Thank you for visiting our website. The protection of your personal data (hereinafter referred to as “data”) is important to us.
As this data enjoys special protection, it is only collected by us (since our foundation in 2008) to the extent technically necessary, both within the scope of the website offer and within our entire company, for example for order processing.
The type, scope and purpose of the data processed are described below.

PRONEGO – Owner: Dr. Manuel Lamotte-Schubert
Provinzialstraße 92
66740 Saarlouis, Germany
Email: info@pronego.com
Phone: +496831 / 16 66-399
Fax: +496831 / 16 66-846

• Contact data (e.g. names, addresses, email, telephone numbers)
• Content data (e.g. text entries in the contact form)
• Usage data (e.g. websites visited and content, access times)
• Meta/communication data (e.g. device and browser information, IP addresses)
• Access data to servers and service accounts (only in the context of order processing)

• Visitors and users of the online offer
• Customers (in the context of order processing)

(hereinafter generally referred to as “users”.)

• Provision of the online offering with its functions and content
• Following up on inquiries submitted through the contact form
• Security measures
• Marketing/visitor logs
• Order processing

This section contains the definition of the required terminology in connection with the GDPR. In this context, we refer to Art. 4 of the General Data Protection Regulation (GDPR), where the terminology is explained in full. This applies in particular if a definition is missing in the following list.

• “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
• “Pseudonymization“ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
• “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements
• “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• “Cookies“ are small files that are stored on users‘ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status can be stored in such a cookie, for example. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).

In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this is only done on the basis of legal permission, you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, subcontractors, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to request the completion of incomplete personal data or the rectification of inaccurate personal data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.

You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

You have the right to withdraw your consent in accordance with Art. 7 para. 3 GDPR with effect for the future.

You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. Please note that in this case we will no longer be able to process any order for you (for example, if you withdraw your consent to the storage of your contact data).

We may use temporary and permanent cookies and provide information about this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, data is stored in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

We collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which our website is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a period of 1 month and then automatically deleted. Data whose further storage is required for evidentiary purposes is excluded from automatic deletion until the respective incident has been finally clarified.

We process our customers‘ data as part of our contractual services, which include conceptual and strategic consulting, in particular software and design development/consulting or maintenance, implementation of processes/handling, server administration, data analysis/consulting services and training services.

We process inventory data (e.g. customer master data such as names or addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries), contract data (e.g. subject matter of the contract, term), payment data (e.g. bank details, payment history), usage and metadata (e.g. as part of the evaluation and performance measurement of marketing measures) and access data. In principle, we do not process special categories of personal data, unless these are part of commissioned processing. The data subjects include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is required to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements of order processing in accordance with Art. 28 GDPR and do not process the data for any purposes other than those specified in the order. We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 J, according to § 257 para. 1 HGB, 10 J, according to § 147 para. 1 AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.

We process data in the context of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services (see previous point). The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.

We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and, if applicable, payment service providers.

We also store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We generally store this mainly company-related data permanently.

We process applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. Applicant data is processed to fulfill our (pre-)contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing becomes necessary for us, e.g. in the context of legal proceedings (in Germany, § 26 BDSG also applies).

The application process requires applicants to provide us with their application data. The necessary applicant data is derived from the job descriptions and generally includes personal details, postal and contact addresses and the documents relating to the application, such as cover letter, CV and references. Applicants can also voluntarily provide us with additional information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the type and scope set out in this privacy policy.

Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated as part of the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application process, their processing is also carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data if this is necessary for the exercise of the profession).

Applicants can send us their applications by email. Please note, however, that emails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We therefore cannot accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend sending it in encrypted form or by post in the form of printed documents.

The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the data will be deleted. Applicants‘ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Subject to a justified revocation by the applicant, the data will be deleted after a period of six months so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

When contacting us (e.g. by contact form, email, telephone or via social media), the user’s details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR. The user’s details are stored in a customer relationship management system (“CRM system”).

We delete the inquiries if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR) content or service offers from third-party providers in order to use their content and services, such as the integration of (third-party) libraries to display the page (hereinafter uniformly referred to as “content”).

This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content.