01 Data controller
The data controller, who is responsible for the collection, processing and use of your personal data within the meaning of Art. 4 para. 7 GDPR, is
Seven Principles Solutions & Consulting GmbH
If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations either as a whole or for individual measures, you can address your objection to the data controller.
02 General purposes of the processing
We use personal data for the purpose of operating the website, to process your enquiries in a business context, and to improve our web offering.
03 Which data we use and why
The hosting services we avail of are used to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating the Website.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, metadata and communication data of customers, potential customers and visitors to this Website on the basis of our legitimate interests in the efficient and secure provision of this Website according to Art. 6 para. 1 clause 1 f) GDPR in conjunction with Art. 28 GDPR.
03.2 Access data
We collect information about you when you use this Website. We automatically collect information about your usage behaviour and your interaction with us and record data about your computer or mobile device. We collect, store and use data about every instance of access to our Website (so-called server log files). The access data includes:
- Name and URL of the file(s) you retrieve/access
- Date and time of the access
- Data volume transferred
- Message about successful retrieval (HTTP response code)
- Browser type and version
- Operating system
- Referrer URL (i.e. the previously visited page)
- The websites that are accessed by the user’s system via our Website
- The user’s internet service provider
- The IP address and requesting provider
We use this log data without allocation to your person or other profiling for statistical evaluations for the purpose of operating, security and optimisation of our website, but also for anonymous recording of the number of visitors to our website (traffic) and the extent and type of use of our website and services, as well as for billing purposes in order to measure the number of clicks received from cooperation partners. This information enables us to provide personalised and location-based content, to analyse traffic, to detect and correct errors, and to improve our services.
We also have a legitimate interest in this pursuant to Art 6. para. 1 clause 1 f) GDPR.
We reserve the right to subsequently check the log data if, based on concrete indications or evidence, there is a justified suspicion of unlawful use. We also store IP addresses if we have reason to suspect that a criminal offence has been committed in connection with the use of our Website.
We use so-called session cookies to optimise our Website. A session cookie is a small text file that is sent by the server in question when you visit a website, and which is temporarily stored on your hard drive. This session cookie file stores a session ID, which makes it possible to track the various requests made by your browser during the joint session. This allows your computer to be recognised when you return to our Website. These cookies are deleted after you close your browser. They serve, e.g., to prevent the cookie banner from being displayed repeatedly.
To a small extent, we also use persistent cookies (another type of small text file that is stored on your device), which remain on your device and enable us to recognise your browser the next time you visit our Website. These cookies are stored on your hard disk and are deleted automatically after a specified time. Their life span is between 1 month and 10 years. These cookies enable us to present our offering in a more user-friendly, effective and secure manner and, for example, to display information on the site that is specifically tailored to your interests.
The following data and information is stored in the cookies:
- Login information
- Language settings
- Search terms entered
- Information about the number of visits to our Website and use of individual features on our Website.
When a cookie is activated, it is assigned an identification number, but your personal data will not be mapped to this identification number. Your name, IP address or similar data that would allow the cookie to be traced to you does not get placed in the cookie. Based on the cookie technology, we only receive pseudonymised information.
You can set your browser so that you are informed in advance about cookies being set and can decide in individual cases whether you want to exclude cookies from being accepted in specific cases or in general, or can prevent cookies entirely. However, this may restrict the functionality of the Website.
3.4 Cookie banner
Data in order for us to fulfil our contractual obligations
We process personal data that we need in order to fulfil our contractual obligations, such as name, address, email address, ordered products, and billing and payment data. This data needs to be collected in order to conclude the contract.
The data will be deleted after expiry of the warranty periods and statutory retention periods. Data that is associated with a user account (see below) will always be retained for the duration the account is maintained for.
The legal basis for the processing of this data is Art. 6 para. 1 clause 1 b) GDPR, because this data is required in order for use to be able to fulfil our contractual obligations to you.
3.6 Contacting us
If you contact us (e.g., via our contact form or email), we will process your details in order to handle your enquiry and in the event that any follow-up questions arise.
If the data processing takes place in order to execute pre-contractual measures that are taking place at your request or, if you are already a customer of ours, in order to execute the contract between us, then the legal basis for this data processing is Art. 6 para. 1 clause 1 b) GDPR.
We will only process further personal data if you give your consent to this (Art. 6 para. 1 clause 1 a) GDFPR) or we have a legitimate interest in the processing of your data (Art. 6 para. 1 clause 1 f) GDPR). There is a legitimate interest, for example, in replying to your email. Consent given can be revoked at any time, with effect for the future.
3.7 Data protection information for applicants
Various media are used by SEVEN PRINCIPLES AG as part of employee recruiting.
In addition to postal applications, these can also be sent by e-mail, via the SEVEN PRINCIPLES AG website (online application), application portals and commissioned recruiting companies.
We process the data that you have sent us in connection with your application in order to check your suitability for the position (or other open positions in our company, if applicable) and to carry out the application process.
On what legal basis is that?
The legal basis for the processing of your personal data in this application process is primarily Section 26 BDSG in the version applicable from May 25, 2018. Thereafter, the processing of the data is permitted that is necessary in connection with the decision on the establishment of an employment relationship.
Should the data be required for legal prosecution after the application process has been completed, data processing can be carried out on the basis of the requirements of Art. 6 GDPR, in particular to safeguard legitimate interests according to Art. 6 Para. 1 clause 1f) GDPR. Our interest then lies in the assertion or defense of claims.
How long will the data be stored?
Applicants’ data will be deleted after 6 months in the event of rejection.
If you have consented to your personal data being stored further, we will transfer your data to our applicant pool. There the data will be deleted after two years.
If you have been accepted for a position as part of the application process, the data will be transferred from the applicant data system to our personnel information system.
To which recipients is the data passed on?
After Stepstone has collected your data and transmitted it to us, all applications (regardless of their input channel) are immediately transferred to the applicant management system and processed there. This is followed by a pre-selection and forwarding to the requesting specialist departments. Data can be passed on to authorities for review on the basis of official requirements (e.g. recruitment of applicants from outside the EU). In addition, the data will not be passed on to third parties.
The provider of our applicant management system is
New Work SE
Am Strandkai 1
4 Social Media
This website uses links to our presences on social media pages. The data protection and liability regulations of the respective providers, which you can access as described below, apply to these presences.
We process your data for the purpose of effectively informing and supporting our customers and interested parties. This is our legitimate address according to Art. 6 Para.1 clause 1f GDPR. The processing takes place based on the declaration of joint responsibility (https://www.facebook.com/legal/terms/page_controller_addendum).
The service provider is Meta Platforms Inc.
Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, is responsible for the European region.
Provider: Twitter, Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA
Provider: New Work SE, Am Strandkai 1, 20457 Hamburg
Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
Data protection: https://www.linkedin.com/legal/privacy-policy
5 Information on the service providers used
In order to operate this Website, we integrate external services in order to make our Website more user-friendly, more effective and more secure. We have a legitimate interest in this pursuant to Art 6. para. 1 clause 1 f) GDPR.
We expressly point out that some of the service providers we use are located in unsafe third countries or transmit data to unsafe third countries (e.g. USA). According to the European Court of Justice, there is no adequate level of protection in these states. The transfer to these countries only takes place after consent has been given.
5.1 Mittwald CM Service GmbH & Co.KG
We use the services of Mittwald CM Service GmbH & Co.KG Königsberger Str. 4 – 6, 32339 Espelkamp, Germany to host our website. The hosting is carried out exclusively on German servers.
Please read here how Mittwald complies with data protection regulations: https://www.mittwald.de/datenschutz
By concluding an order processing agreement, we have obliged Mittwald to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.
We use Mittwald based on Art. 6 Para. 1 clause 1 f) GDPR. Our legitimate interest here lies in the secure and efficient provision and optimisation of our online offering.
5.2 Borlabs Consent Management
This website uses Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) to store your cookie consents.
Borlabs cookie does not process any personal data.
The borlabs-cookie stores the consent you gave when you entered the website. If you wish to revoke these consents, simply delete the cookie in your browser. When you re-enter/reload the website, you will be asked again for your cookie consent.
5.3 Google Maps
To make it easier for you to find our location, we use Google Maps, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
We use Google Maps on the basis of your consent in accordance with Art. 6 para. 1 p. 1 a) DSGVO and § 25 para. 1 TTDSG.
The purpose of the use is to improve our offer on our website and to provide you with better customer service.
As soon as this service is called up on our site, a connection is established to Google, which transmits your IP address to Google. If you are already logged in to Google, information about the search can be assigned to your user account. Please log out of Google beforehand to prevent this.
Please read here how Google complies with the data protection regulations, also with regard to the transmission to the USA: https://policies.google.com/privacy?hl=en-GB
5.3 HubSpot Forms
We have integrated HubSpot Forms on our website. HubSpot Forms is a service of HubSpot, Inc. and offers marketing automation software for marketing services and products, including SEO and content creation, lead management, email marketing and web analytics.
HubSpot Forms is used to store data entered in forms, e.g. when contact is made via a contact form. The data entered may be stored in our customer relationship management system (CRM system).
In this case, your data is passed on to the operator of HubSpot Forms, HubSpot, Inc, Cambridge, Massachusetts, US.
We process your data with the help of HubSpot Forms for the purpose of handling the contact request and its processing pursuant to Art. 6 Para. 1 clause 1 b) GDPR.
The use of HubSpot Forms and the integrated services is subject to our legitimate interest pursuant to Art. 6 Para. 1 clause 1 f) GDPR, the optimisation of our marketing measures and the improvement of our service quality on the website.
5.4 Google Tag Manager
We use Google Tag Manager from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is used to manage website tags via an interface and allows us to control the precise integration of services on our website.
This allows us to flexibly integrate additional services in order to evaluate user access to our website.
The use of Google Tag Manager is based on your consent in accordance with Art. 6 Para. 1 clause 1 b) GDPR and § 25 para. 1 TTDSG.
Data protection information for webinars via “Microsoft Teams
We would like to inform you below about the processing of personal data in connection with the use of Microsoft Teams.
Purpose of the processing
We use the Microsoft Teams tool to conduct webinars. Microsoft Teams is a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
Note: To the extent that you access the Microsoft Teams website, Microsoft Corporation is responsible for data processing.
What data is processed?
When you use Microsoft Teams, various types of data are processed. The scope of the data also depends on the data you provide before or when participating in a webinar. The following personal data is subject to processing:
User details: e.g. display name (“Display name”), e-mail address.
Protocol files/meeting metadata: e.g. description (optional), IP address of the PC ́s or mobile device, date and time of access. Device/hardware and software information, language settings, relevant system configuration details (e.g. graphics card, sound card, driver version).
Text, audio and video data: You may have the opportunity to use the chat function in a webinar. In this respect, the text entries you make are processed in order to display them in the webinar and, if necessary, to record them. In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device will be processed accordingly for the duration of the webinar. You can switch off or mute the camera or microphone yourself at any time via the Microsoft Teams applications.
To participate in a webinar, you must at least provide details of your display name.
Scope of processing
We use Microsoft Teams to deliver webinars. The webinars are not recorded. The chat content is only available for the duration of the webinar.
Legal basis of data processing
We use Teams on the basis of Art. 6 para. 1 clause 1 f) GDPR. Our legitimate interest is to be able to conduct webinars effectively.
If you have given your consent to the use of the service in accordance with Art 6. para. 1 clause 1 a) GDPR and § 25 Para. 1 TTDSG, this will serve exclusively as the legal basis. Consent given can be revoked at any time with effect for the future.
Recipients / passing on of data
Personal data processed in connection with participation in webinars will not be passed on to third parties as a matter of principle, unless they are specifically intended to be passed on. Please note that content from webinars, as well as from face-to-face meetings, is often used to communicate information with employees, customers, interested parties or third parties and is therefore intended for disclosure.
Other recipients: The Microsoft Teams provider necessarily receives knowledge of the above-mentioned data insofar as this is provided for in the context of our order processing agreement with Microsoft Teams.
Data processing outside the European Union
In principle, there is no data processing outside the European Union (EU), as the data centres are located in the EU.
Nevertheless, there are theoretical access possibilities through Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
In this context, we would like to point out that due to the US CLOUD Act of 2018, there is a theoretical possibility for US authorities to access data of US IT companies and cloud providers that are stored outside the USA.
However, the data is encrypted during transport over the internet and thus secured against unauthorised access by third parties.
Further information on data protection can be found here:
6.1 HubSpot Analytics
We use HubSpot Analytics from HubSpot, Inc., Cambridge, Massachusetts, US, as an analysis service for the statistical evaluation of our online offer. This includes, for example, the number of times our online offer is called up, sub-pages visited and the length of time visitors spend on the site.
This information is used, among other things, to compile reports on website activity.
HubSpot Analytics is used on the basis of your consent pursuant to Art. 6 Para. 1 clause 1 a) GDPR and § 25 para. 1 TTDSG.
7 Retention period
Unless specifically stated, we only store personal data for as long as is necessary to carry out the intended purposes.
In some cases, the legislator stipulates that personal data must be retained, for example under tax law or commercial law. In these cases, the data will only be stored by us for these legal purposes, but will not be processed in any other way and will be deleted after expiry of the legal retention period.
8 Your rights as a data subject
Under the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by email or by post to the address specified in section 1, clearly identifying yourself.
You will find an overview of your rights below.
8.1 Right to confirmation and right of access to personal data
You have the right to access clear information about the processing of your personal data.
You have the right to obtain confirmation from us at any time as to whether personal data concerning you is being processed. Should this be the case, you have the right to request information from us, free of charge, about the personal data stored about you, together with a copy of this data. Furthermore, you have the right to the following information:
- The purposes of the processing
- The categories of personal data that are processed
- The recipients or categories of recipients to whom the personal data has been or is still being disclosed – in particular, recipients in third countries or at international organisations
- If possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this period
- The existence of a right to rectification or erasure of personal data concerning you, or to restrict the processing by the data controller, or of a right to oppose such processing
- The existence of a right to appeal to a supervisory authority
- If the personal data is not collected from the data subject him/herself, any available information as to the source of the data
- The existence of any automated decision-making, including profiling, pursuant to Art. 22 para. 1 and 4 GDPR and – at least in such cases – meaningful information about the logic involved as well as the scope and intended effects of such processing for you.
If personal data are transferred to a third country or to an international organisation, you have the right to be informed of the appropriate guarantees in connection with the transfer pursuant to Art. 46 GDPR.
8.2 Right to rectification
You have the right to request that we rectify personal data concerning you, or, if applicable, complete it.
You have the right to request that we rectify inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
8.3 Right to erasure (“right to be forgotten”)
In a number of cases, we are obliged to delete personal data concerning you.
In accordance with Art. 17 para. 1 GDPR, you have the right to demand that we delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay if any of the following reasons applies:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- You revoke your consent on which the processing was based pursuant to 6para. 1 clause 1 a) GDPR or Art.. 9 para. 2 a) GDPR, and there is no other legal basis for such processing.
- You object to the processing pursuant to 21 para. 1 GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR.
- The personal data has been unlawfully processed;
- The personal data has to be erased in order to comply with a legal obligation under Union or Member State law to which we are subject
- The personal data concerning you has been collected in relation to the offer of information society services referred to in 8 para. 1 GDPR.
If we have made your personal data public and are obliged to delete it pursuant to Art. 17 para. 1 GDPR, we shall take reasonable measures, including technical measures – while taking into account the available technology and the implementation costs – to inform the data controllers who are responsibly for processing your personal data that you have requested that all links to your personal data, as well as any copies or replications of your personal data, be deleted.
8.4 Right to restriction of processing
In a number of cases, you are entitled to request that we restrict the processing of your personal data.
You have the right to request that we restrict the processing if one of the following conditions is met:
- You contest the accuracy of your personal information for a period of time that allows us to verify the accuracy of the personal data.
- The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
- We no longer need the personal data for the purposes of the processing, but you require it in order to establish, exercise or defend legal claims.
- You have objected to the processing pursuant to 21 para. 1 GDPR, pending verification of whether our legitimate grounds override yours.
8.5 Right to data portability
You have the right to receive, transmit or have us transmit personal data concerning you in a machine-readable format.
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and the right to transmit this data to another data controller without hindrance from us, where:
- the processing is based on consent pursuant to 6para. 1 clause 1 a) GDPR or Art.. 9 para. 2 a) GDPR, or on a contract pursuant to Art. 6 para. 1 clause 1 b) GDPR; and
- the processing is carried out by automated means.
In exercising your right to data portability pursuant to paragraph 1, you have the right to have your personal data transmitted directly from us to another data controller, provided that this is technically feasible.
8.6 Right to object
You have the right to object to the lawful processing of your personal data by us if this is justified by your particular situation and provided that our interests in the processing do not outweigh yours.
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6 para. 1 (e) or (f) GDPR, including profiling based on those provisions. We will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Art. 89 para. 1 GDPR, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.7 Automated decision-making including profiling
You have the right to not be subject to a decision based solely on automated processing – including profiling – which has a legal bearing on you or which significantly affects you in a similar manner.
No automated decisions are made on the basis of the personal data that we collect.
8.8 Right to revoke consent previously provided under data protection law
You have the right to revoke your consent to the processing of your personal data at any time.
8.9 Right to file a complaint with a supervisory authority
You have the right to file a complaint with a supervisory authority, in particular, in the Member State where you live or work or where the alleged violation took place, if you believe that the processing of your personal data is unlawful.
9 Data security
We make every effort to ensure the security of your data in accordance with the applicable data protection laws and the technical possibilities at our disposal.
Your personal data will be transmitted by us in encrypted form. This applies to all forms that are offered. We use the SSL (Secure Socket Layer) encryption protocol, but would like to point out that any data transmission on the Internet may be subject to security vulnerabilities (e.g., when communicating by email). It is not possible to completely protect data against access by third parties.
To protect your data, we maintain technical and organisational security measures in accordance with Art. 32 GDPR, which we continually adapt to reflect the latest technological developments.
We also do not guarantee that our Website will be available at specific times; disturbances, interruptions or failures cannot be excluded. We regularly and carefully backup the servers we use.
10 Disclosure of data to third parties, no data transfer to non-EU countries
In principle, we only use your personal data inside our company.
Should we involve third parties in the fulfilment of contracts (such as logistics service providers), these third parties will only receive personal data to the extent necessary to perform the corresponding service.
In the event that we outsource certain parts of the data processing (“contract processing”), we contractually oblige the processors we contract to only use personal data in accordance with the requirements of the applicable data protection laws and to ensure that the rights of the data subject are protected.
No data is transferred to places or persons outside the EU apart from the cases mentioned in clauses 5 and 6 of this policy, nor is any such transfer planned.
11 Data protection officer
As an ISO 27001-certified company, information and data security is of great importance to xy gmbH. That is why we handle your data with appropriate sensitivity. If you have any questions about data protection, you can contact our data protection officer at Datenschutz@7p-group.com or by post at:
Data protection officer
SEVEN PRINCIPLES AG