Privacy Policy Sandler Group

 

This Privacy Policy was last updated and is effective as of December 11th, 2023

This Privacy Policy (this “Privacy Policy”) applies to personal data and other personal information that is collected, maintained, used, or otherwise processed by Sandler AG and its subsidiaries (the “Company”, “we”, “us” or “our”) through one or more websites (each a “website“) for the Sandler Group of companies when you access the website.

 

A. General Privacy Policy Information and GDPR Provisions

 

1. An overview of data protection

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Privacy Policy which we have included beneath.

 

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

 

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

 

2. Hosting

We host the contents of our website with the following providers:

 

DomainFactory

The provider is the DomainFactory GmbH, c/o WeWork, Neuturmstraße 5, 80331 München, Germany (hereinafter referred to as: DomainFactory). Whenever you visit our website, DomainFactory records a variety of logfiles, including your IP addresses.

For details, please refer to the Privacy Policy of DomainFactory: https://www.df.eu/de/datenschutz/

We use DomainFactory on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in making the depiction of our website as dependable as possible. If you have been asked for your respective consent, processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, if the consent comprises the archiving of cookies or access to information on the user’s device (e.g., device finger printing) as defined in the TTDSG. Such consent may be revoked at any time.

We collect your data as a result of your sharing of your data with us. This may, for instance be information you

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

 

Amazon Web Services (AWS)

The provider is the Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter referred to as “AWS”).

When you visit our website, your personal data will be processed on AWS servers. This may also result in the transfer of personal data to the parent company of AWS in the United States. The transfer of data to the US is based on the EU’s standard contractual clauses. For details please consult: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.

For more information, please see the AWS Data Privacy Policy: https://aws.amazon.com/de/privacy/?nc1=f_pr

AWS is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in a depiction of our website that is as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

We collect your data as a result of your sharing of your data with us. This may, for instance be information you

Data processing

We have concluded a data processing agreement (DPA) with Opus, Am Pfaffenfleck 10, 95448 Bayreuth, Germany for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR

 

3. General information and mandatory information

 

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

 

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Sandler AG
Lamitzmühle 1
95126 Schwarzenbach/Saale, Germany

Phone: +49 (0) 9284 / 60 - 0
E-mail: info@sandler.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

 

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

 

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

 

Designation of a data protection officer

We have appointed a data protection officer.

Claus Baumgärtner,
Datenschutzbeauftragter

E-mail: datenschutz@sandler.de

 

Information on data transfer to the USA and other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

 

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

 

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

 

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

 

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

 

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

 

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

 

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

 

4. Recording of data on this website

 

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

 

Consent with Usercentrics

This website uses the consent technology of Usercentrics to obtain your consent to the storage of certain cookies on your device or for the use of specific technologies, and to document the former in a data protection compliant manner. The party offering this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 München, Germany, website: https://usercentrics.com/ (hereinafter referred to as “Usercentrics”).

Whenever you visit our website, the following personal data will be transferred to Usercentrics:

  • Your declaration(s) of consent or your revocation of your declaration(s) of consent
  • Your IP address
  • Information about your browser
  • Information about your device
  • The date and time you visited our website

Moreover, Usercentrics shall store a cookie in your browser to be able to allocate your declaration(s) of consent or any revocations of the former. The data that are recorded in this manner shall be stored until you ask us to eradicate them, delete the Usercentrics cookie or until the purpose for archiving the data no longer exists. This shall be without prejudice to any mandatory legal retention periods.

Usercentrics uses cookies to obtain the declarations of consent mandated by law. The legal basis for the use of specific technologies is Art. 6(1)(c) GDPR.

 

Data processing

We have concluded a data processing agreement (DPA) with Opus, Am Pfaffenfleck 10, 95448 Bayreuth, Germany for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

 

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

 

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

 

5. Analysis tools and advertising

 

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

 

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Google Signals

We use Google Signals. Whenever you visit our website, Google Analytics records, among other things, your location, the progression of your search and YouTube progression as well as demographic data (site visitor data). This data may be used for customized advertising with the assistance of Google Signal. If you have a Google account, your site visitor information will be linked to your Google account by Google Signal and used to send you customized promotional messages. The data is also used to compile anonymized statistics of our users’ online patterns.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

 

6. Plug-ins and Tools

 

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

 

Vimeo Without Tracking (Do-Not-Track)

This website uses plugins of the Vimeo video portal. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.

Whenever you visit one of our pages featuring Vimeo videos, a connection with the servers of Vimeo is established. In conjunction with this, the Vimeo server receives information about which of our sites you have visited. Vimeo also receives your IP address. However, we have set up Vimeo in such a way that Vimeo cannot track your user activities and does not place any cookies.

We use Vimeo to make our online presentation attractive for you. This is a legitimate interest on our part pursuant to Art. 6(1)(f) GDPR. If a respective declaration of consent was requested (e.g. concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR; the given consent may be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here: https://vimeo.com/privacy.

For more information on the handling of user data, please consult Vimeo’s data privacy policy at: https://vimeo.com/privacy

 

7. Custom Services

 

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

 

B.  U.S. Privacy Addendum

This portion of the Privacy Policy addresses additional rights and related matters concerning U.S. users of the website.  As used in this portion of the Privacy Policy “personal information“ means infomation about or that can be used to identify a natural person and such other meaning as ascribed to such term under applicable state privacy laws in the United States.

 

How We Use The Information We Collect

We use information that you provide to us, including any personal information, to:

  • Provide you with the website and its contents, and any other information that you request from us
  • Fullfill any purpose for which you provide it
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
  • Notify you when updates for the website are available, and of changes to any products or services we offer or provide though it
  • Develop and improve the website, products and services
  • Provide you with support and to respond to your inquiries, including to investigate and address you concerns and monitor and improve our responses
  • Respond to law enforcement requests, or as required by applicable law, court oder, or governmental rehulations
  • Receive communications from us if you agree to receive emails or other communications from us

The information that we collect automatically helpsus to improve the website and to deliver a better and morge personalized experience by enabling us to:

  • To analyze trends, administer the website, track your navigation around the website, and gather anonymous demographic information for the purpose of improving the website
  • Estimate our audience size and usage patterns
  • Store information about your preferences, allowing us to customize the website according to your individual interests
  • Speed up your searches
  • Recognize you when you use the website

Disclosure of Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual without restriction.

In addition, we may disclose information, that may include personal information:

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the website’s users is among the assets transferred
  • For any other purpose disclosed by us when you provide the information
  • With your consent
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request
  • To enforce our rights arising from any contracts entered into between you and us and for billing and collection
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others

Your Choices About Our Collection, Use, and Disclosure of Your Information

You have many choices with regards to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system, but if you choose to block or delete cookies, it may limit your use of certain features or functions on the website. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.

This section describes mechanisms that we provide for you to control certain uses and disclosures of your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you disable or refuse cookies or block the use of other tracking technologies, some parts of the website may then be inaccessible or not function properly. 
  • Promotions by the Company.  Users may request to be removed from mailing lists at any time

To review or request corrections to your personal information collected by us or removal from any promotional communications, please contact us by one of the means noted below under “Contact Us”.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.

Nevada residents who wish to exercise their sales opt-out rights under Nevada Revised Statutes Chapter 603A may submit such request by sending an email to datenschutz@sandler.de or calling us at +49 9284 60 0.  

Colorado, Connecticut, Virginia, and Utah each provide their residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

For residents of Colorado, Connecticut, Nevada, Virginia, and Utah to exercise the above rights, please contact us (“Consumer Rights Request”) (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at datenschutz@sandler.de or (ii) by regular mail at Sandler AG, c/o Datenschutzbeauftragter, Lamitzmuehle 1, 95126 Schwarzenbach /Saale, Germany 

For residents of Colorado, Connecticut, and Virginia, if we decline to take action on your Consumer Rights Request, you may appeal such refusal (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at datenschutz@sandler.de or (ii) by regular mail at Sandler AG, c/o Datenschutzbeauftragter, Lamitzmuehle 1, 95126 Scharzenabch /Saale, Germany within a reasonable time period after we sent you our decision.
 

Third-Party Information Collection

Generally

When you use the website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies.
  • Your mobile device manufacturer.
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Other Sites 

We are not responsible for the practices employed by websites linked to/from the website nor the information contained therein. Often links to other websites are provided solely as a way for the user to obtain information that may be useful to them. The third party’s privacy policy and/or that of its service provider will govern the use of this information, and we are not responsible for the privacy practices of such companies. To better protect your privacy, we encourage you to read these businesses’ privacy policies to learn about how they treat your information.

Social Media Sites

You may share information from the website with people associated with your social media account and your social media account provider. By sharing this information, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s privacy policy. Please note that any information you post within these public forums or social media pages may become public and may be read, collected, and used by anyone. If you don’t want people to know your email address, for example, don’t include it in any message you post publicly. Please exercise caution when deciding whether to disclose your personal information in public posting areas. We are not responsible for the use by others of the information that you disclose in public posting areas.

Security Measures

We have taken certain precautions that are intended to protect the users of the website’s information. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password and/or user name for access to certain parts of our Platform, you are responsible for keeping such password and user name confidential. We ask you not to share your password or user name with anyone. Because the information you share in public areas may be viewed by other users of the website, we urge you to be careful about giving out information in public areas of the website, such as message boards.

Notwithstanding our efforts, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information transmitted to us, and you transmit such information at your own risk. You are responsible for keeping the information you provide confidential. We are not responsible if someone else accesses your account through information they have obtained from you or through a violation by you of this Policy or our Terms of Service. 
 

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the website and visiting your account profile page. You may also send us an email at datenschutz@sandler.de to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users of the website.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.

Do Not Track

The website does not respond to web browser “do not track” signals or other similar mechanisms.

Retention of Your Information

Our policy is to retain personal information only for as long as is necessary to fulfill the reason for which the personal information was collected and as necessary to process such personal information. In addition to the above, we will retain your personal information for the purposes of satisfying any professional, legal, accounting or reporting requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we collected and processed your personal information and whether we can reasonably achieve those purposes through other means, as well as any applicable legal and professional requirements.

Children or Adolescents

The website is intended strictly for adult users. By agreeing to this policy through use of the site, the user is verifying that they are an adult aged 18 or older. We do not knowingly collect personal information from children under the age of 18. If we discover or are made aware that we have received personal information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will delete such information from our systems.  If you are a parent or legal guardian of a child under the age of 18 and believe that your child has disclosed personal information to us we welcome you contacting us as provided below so that we can address such matter. 

From time to time there may be instances when we collect information through the website about children under the age of 18 but we will only do this when such information is provided to us by that child’s parent or legal guardian.  In all cases where we’ve collected information about a child under the age of 18, the parent or legal guardian may contact us via email or regular mail using the contact information noted below under “Contact Us”, to review and request deletion of such child's personal information as well as to prohibit the further use of such information by us.

California Minors. California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your California Privacy Rights” below for more information.

Linking Policy

We permit text links to the website. However, linking should not: suggest or falsely claim endorsement or affiliation with us; be used for commercial or fundraising purposes; or conceal the fact that the reader has left the linking site.  We reserve the right to withdraw permission for any link at any time. Please contact us with any related questions by using one of the means noted below under “Contact Us”.

Updates to Our Privacy Policy

We may update this Policy from time to time. We will notify you by posting the new Privacy Policy on this page, and we will update the “Last Updated” date at the top of this Policy. We will let you know via email and/or a prominent notice on our Services, in the event of a material change. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

Download here

Your California Privacy Rights

The following additional privacy notices for California residents (the “California Notice”) supplement the information contained in the other portions of this Privacy Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). The Company adopts this California Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and their related regulations (collectively the “California Privacy Law” or the “CPL”) and other applicable California laws.

Overview of Consumer Rights Under the CPL—California Consumers

Under the CPL, California consumers have certain rights regarding their personal information, including:

  • The right to know the categories of personal information that the Company has collected and the categories of sources from which we obtained such information.
  • The right to know the Company’s business purposes for sharing personal information.
  • The right to know the categories of third parties with whom the Company shared personal information.
  • The right to know if we sold or disclosed your personal information for a business purpose, comprising two separate lists disclosing:
  • Any sales, which list identifies the personal information categories that each category of recipient purchased (note that at present we do not sell personal information that we collect); and
  • Any disclosures for a business purpose, which list identifies the personal information categories that each category of recipient obtained.
  • The right to access the specific pieces of personal information that the Company has collected
  • The right to correct personal information that the Company has collected.
  • The right to delete your personal information.
  • The right to not be discriminated against if you exercise your rights under the CPL.

The provisions below of this California Notice provide further details about these and other rights and certain details about the exercise of such rights.

Information We Collect—California Consumers

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (collectively, “personal information”). Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated California consumer information.
  • Information excluded from the CPL’s scope, including:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • Personal information covered by certain other laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information from consumers within the last twelve (12) months: 

Category

Examples

A.     Identifiers

An individual’s name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers.

B.     Personal information categories described in Cal. Civ. Code § 1798.80(e)

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information (Note: Certain of the above information may be considered to be sensitive personal information under the CPL and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.)

C.    Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D.    Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E.     Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F.     Internet or other similar network activity

Browsing history, search history, information on a California consumer's interaction with our website, application, or advertisement and any social media sites from which user information is linked, connected or obtained.

G.    Geolocation data

Physical location or movements (Note: Certain precise geolocation data may be considered to be sensitive personal information under the CPL and, to the extent such data is considered to be sensitive personal information you have the right to limit the use and disclosure of such data.)

 

H.    Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

I.       Professional or employment-related information.

Current or past job history or performance evaluations.

J.      Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K.     Inferences drawn from other personal information

Examples include a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

 

Sources of Personal Information—California Consumers

  • In addition to sources of personal information addressed elsewhere in this Policy, we obtain the categories of personal information listed above from the following categories of sources:
  • Directly from You. For example, from forms you complete or products and services you purchase or from communications with you such as when you contact the Company (whether in person, by mail, by phone, online, via electronic communication or by other means) including our customer support service.
  • Indirectly from You. For example, from observing your actions on the website or from products or services that you have purchased from the Company, if you have enabled such functionality, such as telemetry services.
  • From Others.
  • From third party service providers. For example, if you choose to make an electronic payment directly to the Company, or through a linked website or mobile application, or through an affiliate of ours, the Company may receive personal information about you from third parties such as payment services providers, for the purposes of that payment.
  • From affiliates. We may collect personal information about you from our affiliates or others acting on their behalf.
  • From Public Sources. For example, we may collect information from public records.
  • Uses of Personal Information

In addition to uses of personal information addressed elsewhere in this Policy, we may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill the reason that you provided the information. For example, if you share your name and contact information to request a price quote, request to be contacted by an affiliate, or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we may use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders or to process returns.
  • To perform services such as customer service, order fulfillment, payment processing, financing and advertising, marketing or analytic services.
  • To advance our commercial or economic interests, such as by helping you to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.
  • To verify or maintain quality or safety standards or improve or upgrade a product or service provided or controlled by or for us.
  • To provide, support, personalize and develop the website, products and services such as to perform warranty related services or other post-sale activities such as product or service monitoring or repairs.
  • To create, maintain, customize and secure your account with us.
  • To process your requests, purchases, transactions and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the website, third-party sites and via mail, email or text message (with your consent, where required by law).
  • To help maintain the safety, security and integrity of the website, products and services, databases and other assets and business.
  • For testing, research and analysis purposes, including to develop and improve the website, products and services.
  • To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CPL or applicable law.
  • To send you information relevant to your past purchases and interests, subject to compliance with applicable laws regarding direct marketing.
  • To otherwise use as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting personal information and as compatible with the context in which we collected the information.
  • To perform services on behalf of a CPL-covered business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services.
  • To review and audit our business interactions with you.
  • To detect or prevent security incidents or other illegal activity.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the website users, including California consumers, is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing Personal Information - California Consumers

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

  • A.     Identifiers.
  • B.     Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • C.     Protected classification characteristics under California or federal law.
  • D.     Commercial information.
  • E.     Biometric information.
  • F.     Internet or other similar network activity.
  • G.    Geolocation data.
  • H.    Sensory data.
  • I.      Professional or employment-related information.
  • J.      Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  • K.     Inferences drawn from other personal information.

The categories of third parties to which we may disclose personal information collected by us include the following:

  • Service providers
  • Affiliates
  • Recipients of data from cookies

Sharing Personal Information - California Consumers

The Company does not sell personal information to third parties. 

Exercising Your CPL Rights and Choices – California Consumers

The sections below describe how you may exercise your rights under the CPL.

Exercising Your CPL Rights and Choices – Access to Specific Information and Data Portability Rights—California Consumers.

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights – California Consumers” below), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, a list disclosing the personal information categories that each category of recipient obtained.

Exercising Your CPL Rights and Choices – Deletion and Correction Request Rights – California Consumers.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, Deletion and Correction Rights – California Consumers” below), we will delete (and direct our service providers to delete) your personal information from our (and service provider) records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products or services to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another California consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with California consumer expectations based on your relationship with us, such as future field campaigns or product safety issues.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

In addition, if you provide us with a verifiable consumer request to correct inaccurate personal information that we maintain about you, we will use commercially reasonable efforts to correct such information in accordance with your instructions.

Exercising Your CPL Rights and Choices – Exercising Access, Data Portability, Deletion and Correction Rights – California Consumers.

To exercise the access, data portability, deletion and correction rights described above, you should submit a verifiable consumer request to us by one of the following methods:

  • Emailing us at datenschutz@sandler.de
  • By postal mail at Sandler AG, c/o Datenschutzbeauftragter, Lamitzmuehle 1, 95126 Schwarzenbach /Saale, Germany
  • Accessing your online account that you maintain with us.
  • By calling us at +49 9284 60 0

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of a minor child for whom you are a parent or legal guardian.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include:

  • Your name
  • Your address
  • Additional information depending upon the type of request and the sensitivity of the information involved with such request
  • Describe your request with sufficient detail to enable us to properly understand, evaluate and respond to such request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information involved with the request relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we will consider requests made through a password-protected online account that you maintain with us to be sufficiently verified when the request relates to personal information associated with that online account, provided such online account functionality is then made available by us on the website.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Exercising Your CPL Rights and Choices – Response Timing and Format – California Consumers

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an online account with us, we may deliver our written response to that online account, provided that such online account functionality is then made available by us on the website. If you do not have an online account with us, or such functionality is not available for your online account we will deliver our written response by mail or electronically, at your option.

If we’re unable to comply with your request, the response we provide will also explain the reasons we cannot comply with the request. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Exercising Your CPL Rights and Choices – Response Timing and Format – California Consumers

We will not discriminate against you for exercising any of your CPL rights. Unless permitted by the CPL or other applicable law, we will not as a result of you exercising any of your rights under the CPL:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CPL that can result in different prices, rates, or quality levels. Any CPL-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Retention of Personal Information – Notice to California Consumers.

Our policy is to retain personal information only for as long as is necessary to fulfill the reason for which the personal information was collected and as necessary to process such personal information. In addition to the above, we will retain your personal information for the purposes of satisfying any professional, legal, accounting or reporting requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we collected and processed your personal information and whether we can reasonably achieve those purposes through other means, as well as any applicable legal and professional requirements.

Other California Privacy-Related Disclosures

Sharing Personal Information for Direct Marketing Purposes.

Before sharing personal information of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.

California Do-Not-Track Disclosure.

At this time, the website is not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.

Information on Marketing Disclosures.

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at: (i) by email (writing “Privacy Policy/Removal Request” in the subject line), or (ii) by regular mail, as applicable, by using the contact information under “Contact Us” below.

Content Removal Requests for Website Users Under 18 Years Old.

If you are a user of the website under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the website. You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy/Removal Request” in the subject line) at datenschutz@sandler.de or (ii) by regular mail at Sandler AG, c/o Datenschutzbeauftragter, Lamitzmuehle 1, 95126 Schwarzenbach/Saale, Germany, We will review the request and respond promptly.  You should be aware that a request to remove content or information posted by you on the website does not ensure or require complete or comprehensive removal of such content or information from our databases.

Complaints

If you have any complaint about use of the website, you may contact the Company in writing via email or regular mail by using the contact information under “Contact Us” below.  In accordance with California Civil Code Section 1789.3, California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210.

Changes to Our California Notice

We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will post the updated California Notice on the website and update the Privacy Policy effective date. Your continued use of the website following the posting of changes constitutes your acceptance of such changes.

 

C. Contact Us

If you have any questions about matters addressed in this Privacy Policy, please contact us by one of the following methods:

By Mail:          Sandler AG 
                                  Lamitzmühle 1
                        95126 Schwarzenbach/Saale, Deutschland
 

By E-mail:       Datenschutz@sandler.de

By Phone:       +49 9284 60 0