Supplement to the Privacy Notice

Our Social Media Presence

We maintaincompany profiles on the following social networks

When you visit our profiles or communicate with us via these platforms, personal data is processed both by us and by the respective platform operator.

Purposes of Processing

We use our social media presence in particular for the following purposes:

  • presenting our company as well as our products, services and areas of activity
  • publishing company news, industry information, events and other content relevant to our target audiences;
  • communicating and maintaining relationships with customers, prospective customers, suppliers, business partners and other users;
  • responding to enquiries, comments and messages;
  • monitoring responses to our content and adapting and developing our communications in line with our audiences’ needs;
  • increasing awareness and reach of our company;
  • carrying out advertising and marketing activities;
  • recruiting employees and providing information about job vacancies.

Personal Data Processed

Depending on how you use the respective platform, we may process, in particular, the following personal data:

  • your name or profile name;
  • information publicly available on your profile;
  • the content of comments, posts and messages;
  • information about reactions to our content, such as “likes”, shared content and other interactions;
  • the time and nature of your contact with us;
  • where applicable, contact details and other information you provide to us in connection with an enquiry;
  • statistical information provided by the platform operators regarding the use, reach and audiences of our social media presence.

For certain interactions – for example, comments, reactions, following our page or direct messages – we may be able to identify the user account from which the respective action originated, insofar as the platform displays this information to us.

By contrast, the analyses provided to us by the platform operators as “Page Insights” or page statistics are generally made available to us only in aggregated form. They may include, for example, information on page views, reach and interactions as well as aggregated demographic or professional characteristics. As a general rule, these statistics do not provide us with information that enables us to identify individual visitors or attribute the statistical information to individual persons. This applies in particular to the Page Insights provided to us by LinkedIn.

Please avoid sending us confidential or particularly sensitive information via social networks wherever possible. For confidential matters, you may use the contact options specified in Section 1.

Legal Bases

The processing of personal data in connection with presenting our company, communicating with users and maintaining our business contacts is based on Article 6(1)(f) GDPR. Our legitimate interests consist of maintaining modern corporate communications, providing information about our company and our services, managing our public presence, and communicating with customers, prospective customers, applicants and business partners.

Where your contact with us is aimed at entering into or performing a contract with you, the processing is additionally based on Article 6(1)(b) GDPR.

Where processing is based on your consent, Article 6(1)(a) GDPR constitutes the legal basis. You may withdraw your consent at any time with effect for the future.

Processing in connection with job applications is carried out for the purpose of deciding whether to establish an employment relationship on the basis of Article 6(1)(b) GDPR in conjunction with Section 26(1), sentence 1 of the German Federal Data Protection Act (BDSG).

Processing by Platform Operators

When you visit our social media presence, the respective platform operators process personal data under their own responsibility. This may also occur if you are not logged in to the respective platform or do not have a user account there.

In particular, the platform operators may process your IP address, device and browser information, information from cookies or similar technologies, as well as information about your usage behaviour. This data may be used to create usage profiles, personalise content and advertising, measure reach and further develop the respective platform services. We have only limited influence over the nature and scope of such independent processing by the platform operators.

Further information can be found in the providers’ privacy policies:

  • LinkedIn Privacy Policy
  • Meta Privacy Policy for Facebook and Instagram

Responsible Platform Operators

According to the platform operators, the platforms are provided to users in the European Economic Area in particular by the following companies:

LinkedIn
LinkedIn Ireland Unlimited Company
Wilton Plaza, Wilton Place
Dublin 2, Ireland

Facebookand Instagram
Meta Platforms Ireland Limited
Merrion Road
Dublin 4, D04 X2K5, Ireland

PageStatistics and Joint Controllership

The platform operators provide us with statistical information about the use of our company profiles. These statistics may include, for example, information on page views, reach and interactions as well as aggregated demographic or professional characteristics of users. As a general rule, we receive these analyses only in aggregated form and are generally unable to attribute the information contained therein to individual persons.

For certain processing activities in connection with such page statistics, we may be joint controllers with the respective platform operator within the meaning of Article26 GDPR.

For LinkedIn pages, we have accepted the joint controllership agreement provided by LinkedIn. Under this agreement, LinkedIn assumes responsibility in particular for fulfilling data subject rights and information obligations in relation to the processing of data for “Page Insights”. The key provisions can be found in the Page Insights Joint Controller Addendum. In this addendum, LinkedIn states that ACT receives only aggregated statistics and cannot attribute the underlying information to individual members.

For Facebook and Instagram, Meta’s provisions on joint controllership for “PageInsights” apply. Under these provisions, Meta is responsible in particular for providing information about Insights processing and handling the corresponding data subject requests. The Meta Page Insights Controller Addendum contains the key provisions.

Irrespective of these agreements, you may generally exercise your data protection rights both against us and against the respective platform operator. Where your request concerns processing that predominantly falls within the area of responsibility of the platform operator, we will forward your request to the platform operator where necessary.

With regard to the processing of personal data for the creation of page statistics (“Page Insights”), we and the respective platform operators act as joint controllers within the meaning of Article 26 GDPR. Details of the respective responsibilities are set out in the joint controllership agreements provided by the platform operators.

Recipientsand Transfers to Third Countries

Data processed via our social media presence may be transferred by the platform operators to affiliated companies, service providers and other recipients. In this context, processing may also take place outside the European Union and the European Economic Area, in particular in the United States.

Where the applicable requirements are met, transfers to the United States may be based on the European Commission’s adequacy decision concerning the EU-U.S. Data Privacy Framework. In other cases, the platform operators state that they use appropriate safeguards, such as the European Commission’s Standard Contractual Clauses. Further information on the respective legal bases for such transfers can be found in the privacy policies of the platform operators.

Retention Period

We retain messages, comments and other information processed directly by us only for as long as necessary to deal with the respective matter. Data may be retained for a longer period where this is necessary for the performance of a business relationship, compliance with statutory retention obligations, or the establishment, exercise or defence of legal claims.

Public posts and interactions generally remain available on the respective platform until they are deleted by you or the platform operator, or until we remove them where this is within our control. We have no material influence over the retention period of data processed by the respective platform operator under its own responsibility. Further details can be found in the privacy policy of the respective provider.