Privacy Policy init SE

We at init innovation in traffic systems SE are pleased that you have visited our website and expressed interest in our company, products and services. We take the protection of your privacy very seriously, and we want you to feel safe when visiting our websites. Therefore, we treat your data confidentially and in accordance with the legal data protection regulations as well as this privacy statement.

Click here to read additional information required under the Québec Privacy Legislation.

1. An overview of data protection

General information

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 Data Protection Declaration, which we have included beneath this copy.

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. 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:

init innovation in traffic systems SE
Käppelestraße 4-10
76131 Karlsruhe
Deutschland
Phone: +49.721.6100.0
E-mail: webmaster_prefix@initse._suffixcom

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.

Designation of a data protection officer as mandated by law

We have appointed an external data protection officer:

init innovation in traffic systems SE
Georg Biel
Käppelestraße 4-10
76131 Karlsruhe
E-mail: dataprotection_prefix@initse._suffixcom

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.

Following the invalidation of the Privacy Shield between the USA and the EU, all necessary measures were implemented to secure the transfer of personal data. In particular, we revised all existing standard contractual clauses with group companies in third countries and brought them up to June 2021 status.

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 demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, 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.

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.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. 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 in lieu 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.

3. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files 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. In some cases, it is possible that third-party cookies are stored on your device once you enter our site (thirdparty cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services). Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping cart function) or those that are necessary for the optimization 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 cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR); 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. In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.


You can object to the use of optional cookies at any time by adjusting your 
cookie settings accordingly.

Technically necessary cookies

Your cookie settings
Your cookie settings are saved in a cookie itself.

Name: nb_cookie_settings
Storage period: 1 year
Purpose: storage of cookie settings

language selection
Your last language selection on our site is saved so that when visit again, the pages are displayed in the correct language.

Name: language_selector
Storage period: 1 year
Purpose: to save the selected language

MTCaptcha
We use a service from MTCaptcha to protect the contact forms on our website from abuse by spammers and bots. The cookies set by this service are used exclusively to prevent the use of forms by bots and automatic scripts. No personal data is collected.
More information on compliance with the GDPR can be found on the provider's website: https://www.mtcaptcha.com/gdpr-captcha

Name: jsV
Storage duration: will be deleted after the session
Purpose: storage of the script version used

Name: mtv1ConfSum
Storage duration: will be deleted after the session
Purpose: test data for validation

Name: mtv1Pulse
Storage duration: will be deleted after the session
Purpose: identification string

Session management in the career area
Name: sid
Storage time: 1 minute
Purpose: visitor allocation

Investor Relations Form

If you submit inquiries to us via the Investor Relations Form, the information provided in the form as well as any contact information provided therein (title, surname, first name, email) 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 this 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 information you have entered into the form shall remain with us until you ask us to delete 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.

To protect the Investor Relations Form on our website from abuse by spammers and bots, we use a service provided by EQS Group AG, Karlstr. 47, 80333 München, Deutschland. To generate a honeypot field, a cookie is set that serves to identify the user's session instance and is valid until the end of the browser session. No personal data is processed. It is not possible to draw conclusions from the randomly generated session ID to the person visiting the website. Further information can be found at irpages2.eqs.com.

Session-Cookie:

Name: IRPages2_Session:"dec70c86ade9a95099bd9c244478e4edcf902120"

Provider: irpages2.eqs.com

Expiry: Will be deleted after the session

Purpose: Session Identification

Type: http/https


Cookies for statistical evaluation

Google Analytics
We use Google Analytics to collect anonymized statistical data. The analysis of user behavior enables us to optimize our website and better adapt it to the needs of consumers.

Name: _dc_gtm_UA-32364987-7
Storage time: 10 minutes
Purpose: to limit the polling rate

Name: _ga
Storage period: 2 years
Purpose: to distinguish visitors

Name: _gid
Storage duration: 1 day
Purpose: stores visitor behavior

Matomo
In some areas of our website we use the tracking software Matomo.

Name: _pk_ses.2.030d, _pk_ses.3.030d, _pk_ses.4.030d, _pk_ses.5.030d, _pk_ses.6.030d, _pk_ses.7.030d, _pk_ses.10.030d,  _pk_ses.11.030d
Storage time: 30 minutes
Purpose: temporary storage of click data

Name: _pk_id.2.030d, _pk_id.3.030d, _pk_id.4.030d, _pk_id.5.030d, _pk_id.6.030d, _pk_id.7.030d, _pk_id.10.030d,  _pk_id.11.030d
Storage period: 13 months
Purpose: to distinguish visitors

Video statistics
Name: vimeo_consent
Storage period: 14 days
Purpose: Storage of consent to play Vimeo videos.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address


This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

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. If the contact form is completed in order to request further information on US projects, please be aware that this email is automatically forwarded to a contact in the USA and your personal data will be transferred to the USA.

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 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 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.

4. 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 the relevant consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; the 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. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

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.

This analysis tool is used on the basis of Art. 6(1)(f) GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked 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/.

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

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: ttps://support.google.com/analytics/answer/6004245?hl=en.

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.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 2 months. For details, please click the following link: ttps://support.google.com/analytics/answer/7667196?hl=en

Matomo (formerly called Piwik)

This website uses the open-source web analysis service Matomo. Matomo uses technologies that make it possible to recognize the user across multiple pages with the aim of analyzing the user patterns (e.g. cookies or device fingerprinting). The information recorded by Matomo about the use of this website will be stored on servers of Rexx (rexx systems GmbH Headquarters, Süderstrasse 75-79, 20097 Hamburg). Prior to archiving, the IP address will first be anonymized.

Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time.

IP anonymization

For analysis with Matomo we use IP anonymization. Your IP address is shortened before the analysis, so that it is no longer clearly assignable to you.

Hosting

We host Matomo with the following third-party provider:

rexx systems GmbH Headquarters
Süderstrasse 75-79
20097 Hamburg

5. Plug-ins and Tools

Vimeo

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

If you visit one of the pages on our website into which a Vimeo video has been integrated, a connection to Vimeo’s servers will be established. As a consequence, the Vimeo server will receive information as to which of our pages you have visited. Moreover, Vimeo will receive your IP address. This will also happen if you are not logged into Vimeo or do not have an account with Vimeo. The information recorded by Vimeo will be transmitted to Vimeo’s server in the United States.

If you are logged into your Vimeo account, you enable Vimeo to directly allocate your browsing patterns to your personal profile. You can prevent this by logging out of your Vimeo account.

Vimeo uses cookies or comparable recognition technologies (e.g. device fingerprinting) to recognize website visitors.

The use of Vimeo 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 a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can 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 how Vimeo handles user data, please consult the Vimeo Data Privacy Policy under: https://vimeo.com/privacy.

6. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service. Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider.

Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected. We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/de-de/privacystatement.

Order processing

We have entered into a contract on order processing (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that this provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.


Zoom

We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy: https://zoom.us/en-us/privacy.html.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://zoom.us/de-de/privacy.html.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. 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.

GoToWebinar

We use GoToWebinar. The provider is LogMeIn, Inc., 320 Summer Street Boston, MA 02210, USA. For details on data processing, please see GoToWebinar’s Privacy Policy: https://www.logmeininc.com/legal/privacy.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://logmeincdn.azureedge.net/legal/lmi-customer-dpa-2020v1-de.pdf.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. 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.

Webex

We use Webex and host the application on our premises. The service provider is the Webex Communications Deutschland GmbH, Hansaallee 249 c/o Cisco Systems GmbH, 40549 Düsseldorf, Germany.

Nevertheless, it is possible for data processed by WebEx to be transferred to third countries (e.g. the USA). Webex has Binding Corporate Rules (BCR) approved by Dutch, Polish, Spanish and other relevant European data protection regulators. These are binding corporate rules that legitimize corporate data transfers to third countries outside the EU and EEA. Details can be found here: https://www.cisco.com/c/de_de/about/trust-center/data-protection-and-privacy-policy.html and https://konferenzen.telekom.de/fileadmin/Redaktion/conference/ciscowebex/Webex_Compliance_Deutsch_V1.0.pdf.

For details on data processing, see Webex's privacy policy: https://www.cisco.com/c/de_de/about/legal/privacy-full.html.

Order processing

We have entered into a contract on order processing (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that this provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

Newsletter

We send e-mails which contain advertising content (‘newsletters’) based on your consent or legal permission. The content of the newsletter relates to the subscription or selection of topics you chose during the registration process. We also inform you about us and our services in our newsletter. We require personal information in order to send you our free newsletter. After submitting the registration form, you will receive a confirmation e-mail from us. The order becomes effective only after you click on the link in the confirmation e-mail (double-opt-in). You can unsubscribe from our newsletter at any time by clicking the corresponding link at the bottom of every newsletter. Your e-mail address will then be added to an internal block list to prevent the newsletter from being sent to your e-mail address again. We use Sendinblue, an offer from Sendinblue GmbH, Köpenicker Straße 126, D-10179 Berlin to send our newsletter. The servers are located in Germany and Sendinblue is subject to the data protection regulations in force in the European Union. Sendinblue treats the personal data of its recipients confidentially and does not pass them on to third parties. If you subscribe to the newsletter, you give your consent to receive our newsletter and that your personal information will be stored and processed by Sendinblue on our behalf. Sendinblue provides analytical tools which make it possible to make statements about the success of the newsletter delivery. Among other services, Sendinblue uses Google Analytics for this purpose. We are interested only in statistical results, such as how many subscribers read our newsletters and which links are followed. For more information, see the description of the features (https://www.sendinblue.com/newsletter-software) and the privacy policy (https://www.sendinblue.com/legal/termsofuse/) of Sendinblue.

If you register for the North American issue of the INIT Inc. newsletter, we would like to point out that your data will be forwarded to "INIT Innovations in Transportation Inc., 424 Network Station Chesapeake, VA 23320, United States". By subscribing to this newsletter, you consent to this transfer and are aware that the United States are considered a third country under data protection law and does not meet the data protection standards applicable in the EU and in Germany. Your data will be processed in accordance with the following Privacy Policy: https://www.initse.com/us/footer-meta/privacy-policy.html

For the newsletter dispatch of the North American issue we use Constant Contact, an offer of Constant Contact Inc, 1601 Trapelo Road, Waltham, MA 02451, United States. The provider is based in the United States and is subject to the data protection regulations applicable in the United States. Constant Contact treats the personal data of its recipients confidentially and does not pass them on to third parties.

If you subscribe to the newsletter, you give your consent that you would like to receive our newsletter, that information is stored and may be processed by Constant Contact on our behalf. Constant Contact provides analytical tools, which make it possible to make statements about the success of the newsletter delivery. Among other services, Constant Contact uses Google Analytics, for this purpose. We are interested only in statistical results, such as how many subscribers read our newsletter and which links are followed. For more information, see the description of the features (https://knowledgebase.constantcontact.com/articles/KnowledgeBase/5536-constant-contact-privacy-policies-for-protecting-customers?lang=en_US) and the privacy policy (https://endurance.clarip.com/privacycenter/?brand=ctct & https://www.endurance.com/privacy/privacy) of Constant Contact.

7. Custom Services

Job Applications

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 GDPR 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. Initially, your personal data is processed by init SE and then passed on exclusively within the INIT Group to the people who are the decision-makers in the application process. In each job advertisement, it is specified which subsidiary is the hiring company. If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 GDPR 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.

Contact for applicants (withdrawal/request for information):

working_prefix@jobs-init-group._suffixcom

Job alert

You have the possibility to subscribe to our Job Alert on the website. When you subscribe to the Job Alert, the data requested from the input mask is transmitted to INIT.

In addition, the following data is collected during registration:

  • IP address of the registering person's computer
  • Date and time of registration
  • Name of the website on which you have subscribed to our Job Alert


As part of the registration process, consent is obtained through a so-called double opt-in procedure. You can cancel the Job Alert at any time using the link provided for this purpose in the Job Alert. Once you have unsubscribed, your e-mail address will be deleted from our newsletter distribution list immediately.

Your personal data is protected against theft and misuse using the latest technical procedures. If personal data is provided, it will be transmitted encrypted (TLS). Under no circumstances we will pass on your data to third parties.

The legal basis for the processing of data after registration for Job Alert by the user is, if the user has given his consent, Art. 6 para. 1 a) GDPR §26 para. 1 BDSG (neu). The collection of the user's e-mail address is used to deliver the Job Alert. The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used.

The data is deleted as soon as it is no longer required for the purpose of its collection. The user's e-mail address is therefore stored as long as the subscription to the Job Alert is active. The subscription to the Job Alert can be cancelled by the user concerned at any time. For this purpose there is a corresponding link in every Job Alert.

Talent Pool

With your application, you can not only agree to be used for a specific position, but also agree to be used for other potential positions via Opt In (consent). The legal basis for the processing of the data is Art. 6 para. 1 a) GDPR, if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 f) GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 b) GDPR and §26 para. 1 BDSG (neu).

Your data will be used to check whether INIT can also consider you for another job advertisement and include your documents in the decision-making process. The data will be deleted as soon as they are no longer necessary for the purpose of their collection. After 12 months, the data will be converted into basic data, after 24 months these data will also be deleted.

The user has the possibility to revoke his consent to the processing of personal data at any time. To do so, the user can contact the person responsible via the contact details provided on the website. If the user contacts INIT by e-mail, he may object to the storage of his personal data at any time. In such a case the conversation cannot be continued.