Privacy policy

Responsible party

The responsible party as defined in the EU General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is: 

Columbus Leasing GmbH 

Eywiesenstrasse 6, 88212 Ravensburg 

Registration Court/No.: District Court Ulm, HRB 551221 

Managing Director: Wolfgang Marschall, Haiko-Falk Wagener 

Phone: +49 751 36344-315 / -327 

Email: w.marschall@columbus.ag / h.wagener@columbus.ag 


Data Protection Officer 

The data protection officer of the responsible party can be reached at: 

Eywiesenstrasse 6, 88212 Ravensburg Email: datenschutz@columbus.ag

 

1. General information about data processing

This Privacy Policy explains to users the nature, scope and purpose of the processing of personal information within our online offering and the related sites, features and content (collectively referred to as "online offering" or "website"). The Privacy Policy applies regardless of the domains, systems, platforms and devices used (e.g. desktop or mobile) on which the online offering is executed.


For the terms used, such as "personal data" or their "processing", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR). 

The term "user" covers all categories of persons affected by data processing. These include our business partners, customers, interested parties and other visitors to our online offering. The terms used, such as "user", are to be understood as gender neutral. 

 

2. Extent of processing of personal data

The personal data of the users processed in the context of this online offering includes stock data (e.g. names, addresses, email addresses of interested parties), usage data (e.g. the visited web pages of our online offering, interest in our services) and content data (e.g. entries in the contact form).   


We process the personal data of users only in compliance with the relevant data protection regulations. This means that users' data will only be processed if a legal permit is present:

  • if the data processing is necessary or required by law for the provision of contractual or pre-contractual services (e.g. processing of inquiries via the contact form),
  •  the consent of the users is available (e.g. subscribing for the newsletter),
  •  as well as due to our legitimate interests (i.e. interest in the analysis, optimization and economic operation and security of our online offering within the meaning of Art. 6(1) lit. f. of the GDPR).
 

Insofar as we obtain the consent of the data subject for processing of personal data (e.g. subscribing for the newsletter), Art. 6(1) lit. a of the EU General Data Protection Regulation (GDPR) serves as a legal basis.   


In the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6(1) lit. b of the GDPR serves as a legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures, such as processing a request via the contact form.

Insofar as processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6(1) lit. c of the GDPR serves as legal basis.   


If processing is necessary to safeguard the legitimate interests of our company or a third party, and if the interests, fundamental rights and freedoms of the data subject do not prevail over the first interest, Art. 6(1) lit. f of the GDPR serves as a legal basis for processing. This is the case when using the website tracking of Google Analytics or Wiredminds, which is done with anonymous IP address. See the points Google Analytics and Wiredminds.

 

4. Duration of data storage

The data stored with us are deleted as soon as they are no longer necessary for their purpose and the deletion does not conflict with any statutory storage requirements. Where the users' data is not deleted because it is necessary for lawful purposes, its processing is restricted.  

This means that the data is blocked and not processed for other purposes. This applies, for example, to the data of users that must be kept for commercial or tax law reasons.

 

5. Security measures

We provide state-of-the-art organizational and technical security measures to ensure compliance with data protection laws and to protect data processed by us against accidental or intentional manipulation, loss, destruction or access by unauthorized persons. 

 

6. Contacting

Description and scope of the data processing 

When contacting us (via contact form or email), the information provided by the user in the form is handled according to. Art. 6(1) lit. b) of the GDPR for processing the contact request and implementing it. The consent of the user for processing the data from the contact form is obtained during the sending process and reference is made to this Privacy Policy. It is also possible to make contact via the provided email address. In this case too, the user's personal data given by email will be stored. No disclosure of the data is made to third parties in this context. The data is used exclusively for processing the contact request. 


Legal basis for data processing

The legal basis for processing the data in the presence of the consent of the user is Art. 6(1) lit. a of the GDPR. The legal basis for processing the data transmitted in the course of sending an email is Art. 6(1) lit. f of the GDPR. If the email contact aims to conclude a contract, then additional legal basis for the processing is Art. 6(1) lit. b of the GDPR.


Purpose of data processing 

The processing of personal data from the input mask or from the sent email takes place solely to process the contacting. In the case of contact via email, this also includes the required legitimate interest in the processing of the data.

Duration of storage The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection. For the personal data from the input mask of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have finally been clarified.   


Right to opposition / revocation 

The user has the option at any time to revoke his consent to the processing of the personal data. If the user contacts us by email, he may object to the storage of his personal data at any time. In such a case, the conversation can not continue.   


The user can revoke his consent to Columbus Leasing GmbH, Eywiesenstraße 6, 88212 Ravensburg, or by email at datenschutz@columbus.ag, at any time and without stating reasons, with effect for the future, or object to the processing of personal data in the same way. All personal data that are stored when making contact will be deleted in this case.

 

7. Newsletter subscription

Description and scope of the data processing

We send newsletters, emails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Our newsletters contain information about our services, projects, events and our company.


Double opt-in and logging

Subscription for our newsletter is via a so-called double opt-in procedure. This means you will receive an email after logging in to ask for confirmation of your registration. This confirmation is necessary so that nobody can register with unfamiliar email addresses. The registration for the newsletter will be logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the email address, the registration and confirmation time, and also the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.


Registration data  

To subscribe to the newsletter, it is sufficient to enter your email address. Optionally, we ask you to specify a name and the title, for the purpose of the personal address in the newsletter.


Legal basis for data processing

The use of the shipping service provider, the implementation of statistical surveys and anonymous analyses, and the logging of the registration process, are based on your consent in accordance with Art. 6(1) lit. a of the GDPR. 


Shipping service provider

The newsletter is sent using the newsletter software of Inxmail GmbH, Wentzingerstr. 17, 79106 Freiburg, hereinafter referred to as "shipping service provider". An order processing contract has been concluded with the shipping service provider, which ensures that appropriate legal precautions and appropriate technical and organizational measures are taken to protect personal data in accordance with statutory provisions.

Newsletter tracking If the user has previously expressly consented, a newsletter tracking (also called web beacons or tracking pixels) is used. When delivering the newsletter, the external server can then record specific data of the recipient, such as the time of retrieval, the IP address or information on the email program (client) used. The name of the image file is customized for each mail recipient by appending a unique ID. The mailing sender remembers which email address belongs to which ID and can thus determine which newsletter recipient has just opened the email when the image is retrieved. 


Withdrawal / cancellation 

The user can unsubscribe from our newsletter at any time, i.e. revoke your consent. Your consent for sending the newsletters via the shipping service provider and the statistical analyses is also cancelled at the same time. A separate cancellation of the shipment by the shipping service provider and the personal evaluation is also possible. You will find a link to unsubscribe from the newsletter or revoke your consent to personal tracking at the end of each newsletter. If you have only subscribed to the newsletter and cancelled this subscription, your personal data will be deleted.   


The user can also revoke their consent to Columbus Leasing GmbH, Eywiesenstraße 6, 88212 Ravensburg, or by email at datenschutz@columbus.ag, at any time and without stating reasons, with effect for the future, or object to the processing of personal data in the same way. All personal data stored during the newsletter subscription will be deleted in this case.

 

8. Applications and application process

Description and scope of the data processing

We collect and process the personal data of applicants (the term "Applicant" is understood to be gender-neutral) for the purpose of handling the application process. The processing can also be done electronically. This is particularly the case if an applicant submits their application by electronic means, for example by email or via the web form on the website. No disclosure of the data is made to third parties in this context. The data will be used exclusively to process the application request.


Legal basis for data processing

The legal basis for the data processing of the application data is Art. 6(1) lit. b of the GDPR, as the transmission of the data is intended to conclude a contract (employment contract).


Purpose of data processing

The processing of personal data from the application and its attachments, whether via the application form or by email, is done solely to process the application. In the case of an application by email, this also includes the required legitimate interest in the processing of the data.

Duration of storage  If we conclude a contract of employment with the applicant, the data transmitted to us will be stored for the purpose of handling the employment relationship in compliance with the statutory provisions. If it does not result in the conclusion of an employment contract, the application documents will be deleted two months after notification of the rejection decision, provided that deletion does not conflict with any other legitimate interests on our part. A further legitimate interest in this sense is, for example, our burden of proof in proceedings under the General Equal Treatment Act (AGG). 


Right to opposition / cancellation 

The applicant has the option at any time to revoke their consent to the processing of the personal data. If the applicant sends their documents to us by email, they may object to the storage of their personal data at any time. In such a case, a further conversation and thus consideration in the application process can not take place.   


The applicant can revoke their consent to Columbus Leasing GmbH, Eywiesenstraße 6, 88212 Ravensburg, or by email at datenschutz@columbus.ag , at any time and without stating reasons, with effect for the future, or object to the processing of personal data in the same way. All personal data saved during the application will be deleted in this case.

 

9. Use of cookies

Our website uses cookies. Cookies are text files that are stored in the Internet browser or stored on the user's computer system by the Internet browser. When a user visits a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is reopened.   


The data of the users collected in this way are pseudonymised by technical means. An assignment of the data to the calling user is therefore no longer possible. The data will not be stored together with other personal user data.   


When accessing our website, users are informed by an info banner about the use of cookies for analytical purposes and referred to this Privacy Policy and the opt-out options. 


  • Session cookies: are automatically deleted if the user closes the browser after visiting a website. Session cookies store the so-called session ID, with which various requests from the browser can be assigned. This allows the computer to be recognized when the user returns to the respective website. 
  • Persistent / permanent cookies:  Cookies whose information remains stored for a certain period of time or indefinitely, even after visiting a website and after closing the browser. Users can delete persistent cookies at any time using the settings in the browser. 
  • Third party cookies: Cookies that originate from third parties and can be recognized by them.

We use the following cookies on our web pages:

  • _ga, _gat, _gid (Google Analytics)
  •  cookieconsent_dismissed (persistent cookie) places and removes the cookie notice on the website 
  • WSESSIONID (Weblication) 
  • WM_DONT_COUNT (Wiredminds) is placed when the opt-out is used

If a user does not want to have cookies stored on their computer, they should deactivate the corresponding option in the system settings of their browser. Already saved cookies can also be deleted in the system settings of the browser.   


Further information can be found on the following websites: 

  

 

10. Server log files

When accessing the website, the following data is automatically transmitted to the web server for technical reasons:

      

  • Date and time of retrieval of our web pages, including time zone difference to Greenwich Mean Time (GMT)
  •  Retrieved file/page or size of sent file
  •  Browser type and version
  •  Operating system
  •  URL of the referring website
  •  Your IP address

A merger of this data with other data sources will not be conducted. Assignment of this data to a specific person is not possible. The stored data will only be evaluated internally and exclusively for statistical purposes.

 

11. Disclosure of data to third parties and third party providers

Disclosure of data to third parties only occurs within the scope of legal requirements. We only disclose the data of users to third parties if, for example, this is required on the basis of Art. 6(1) lit. b) GDPR for contractual purposes or based on legitimate interests relating to the economic and effective operation of our business operations in accordance with Art. 6(1) lit. f. of the GDPR.   


If we use subcontractors to provide our services, we take appropriate legal precautions and appropriate technical and organizational measures to safeguard personal data in accordance with the law.

If, within the framework of this Privacy Policy, content, tools or other means are used by other providers (collectively referred to as "third party providers") and their registered office is located in a third country, it should be assumed that data will be transferred to the countries of residence of the third party providers. Third countries are to be understood as countries in which the GDPR is not directly applicable law, i.e. generally countries outside the EU or the European Economic Area. The transfer of data to third countries occurs either when there is an adequate level of data protection, the consent of the user or other legal authorization.

 

12. Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6(1) lit. f of the GDPR), we make use of content or services offered by third-party providers within our online offering in order to integrate their content and services, such as videos or fonts (collectively referred to as "content").   


The following presentation provides an overview of third-party providers as well as their content, in addition to links to their privacy policies, which contain further notes on the processing of data and, in some cases already mentioned here, possibilities to object (so-called opt-out): 


    • Bot detection function, e.g. "ReCaptcha" from Google, Inc. for entries in online forms. By using this service, it can be distinguished whether the corresponding input is of human origin or done improperly by automated machine processing. To our knowledge, the referrer URL, the IP address, the behaviour of website visitors, information about the operating system, browser and duration, cookies, presentation instructions and scripts, the input behaviour of the user and mouse movements in the "reCAPTCHA" checkbox area are collected. Google is certified under the Privacy Shield Agreement, and thereby provides a guarantee to comply with European data protection law. 
      Privacy Policy 
      Opt-Out
      • Videos from the "YouTube" platform of the third-party provider Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. 
        Privacy Policy 
        Opt-Out
      • Link to the social network XING operated by XING SE, Danntorstraße 30, 20354 Hamburg, Germany. 
        Privacy Policy
      • Link to the social network LinkedIn, which is operated by the LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043 USA. Data protection issues outside of the US are the responsibility of LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
        Privacy Policy
        Cookie Policy
        Opt-Out
       

      13. Web analytics Wiredminds

      Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6(1) lit. f of the GDPR), we use wiredminds (www.wiredminds.de), a web analytics service from Wiredminds GmbH to analyse visitor behaviour.   


      If necessary, data is collected, processed and stored, from which user profiles are created under a pseudonym. Wherever possible and practical, these user profiles are completely anonymised. Cookies can be used for this purpose. Cookies are small text files that are stored in the visitor's Internet browser and serve to identify the Internet browser. The collected data, which may also contain personal data, are transmitted to wiredminds or collected directly by wiredminds.

      Wiredminds may use information that is left by visits to the websites to create anonymised user profiles. The data obtained will not be used to personally identify the visitor to this website without the separately granted consent of the data subject, and they will not be merged with personal data about the bearer of the pseudonym. Where IP addresses are recorded, their immediate anonymisation is done by deleting the last number block.   


      Data collection, processing and storage may be objected to at any time with future effect. Clicking on the following link objects to the use of the visitor data and website tracking is completely prevented:


      Exclude from site tracking

       

      14. Use of Google Analytics

      Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6(1) lit. f of the GDPR), we use Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google uses cookies, which are text files that are stored on the user's computer and allow an analysis of the use of the website. The information generated by the cookie about the use of this website is usually transmitted to a Google server in the USA and stored there. We only use Google Analytics with activated IP anonymisation. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.  


      On our behalf, Google will use this information to evaluate the 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. Google is certified under the Privacy Shield Agreement, and thereby provides a guarantee to comply with European data protection law.

      The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies using the appropriate setting on their browser software; users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offering and to the processing of such data by Google by downloading and installing the browser plug-in available under the following link: Browser plug-in


      As an alternative to the browser plug-in or within browsers on mobile devices, the following link applies in order to place an opt-out cookie, which prevents future detection by Google Analytics within this website in the browser used:

      Opt-Out


      For more information about data usage by Google, setting and contradictory options, visit the websites of Google:


       

      15. Right to information, blocking, deletion, limitation of processing

      Users may at any time request free information about their stored data or correction, blocking, limitation of processing and deletion of their stored data and their processing. 

      Please contact our data protection officer by email at   datenschutz@columbus.ag.

       

      16. Right to data portability

      Users have the right to receive personal data concerning them, whose processing is based on a consent or contract, in a structured, standard format.

       

      Users may object to the processing of their personal data in accordance with legal requirements at any time. This right includes the right to revoke a data protection approval prior granted by the user for processing. 

      The user can revoke their consent to Columbus Leasing GmbH, Eywiesenstraße 6, 88212 Ravensburg, or by email at datenschutz@columbus.ag, at any time and without stating reasons, with effect for the future.

       

      18. Right to object

      Users have the right at any time to object to the processing of personal data concerning them, which takes place on the basis of Art. 6(1) lit. e or f of the GDPR.   


      The responsible party will no longer process the personal data concerning him or her unless it can demonstrate compelling legitimate grounds for processing that outweigh the interests, rights and freedoms of the users, or the processing is for the purpose of enforcing, pursuing or defending legal claims.

      The user can object to the processing of their personal data to Columbus Leasing GmbH, Eywiesenstraße 6, 88212 Ravensburg, or by email at datenschutz@columbus.ag, at any time and without stating reasons, with effect for the future.

       

      Stand: 23.05.2018

      Columbus Leasing   |    Eywiesenstraße 6, 88212 Ravensburg   |    T +49 751 36344 200   |   F +49 751 36344 900   |    leasing@columbus.ag