1. Introduction
The protection of your personal data is an important concern for us. It goes without saying that we comply with all statutory provisions on data protection and data security, in particular the German Federal Data Protection Act (BDSG) and the EU General Data Protection Regulation (EU-DSGVO) as well as the Telecommunications Telemedia Data Protection Act (TTDSG).
In this privacy policy we would like to inform you how we process your personal data.
2. Responsible Person / Contact
Uniper SE, Holzstraße 6, 40221 Düsseldorf, Germany ("we", "us" or "Uniper") is responsible for the data processing described in this privacy policy.
We are jointly responsible with Facebook Ireland Limited ("Facebook") for data processing within the scope of the so-called "Page Insights" in terms of data protection law.
We would like to point out that the use of our Fanpage also involves further processing of your personal data by Facebook beyond the "Page Insights" function. In this respect (especially with regard to the technical enabling of the use of our fan page), we refer to the data protection information of Facebook at https://www.facebook.com/privacy/explanation.
Insofar as this Fanpage contains links to other websites or online content, the respective data protection notices apply there.
You can reach our data protection officer by post at
Uniper SE
- for the attention of the data protection officer -
Holzstraße 6
40221 Dusseldorf
or by e-mail to: dataprotection@uniper.energy
3. Processing Activities
3.1 Communication with us / Community management
When you contact us via private messages, e.g. to ask us questions about our products and services, we use your name and possibly your e-mail address as well as the other data that you yourself provide us with in order to process and answer your questions.
These processing operations are carried out on the basis of statutory provisions that allow us to process personal data because we, as a company, have an overriding legitimate interest in meeting your requests for information and responding to customer inquiries (Art. 6 (1) sentence 1 f) DSGVO).
After a final response to your inquiry, we delete your inquiry, as well as information about its processing, with a period of one year after the end of the respective calendar year.
In addition, content and posts are regularly published publicly on our fan page and in other public areas of Facebook that are directly directed at us or concern us (e.g., because products of ours are mentioned). We collect this content that is sent to us or published on our fan page as well as other public areas of Facebook so that we can respond to it accordingly. Depending on the nature of the content, we may respond to it accordingly, for example, by contacting the authors to assist them with their questions about our services. We also create evaluations of how strongly content is perceived, including the "likes" submitted and other interactions with the content, in order to learn from this and improve our public relations work.
The legal basis for this processing is our overriding legitimate interest in responding appropriately to public communications relating to us (Art. 6 para. 1 sentence 1 f) DSGVO).
Content posted on our Fan Page or other public areas of Facebook may be deleted in the same manner as other content you have created. If at any time you wish to have posted content deleted, please send us an email to the above address. You can also find information about your rights below.
3.2 Community functions
We offer various community functions on our fan page that allow you to interact with other users, for example by posting articles on our "Wall", leaving comments or "liking" or sharing articles.
We collect all data entered as part of the community functions in order to provide you with the community functions as intended. Without this data, we are not able to provide you with the corresponding community functions. We process this personal data because we have an overriding legitimate interest in making the use of the offer as easy and efficient as possible (Art. 6 para. 1 sentence 1 f) DSGVO).
3.3 Usage analysis / page insights
In joint responsibility with Facebook, we analyze how you use our Fanpage ("Page Insights").
The information required by the DSGVO on the data processing carried out as part of Page Insights can be found in Facebook's privacy policy at https://www.facebook.com/privacy/explanation.
Facebook also provides you with the relevant contents of the joint responsibility processing agreement concluded between Facebook and us pursuant to Article 26 of the GDPR: https://www.facebook.com/legal/terms/page_controller_addendum.
As part of the page insights, we ourselves only receive anonymized statistics. We do not have access to personal data processed by Facebook.
3.4 Competitions
We occasionally offer competitions. If you wish to participate in this, we request identification data and contact information from you (e.g. name, date of birth, address, e-mail address, etc., as well as any other information required for participation in the competitions, such as answers to prize questions, photos of you or other persons, or results of online games). We use this information for the proper execution of the competitions as well as for abuse detection and legal defense.
Further details are contained in the respective conditions of participation for the competitions. If you have consented to this in the context of participation, we will also use the information for the purposes stated in the declaration of consent.
These processing operations are carried out on the basis of statutory provisions that allow us to process personal data insofar as it is necessary for the implementation of the competitions (e.g. Art. 6 (1) sentence 1 b) DSGVO), or because you have given us your consent to do so (Art. 6 (1) sentence 1 a) DSGVO), or in order to pursue our legitimate interests in preventing fraud and, where applicable, effective legal defense (Art. 6 (1) sentence 1 f) DSGVO).
In the event of participation in a competition, we store personal data of the winners for a period of 3 years after the end of the respective competition; we store personal data of other participants for a period of 3 months after the end of the respective competition.
3.5 Event invitations / event photos
We occasionally announce events for which you must register. When you register for an event, we process the personal data you provided during registration, such as name and address, as well as contact and communication data, such as telephone number and e-mail address, and, if applicable, the other information you provided in order to hold the respective event (for example, to create the guest list, accreditation and admission control, room and staff planning, and catering planning), as well as to send you your invitation and notifications about the respective event; we also use this information for abuse detection and legal defense.
The legal basis for this data processing is Art. 6 (1) sentence 1 b) DSGVO (for the fulfillment of a contract or a pre-contractual measure) or because we have a legitimate interest in the prevention of crime and, if necessary, effective legal defense (Art. 6 (1) sentence 1 f) DSGVO).
In the event of registration for an event, we will delete your registration data with a period of three months after the end of the event.
At events for which you have registered, photos and video recordings may be made under certain circumstances (possibly by a photographer commissioned by us), on which you may also be depicted.
If you are the central subject of a photograph ("single image"), the photographer will ask you whether you agree before taking the picture. In such a case, you grant us the right to reproduce, distribute or make publicly available this photograph and, if applicable, your spoken contribution, and in particular to use it for advertising purposes. In this context, we will provide a consent form at the event. The legal basis for data processing in this case is Art. 6 (1) sentence 1 a) DSGVO (consent).
Otherwise, we use recordings to publish impressions of the respective event for the purpose of visualized reporting as well as for advertising purposes on our social media channels and websites ("impressions"). The legal basis for this data processing is our legitimate interest in enabling visualized reporting on our event without this being opposed by an overriding interest of the participants (Art. 6 (1) sentence 1 f) DSGVO).
We delete recordings when the photos are no longer used for advertising purposes, but individual images after three years at the latest and impressions after five years. The period begins in each case with the end of the respective calendar year of the event.
3.6 Passing on data
A transfer of your personal data takes place in the following cases:
§ If it is necessary for the clarification of an illegal use of our services or for legal prosecution, personal data will be passed on to the law enforcement authorities. However, this only happens if there are concrete indications of unlawful or abusive behavior. The transfer of this data is based on our legitimate interest in combating abuse, prosecuting criminal acts and securing, asserting and enforcing claims (Art. 6 para. 1 sentence 1 f) DSGVO).
§ We may also disclose the data to aggrieved third parties. The disclosure of this data is based on the legitimate interest of the aggrieved third parties in combating abuse, prosecuting criminal acts and securing, asserting and enforcing claims (Art. 6 para. 1 sentence 1 f) DSGVO).
§ We are also required by law to provide information to certain public authorities upon request. These are law enforcement authorities, authorities that prosecute administrative offenses subject to fines and the tax authorities. The legal basis for this is the law obligating us in each case in conjunction with Art. 6 para. 1 sentence 1 c) DSGVO.
§ We rely on contractually affiliated third-party companies and external service providers ("processors") to provide the Services. Categories of such service providers are agencies, fulfillment service providers and IT service providers. In such cases, personal data is disclosed to these Order Processors to enable them to continue processing. These processors are carefully selected and regularly reviewed by us to ensure that your privacy is protected. The processors may only use the data for the purposes specified by us and are also contractually obligated by us to treat your data exclusively in accordance with this privacy policy and the German and European data protection laws. Due to the aforementioned transfers, the service providers bound by instructions may process the data in countries outside the EU ("third countries"). The legal basis for the transfer to service providers is the legal basis stated above for the respective processing purpose.
§ As our business evolves, we may change our legal form by changing our legal form, establishing, buying or selling subsidiaries, divisions or components. In such transactions, customer information is transferred along with the part of the business being transferred. In any transfer of personal information to third parties to the extent described above, we will ensure that it is done in accordance with this Privacy Policy and relevant data protection laws. Such transfer of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances as necessary (Art. 6 para. 1 sentence 1 f) DSGVO).
Any transfer of data to a third country takes place in compliance with the applicable data protection law. Insofar as the existence of an adequate level of protection has not been established for a third country by the European Commission, we provide appropriate safeguards to ensure adequate protection of your data. This can be done, for example, by concluding data processing contracts that contain EU standard data protection clauses and provide adequate safeguards in the opinion of the European Commission or other safeguards provided for in Art. 46 et seq. DSGVO, take place.
4. Your rights as a data subject
You have a right of access to your processed data, a right to rectification and to deletion of your personal data, a right to have the processing of your personal data restricted and, if applicable, a right to the portability of your personal data. Furthermore, you have the right to lodge a complaint with a supervisory authority.
In cases where the data processing is based on Art. 6 (1) sentence 1 e) or f) DSGVO or is carried out for the purpose of direct marketing, you have the right to object to the processing.
If you have given us consent, you can revoke this at any time with effect for the future. Processing until the revocation takes effect remains lawful and is not affected by the revocation.
As far as data processing related to Page Insights is concerned, Facebook acts as a common point of contact and handles all requests to assert the aforementioned rights.
5. Changes to this privacy policy
The status of this privacy policy is May 2022.
The further development of our social media presence may also affect the handling of personal data. We may therefore amend this data protection declaration in the future within the framework of the applicable data protection laws and adapt it to changed data processing realities. We therefore recommend that you visit our social media presence from time to time to take note of any updates to our data protection declaration.