Personal master data (if provided)

  • Company data

  • Logfiles, protocol data

  • Metadata (IP address, time of participation, etc.)


Unless otherwise announced, no audio or video recordings are allowed to preserve anonymity.


Additional data may be required depending on the tool used (e.g., MS Teams, Zoom). Details are provided during registration.


Purpose: management of your registration, participation, notifications, and materials.


Legal basis: Art. 6 (1)(b) GDPR (contractual obligations) and, if applicable, Art. 6 (1)(f) GDPR (legitimate interests, e.g., smooth execution).



3. Rights of Data Subjects


See section E below.



4. Exercising Your Rights / Complaints


For questions, corrections, blocking, objections, deletion, or data portability requests, contact: [email protected].



D. Data Processing


1. Data Processing Activities


1.1 Contract Fulfillment & Data Management


For service provision and contract execution, we process your data (name, contact details, address, information necessary for fulfilling the contract).


Includes: consulting, communication, invoicing, accounting, tax obligations.


Legal basis: Art. 6 (1)(b) GDPR (contract performance) and Art. 6 (1)(c) GDPR (legal obligations).


Data may be shared with third parties, including supervisory authorities or group subsidiaries, for service delivery.



1.2 External Content on Our Website


Dynamic third-party content may be embedded. Requests to third-party servers transmit log data (e.g., IP address).


YouTube Videos: operated by YouTube LLC (Google Ireland Limited responsible). Data is transmitted to U.S. servers when videos are played.
Legal basis: our legitimate interest in marketing under Art. 6 (1)(f) GDPR. Google is certified under the EU-U.S. Data Privacy Framework.


Google Maps: provides interactive maps. Data including IP and location is transferred to Google servers.
Legal basis: your consent under Art. 6 (1)(a) GDPR. Google may transfer data to U.S. servers. Google is certified under the EU-U.S. Data Privacy Framework.



2. Social Media


2.1 LinkedIn


2.1.1 Joint Responsibility
LinkedIn Ireland Unlimited Company provides LinkedIn. Together with LinkedIn, we are jointly responsible for data processing related to our company profile and “Page Insights.”


LinkedIn assumes primary GDPR responsibility for Page Insights data (Art. 12–34 GDPR).


Joint Controller Addendum: LinkedIn Page Insights Addendum
LinkedIn Privacy Policy: LinkedIn Privacy Policy


2.1.2 Data Processing Purposes



  • Exchange & Communication: Contact with users, company updates, interaction with posts.

  • Applications: Data submitted via LinkedIn profiles processed for recruitment (Art. 26 BDSG, or Art. 6 (1)(f) GDPR for legal defense).

  • User Analysis: LinkedIn provides aggregated insights (no personal data access).


2.1.3 Data Transfers
Data may be processed by LinkedIn Corporation in the USA (certified under the EU-U.S. Data Privacy Framework).


We do not otherwise share data with third parties.



2.2 XING


2.2.1 Data Processing Purposes



  • Exchange & Communication: Contact with users, company updates, applications.

  • Applications: Candidate data processed under § 26 BDSG, or Art. 6 (1)(f) GDPR for legal defense.


Privacy policy: XING Privacy Policy


2.2.2 Data Transfers
No further data sharing with third parties by us.



E. Your Rights as a Data Subject


Unless otherwise stated, you are entitled to the following rights:



  1. Access – free information about all personal data stored about you.

  2. Rectification, Erasure, Restriction, Objection – correction, deletion, blocking, or restriction upon request. Objection rights include cases of public interest tasks, legitimate interest processing, profiling, and direct marketing.

  3. Withdrawal of Consent – at any time with future effect.

  4. Data Portability – receive data in a common, machine-readable format for transfer to another controller.

  5. Restrictions – anonymized data (e.g., for analytics) may be excluded unless you provide additional identifiers.

  6. No Automated Decision-Making – you will not be subject to automated decisions under Art. 22 GDPR unless specifically notified.

  7. Exercise & Complaints – contact the above address to exercise rights. You may also lodge complaints with a supervisory authority.




Effective Date of this Privacy Policy: January 2025