The following information shall inform users of our website about how we process personal data. These information serve us to comply with our duties imposed under the General Data Protection Regulation (GDPR). Personal data means any information relating to you by which you can be identified, directly or indirectly.
Data protection information dated: January 2021
Bertelsmann SE & Co. KGaA
Carl-Bertelsmann-Straße 270
33311 Gütersloh
benet@bertelsmann.de
Phone: +49 (0) 52 41 / 80-23 68
Fax: +49 (0) 52 41 / 80-96 52
The above indicated company is accountable for the use of personal data on this website. Every processing of personal data on this website is conducted in compliance with the GDPR as well as possibly applicable other legislation.
You can contact the company by the means indicated above and by reference of your query. Where you want to contact the responsible data protection officer directly, add “Attention Data Protection Officer” to the address, or send an email to datenschutz@bertelsmann.de.
When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.
Some services require the provision of personal data. In these situations the respective service requested by you will be the leading purpose of our use of your data. Our website offers the following features, where you can request actions from us, where we will need information by you (e.g. user data such as email address and password, address details, search terms, form data and clicking data).
This website uses cookies. Cookies are small text files which are stored on your computer when you browse our website. The stored cookies are assigned to the browser you are using. If a given website is re-visited, the web browser transmits the content of the cookies back, allowing the site to recognize the user. Certain cookies are deleted when you log out or end the browser session (“transient cookies”). Other cookies are stored for a specified time or permanently (“temporary cookies,” “persistent cookies”). These cookies are automatically deleted after the specified time has elapsed. You can also delete cookies at any time in the security settings of your browser and configure the use of cookies according to your wishes. However, we wish to point out that this may result in you not being able to use all functions of the website.
As a general principle, cookies enable online recognition without reference to a specific person. Cookies become personalized – traceable to a specific person – when the information generated by the cookies is combined with other data. A distinction can be made between cookies that are necessary for the provision of website features, and cookies that are needed for further purposes such as analyzing user behavior or advertising.
Cookies that are necessary for the provision of our website include the following in particular:
Cookies that are needed for further purposes include analytics cookies for recording and statistically evaluating the usage behavior of our users (e.g. sub-pages visited, searches performed).
3.1 Functional cookies
On our website, we use cookiebot, a webservice developed and administered by Usercentrics A/S, Havnegade 39, 1058 Copenhagen (hereinafter: cookiebot.com). We use this service to collect, store and respect your cookie preferences in compliance with the GDPR. In order to do so, your browser will submit your IP-Address to cookiebot.com and cookiebot.com will assign you a cookie-ID which contain your cookie choices. The legal basis for this processing of personal data is Art. 6 (1) f GDPR, whereas the our legitimate interest is to store your privacy and cookie choices in a format which suits our technical setup. You can find further information, such as your rights as a data subject and information on deletion under: https://www.cookiebot.com/en/privacy-policy/ . You can surpress the aforementioned processing of personal data by deactivating the execution of scripts in your browser or use a script blocker such as: https://www.noscript.net or https://www.ghostery.com .
3.2 Consent-based cookies
Information on cookies that collect and process your data based on the consent you have given, can be found in section 4.8.
Privacy settings
Under “ Privacy Settings,” you can decide whether you consent to the storage of information on your device and the collection and processing of such information and other data by the us and our partners for the personalization, playout, and measurement of content within and outside of the services offered on this website and for the analysis of the usage of the services offered on this website.
Privacy settings
The purposes for processing personal data can be found in technical, contractual, and obligations by law, as well as your consent.
We use the data listed above in sec. 2 for the following purposes:
The following sections contain further information on these purposes underlying the processing of your data.
4.1 Technical provision
4.1.1 Description and extent of the processing
For the provision of our website, including regular performance and security checks, server log files are stored as part of the information when our website is accessed. These log files contain the information and possibly personal data as indicated in section 2 above. Log files are used for the purposes of technical provision only and they are not merged with any other data. Part of the technical provision is a regular reviewing procedure that is designed to detect fraud, hacking and other forms of disruptive behavior.
4.1.2 Purposes and legal basis for the use of personal data
The legal basis for the use of server log files is to be found in Art. 6 sec. 1 lit. f GDPR. Our interest is the undisturbed, resilient and performant operation of our website.
4.1.3 Duration of storage
After accessing our website we store the server log files on the web server, and your IP address is deleted after a maximum of seven days. Any analyses of these data are conducted only in case of a disruptive event involving these data.
4.1.4 Right to object
You are entitled to object the use of your personal data pursuant to Art. 21 GDPR on grounds that relate to your particular situation. If you want to exercise that right contact the Data Protection Officer via the means of contact indicated in section 1 above.
4.2 Email or phone contact
4.2.1 Description and extent of the processing
On our website you are given the means of getting in touch with us using an email address or a phone number. If you use one of them, the data you enter, your email address and/or your phone number and your request will be transmitted to us. Depending on your request (e.g. questions about this website and its contents, assertion of your rights as a data subject e.g. right of access). Where this is necessary, some or all of the data collected under this clause can be transmitted to other entities, provided we need their support to answer your request. In that situation we ensure that the recipient has implemented a proper level of protection as well.
4.2.2 Purposes and legal basis for the use of personal data
The legal basis for using data in this regard is to be found in Art. 6 sec. 1 lit. f GDPR. Our shared interest is that you receive an adequate answer. Our legitimate interest lie in the transmission of information, communicating with you, and processing your request.
4.2.3 Duration of storage / Criteria that determine the duration of storage
After responding to your request and the end of possibly further communication, your information provided for the purpose of the query will be erased unless there are legal retention periods to the contrary. These may result, for example, from the exercise of rights of affected persons
4.2.4 Right to object
You are entitled to object the use of your personal data pursuant to Art. 21 GDPR on grounds that relate to your particular situation. If you want to exercise that right contact the Data Protection Officer via the means of contact indicated in section 1 above. If you object, we can no longer communicate with you. Other rules apply if the storage of your contact data is necessary for the assertion of your rights as an affected party.
4.3 Newsletter mailings
4.3.1 Description and extent of the processing
Our website offers you the option of subscribing to free newsletters and company news alerts via email or SMS. For this purpose, your data will either be forwarded to us by your HR department, or transmitted to us from the website’s registration form and (with the help of service providers) processed further for the dispatch of news alerts and newsletters. The user data is updated daily from the SAP payroll and administration system, among other things, and user data for individual companies is imported manually on an irregular basis. Users can also register independently via the website. When registering, you will be asked for your consent and referred to this data protection information. We will not forward your data to companies outside the Group. Mandatory data for receiving alerts and newsletters is your email address or your mobile phone number. The processing of your access data is also required so that we can prove that you have given your consent. Further data can be given voluntarily, so that we can address you personally.
4.3.2 Purposes and legal basis for the use of personal data
It is necessary for us to process your data in connection with sending a newsletter in order to transmit information to and communicate with you. The legal basis for the HR department's transmission [of your data] to us upon your joining the company is Art. 6 Para. 1 lit. f - entitled interests - of the GDPR. Our legitimate interest lies in the fact that you always receive the company's news first-hand and from a verified source. If you yourself subscribe to the newsletter , Art. 6 Para. 1 lit. a - Consent - GDPR is the legal basis.
4.3.3 Duration of storage
The data is stored for the duration of your subscription to the news alerts and newsletters. After you unsubscribe,, your data will only be stored in order to prove that the company had obtained your consent to send communications and newsletters. The same applies if you have revoked your consent.
4.3.4 Right to object
You have the following options to oppose our use of your data for the purpose of sending the newsletter: You can object to the transmission by your personnel department and the subsequent use of the data. Your data will then no longer be used for this purpose and the newsletter will no longer be delivered to you. If you have given your consent to receive news alerts and newsletters, you can revoke your consent at any time with effect for the future by informing the company of your revocation via the email address benet@bertelsmann.de with the subject "Revoke Consent Newsletter."
4.4 Contests and prize drawings (Online lottery)
4.4.1 Description and extent of the processing
Our website offers you the opportunity to participate in our competitions and prize drawings. We collect your data via the application form as a part of the terms of use. We need to process your data in order to determine and announce a winner as well as demonstrate compliance that we have collected your data validly. Participation is completely voluntary.
If you win, your participation data ([INSERT data, like „Name, ZIP Code”] will be processed and published on our website. We will also contact you to let you know you have won, and deliver your reward, possibly by involvement of Processors. As part of the distribution of prizes, your data may also be forwarded to third parties (the prize sponsor).
4.4.2 Purposes and legal basis for the use of personal data
The processing of participant data is required for participation in the competition or prize drawing. The legal basis is the fulfilment of a contract in accordance with Art. 6 Para. 1 lit. b GDPR.
4.4.3 Duration of storage
After the winner is drawn, the participant data will be deleted after six months at the latest, unless its retention is mandated by law.
4.4.4 Right to object
Given that we need your data for you to participate in the competition or prize draw, there is no possibility for you to object.
4.5. Use of Data in the Context of BENET Reporting
4.5.1. Description of the data processing
The BENET is used for group-wide communication as well as information from employees and interested external parties. To this end, new articles on relevant topics, people and products from the Group are produced daily and published on BENET. In addition, the headlines and brief descriptions of these articles are sent out in a daily newsletter, to employees and external subscribers to the newsletter. If the data in BENET is processed in the form of a video contribution, both the video and the teaser for the contribution are also published in the BENET Clips App as well as in the newsletter. The data processing associated with this reporting varies according to the content of the report; first and last names, a picture or video, and other personal information (e.g. work/collaboration on a specific project, participation in a conference, assumption of responsibilities, CV information, etc.) that is thematically relevant are regularly included and published in articles. Where appropriate, further information relating to the person covered in the article will be processed. The data subject is notified of these prior to publication.
4.5.2. Purposes and legal basis of the data processing
Data processing in the context of BENET reporting/coverage is carried out on the basis of a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR; the legitimate interest on our part is to create identification with the Group among our readers, to create a corporate identity in the global community, and an attractive, collegial environment. As a rule, the interest of the parties concerned does not outweigh this legitimate interest until a right of objection is exercised.
4.5.3. Duration of storage or criteria for determining such duration
Generally, the data processed in the context of reporting is available in BENET for a period of three years after publication. The contributions are then removed from the freely accessible part of BENET and can only be viewed in the archive by members of the public relations department (ZÖ). The data is stored there for as long as the legitimate interest in retrievability is valid.
4.5.4. Objection and deletion options
In accordance with Art. 21 GDPR, you always have the right to object to the use of your data for the purposes specified under 4.5.1. You can assert this right informally vis-à-vis the body specified in Section 1 by referring to the data processing you no longer wish to be carried out in the future. If the conditions are met, your data will be blocked for this type of processing in the future and deleted in accordance with Art.17 GDPR.
4.6. Use of data in connection with the BENET Clips app
4.6.1. Description of the data processing
The BENET Clips app processes personal data only for purposes of providing the technology. So the data referred to in Section 2 may also be processed in connection with the BENET Clips app. In particular this includes data such as the Mac address of your device, information about the version and system, and technical information such as transmission rate, success, and time of access. After downloading the app, you will need to complete a one-time login with your BENET access information. The app establishes a secure connection to the BENET backend, where it is verified that this access is authorized. After successful registration, the app has permanent access to the BENET clips via a cookie on your smartphone. In addition, an evaluation tool collects anonymous information about which clips and articles are clicked on, when, and how often. For this purpose, it is technically ensured that only numerical values are collected for statistical evaluation.
4.6.2. Purposes and legal basis of the data processing
The processing of data in connection with the BENET Clips-App serves two purposes, both based on Section 6 para 1 letter f of the GDPR: the mobile and handy (technical) provision of the videos also available on BENET (with links to the corresponding BENET article), and the evaluation of the utilization (click rates) of the articles..
4.6.3. Duration of storage or criteria for determining such duration
The data processed for the purpose of providing the technology will generally be deleted after 14 days. Deviations from this rule will only be made if the data is required for further processing due to technical incidents as defined in Section 2.
4.6.4. Objection and deletion options
In principle, in accordance with Art. 21 GDPR you have the right to object to the use of your contact data for the purposes specified under 4.7.1. You can claim this informally vis-à-vis the body specified in Section 1 by referring to the data processing no longer desired in the future. If the conditions are met, your data will be blocked for this type of processing in the future. Please note that we do not use the data on a personalized basis and therefore cannot exclude data processing in the event that you continue to use the BENET Clips app.
4.7 Web tracking
Our website uses features to measure and evaluate user behavior and interaction. These features will utilize your access data (see section 2 above) and analyze your interactions with our website by means of tracking cookies (see section 3 above). The information collected will not be combined with other data, so no identifiable user profiles are created.
Web tracking is usually conducted by external providers (Processors). We have concluded data-processing agreements with these Processors; contracts that strictly bind them to our instructions and oblige them to process the collected data on our behalf and not for their own purposes. The website’s Processor is described in greater detail in the following.
4.7.1 Google Analytics
This website uses Google Inc.’s web analysis service (“Google Analytics”) to analyze the use of the website. A cookie is set for this purpose. The information generated by this cookie about your use of this website (including your IP address) is transferred to a Google server in the USA and stored there.
This website uses Google Analytics exclusively with the IP anonymization extension, whereby IP addresses are processed only in shortened form, to exclude the possibility of tracing them to a specific individual. Through the IP anonymization on this website your IP address is shortened by Google within EU Member States or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.
Google will use this information to evaluate your use of the website, compile reports on website activity for these websites, and provide other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. Google may transfer this information to third parties provided this is required by law or if third parties process this data on behalf of Google. You can read more about Google Analytics security and privacy principles at: https://policies.google.com/privacy
4.7.2 Purposes and legal basis:
The legal basis for the creation and utilization of pseudonymous user profiles is Art. 6 sec. 1 lit. a GDPR. You granting your consent to data processing by Google Analytics in our cookie-consent tool authorizes us to process your data in the manner and for the purposes stated.
4.7.3 Duration of storage or criteria for determining the duration:
Data collected and evaluated by use of web tracking tools are usually stored until you object to their use. If the data processing is based on your consent, your data will be stored until you revoke your consent. The storage period for analysis cookies is generally a maximum of 24 months.
4.7.4 Right to objectand options for deletion:
The collection and storage of data by Google Analytics can be objected to at any time with effect for the future. You have the possibility to install a browser plug-in published by Google. This is available for various browser versions and can be downloaded here . Furthermore, it is possible to object at any time in the future using the corresponding data protection setting in our cookie consent tool.
4.7.5. Google Tag Manager
Google Tag Manager is a solution that allows you to manage website tags via an interface. The Google Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not collect any personal information. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If disabled at domain or cookie level, it will remain disabled for all tracking tags implemented with Google Tag Manager. For more information about Google Tag Manager, please visit: http://www.google.de/tagmanager/use-policy.html .
4.8 External services and content on our website
We integrate external services and content on our website. If you use such a service or if third-party content is displayed to you, communication data (access data, see section 2 above) will be exchanged between you and the respective provider for technical reasons. This access data is not personalized due to the type of technical integration.
For further information about the purpose and scope of the collection and processing of your data (by these service providers), please refer to the data protection notices of the providers responsible under data protection law of the services or content integrated by us:
Youtube (videos) https://policies.google.com/privacy?hl=en
4.9 Privacy / Data Protection Information for Participation in BENET Predictor Games
4.9.1 Details of the data processing
We collect and use personal data from you when you participate in the BENET predictor game. You can reach our Data Protection Officer at datenschutz@bertelsmann.de
To participate in the predictor game, you must register and select a player name (this can be a pseudonym), which is visible to all logged-in players in the ranking list. The same goes for any profile picture you may have in your login area. You assign a password and have to enter your email address (preferably the company email address). Your title, first and last name, and the address of your company are also recorded (the company name is also visible for all logged-in players in the ranking list). The specification of a private address for the dispatch of a possible prize to the home office address is not a mandatory field. Once you have received your access data, you can log in and make further settings under “My profile”. When choosing your avatar, please keep in mind that the selected picture will be visible to all logged-in players. The following additional settings are possible: main language for the game (German or English), newsletter for the game (yes/no), and receive prediction reminders (yes/no). Now you can submit your predictions for the upcoming games.
To secure digital participation in the game, login data such as username, password, IP address, browser and its version and other technically required data are used, and technically required cookies are set, which allow your session to be maintained. No advertising tracking or the like takes place.
4.9.2 Purposes and legal basis of processing
The predictor game takes place within the scope of and in accordance with our Terms and Conditions of Participation. In accordance with Art. 6 (1) b of the German Data Protection Regulation (GDPR), these conditions of participation form the legal basis for our using your data under data protection law.
4.9.3. Retention Period and Publication
According to German tax and commercial law (§§ 147 AO, 257 HGB), we have a six-year retention period for the winners’ data. We also reserve the right to link to you as the winner of the predictor game or to report on it within our BENET site, and thus to make you visible to other persons. The winners will be announced on BENET.
4.9.4 Options for objection and removal
If you wish to terminate the processing of your data by us, you are free to have your account deleted at any time. To do so, please contact us by email at: benet@bertelsmann.de. The final deletion of the data will take place within seven days due to technical deletion cycles.
You always have the right to object to the use of your data for the purposes mentioned under 4.9.1. and 4.9.2. in accordance with Art. 21 GDPR. You can assert this right informally to the office named in section 1, with reference to the fact that you no longer desire your data to be processed henceforth. If the conditions are met, we will block your data for this type of processing in the future. Please note that we do not use the data in a personalized manner and thus cannot exclude data processing in the event that you continue to play or renew your registration for the predictor game.
Within our company only those departments will have access to your data who need them in order to fulfil the purposes (see section 4 above). Service providers used by the company can also have access to your data (“Processors,” e.g. data centers , newsletter dispatch, processing of competitions and prize drawings, web tracking, video service providers). Our data processing agreements with our Processors ensure compliance with instructions, data security and a confidential treatment of your data by these service providers.
Data is not forwarded to other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”).
This website exclusively operates servers in Germany. However, service providers used for the provision of the services presented on this website may be located outside the European Union or the European Economic Area (“EU” or “EEA”). By concluding standard contractual clauses as part of an applicable adequacy finding or other legally accredited guarantees, it is ensured that European data protection standards are guaranteed during transfers to third countries. You can request a copy of this guarantee from us using the contact details given in section 1.
Google uses servers located in the EU for the Analytics service wherever possible. However, it cannot be ruled out that data may also be transferred to the USA. In this event, we ensure that the service providers guarantee an equivalent level of data protection by contract or otherwise. For example, this could be the conclusion of a data protection agreement specified by the EU Commission (“EU standard contract clauses”). You can request a copy of the respective guarantees using the contact details given in section 1 above.
You have the right to information about your personal data stored by us at any time. If any information about you is incorrect or no longer current, you have the right to request that it be corrected. You also have the right to request the deletion or limitation of the processing of your data in accordance with Art. 17 or Art. 18 DSGVO. You may also have a right to the publication of the data you have provided in a common and machine-readable format (right to data transferability).
If you have given your consent to the processing of personal data for specific purposes, you can revoke your consent at any time with effect for the future. The revocation is to be addressed to the company at the contact address specified under item 1. Consents that you have given on the website can also be revoked by e-mail to benet@bertelsmann.de
In accordance with Art. 21 DSGVO, you have the right to object at any time for reasons arising from your particular situation to the processing of your data in accordance with the legal basis of Art. 6 para. 1 lit. f DSGVO.
You also have the option of contacting a data protection authority and lodging a complaint there. The authority responsible for the company is the:
State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Phone: +49 (0) 211/38 424-0
Fax: +49 (0) 211/38 424-10
Email: poststelle@ldi.nrw.de
You can also contact the data protection authority responsible for your place of residence.
