1. introduction

In the following, we inform about the processing of personal data when using

our website www.voltaro.de
of our profiles in social media.

Personal data is any data that can be related to a specific natural person, e.g. their name or IP address.

1.1. contact details

The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Voltaro Energy GmbH, Goethestraße 28, 80336 Munich, Germany, email: info@voltaro.de. We are legally represented by Jannik Kupke, Alessandro Mauri.

Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal basis

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

Art. 6 (1) p. 1 lit. a DSGVO serves as the legal basis for processing operations for which we obtain consent.
Art. 6 para. 1 p. 1 lit. b DSGVO is the legal basis insofar as the processing of personal data is necessary for the fulfillment of a contract, e.g. when a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
Art. 6 (1) p. 1 lit. c DSGVO applies if we fulfill a legal obligation with the processing of personal data, as may be the case, for example, in tax law.
Art. 6 (1) p. 1 lit. f DSGVO serves as the legal basis when we can invoke legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 para. 3 of the GDPR guarantee the security of the data during the transfer, insofar as these exist, as is the case, for example, for the United Kingdom, Canada and Israel.

If no adequacy decision exists (e.g., for the USA), the legal basis for the data transfer is usually, i.e., unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 (2) lit. b DSGVO, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies want to access data.

1.4. storage period

Unless expressly stated within the scope of this data protection declaration, 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, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for reasons of commercial or tax law.

1.5 Rights of the persons concerned

Data subjects have the following rights vis-à-vis us with regard to the personal data concerning them:

Right to information,
Right to rectification or deletion,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Right to revoke consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details for the data protection supervisory authorities can be found at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

In the context of a business relationship or other relationship, customers, interested parties or third parties only have to provide us with the personal data that is required for the establishment, implementation and termination of the business relationship or for the other relationship, or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automatic decision-making in individual cases

For the establishment and implementation of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 DSGVO. Should we use these procedures in individual cases, we will inform about this separately if this is required by law.

1.8 Contacting

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 p. 1 lit. f DSGVO) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit f DSGVO. We delete the data when the results of the surveys have been evaluated.

2. newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest lies in direct advertising (recital 47 DSGVO). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 (1) p. 1 lit. a DSGVO. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 p. 1 lit. a DSGVO), we also measure the opening and click-through rate of our newsletters to understand which content is relevant to our recipients.

We send newsletters using the HubSpot tool from the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/de/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the USA.

3. data processing on our website

3.1 Note for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions:

Insofar as this storage or access is absolutely necessary in order for us to provide the service of our website expressly requested by website visitors (e.g. to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 (2) no. 2 TTDSG.
Otherwise, this storage or access is based on the consent of the website visitors (§ 25 para. 1 TTDSG).

Downstream data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2 Informational use of the website

During the informational use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

These data are:

IP address
Date and time of the request
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (concrete page)
Access status/HTTP status code
Data volume transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.3 Web hosting and provision of the website

Our website is hosted by Strato. The provider is STRATO AG, Pascalstraße 10, 10587 Berlin. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://www.strato.de/datenschutz/.

It is our legitimate interest to provide a website, so that the legal basis of the described data processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

3.4 Contact form

When contact is made via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in responding to inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.
We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.5 Job advertisements

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.
The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) DSGVO in conjunction with Section 26 (1) BDSG. We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 p. 1 lit. a DSGVO).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their resumes and cover letters. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 (2) a DSGVO).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 p. 1 lit. a DSGVO.

We pass on the applicants' data to the responsible employees in the HR department, to our order processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to also use their data for further application procedures, we will not delete their data until one year after receipt of the application.

3.6 Booking appointments

Site visitors can book appointments with us on our website. For this purpose, we process meta data or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly option for making appointments. Therefore, the legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Insofar as we use a tool from a third-party provider for the agreement, the information on this can be found under "Third-party providers".

3.7. third party suppliers

3.7.1 LinkedIn Insight Tag

We use LinkedIn Insight Tag for conversion tracking. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. a DSGVO. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.linkedin.com/legal/privacy-policy?

3.7.2 HubSpot

We use HubSpot to manage customer relationships. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in managing data in a simple and inexpensive way.

The data is deleted when the purpose for which it was collected no longer applies and there are no retention obligations to the contrary. Further information is available in the provider's privacy policy at https://legal.hubspot.com/privacy-policy.

3.7.3 Microsoft Clarity

We use Microsoft Clarity to identify business opportunities in our website visitors and for analytics. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

3.7.4 Google Tag Manager

We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is ensured by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

We delete the data when the purpose for collecting it no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.7.5 Webflow

We use Webflow to create websites. The provider is Webflow, Inc., 398 11th St., Floor 2, San Francisco, CA 94103, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.

We delete the data when the purpose for collecting it no longer applies. Further information is available in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.

3.7.6 HubSpot

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest in managing data in a simple and inexpensive way.

3.7.7 Microsoft Clarity

We use Microsoft Clarity to analyze and identify business opportunities in our website visitors. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

3.7.8 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

4. data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

4.1 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

Privacy policy