Privacy Policy

The protection of personal data is very important to us. We would therefore like to list all the information about the processing and storage of your data when you visit our website.

ABOUT US

Zortify S.A.
House of Startups
9, Rue du Laboratoire
1911 Luxembourg, Luxembourg
Email: hello@zortify.com

Further information can be found in the imprint.

DATA PROTECTION OFFICER

Data Protection Officer: Mag.a iur. Elisa Drescher
E-mail: office@scaleline-ltd.com (please refer to Zortify when contacting us)

COLLECTION AND PROCESSING OF PERSONAL DATA ON THIS WEBSITE

To protect your data as comprehensively as possible from unwanted access, we take so-called technical and organisational measures and use an encryption process on our website. Your data is transmitted over the Internet from your computer to our computer and vice versa using so-called TLS encryption. TLS stands for “Transport Layer Security” and is an encryption protocol for data transmission on the internet. You can usually recognise “TLS” by the fact that the lock symbol in the status bar of your browser is closed and the address begins with https://.

1. COLLECTION OF ACCESS AND LOG DATA

This website automatically collects and stores server log file information that your browser transmits to us.

These are:

The legal basis for this data processing is the legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR. The legitimate interest lies in being able to identify indications of unlawful use of our website (e.g. defence against hacker attacks) and to ensure a smooth connection setup.

We have concluded an order processing contract with the provider of this website, Hetzner Online GmbH, based in Germany, in accordance with Art. 28 GDPR. This is a contract prescribed by data protection law, which ensures that Hetzner Online GmbH processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

The data collected is stored in server log files, which your browser automatically transmits to us in encrypted form, for seven days. We only store the server log files in the event of attacks on our server infrastructure or other legal violations. This longer storage period is based on our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR and serves only to preserve evidence.

2. ENQUIRIES VIA THE CONTACT FORM, E-MAIL AND TELEPHONE

Any personal data that you provide to us on a voluntary basis will of course be treated confidentially. We use the personal data you provide exclusively to process and respond to your enquiry. The legal basis for data processing is our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR. This arises from our interest in responding to enquiries from our customers, business partners and interested parties and in promoting and maintaining customer satisfaction. Another legal basis for natural persons is the initiation or fulfilment of a contract in accordance with Art. 6 para. 1 lit. b) GDPR.

All personal data that you send to us with your enquiry will be deleted or anonymised by us no later than 2 years after the final response to you, unless a contract is concluded. The retention period of 2 years is due to the fact that you may occasionally contact us again about the same matter after a reply and refer to the previous correspondence. In our experience, we have found that after 2 years there are no more queries in response to our replies.

3. BOOKING APPOINTMENTS

You can book an appointment with us directly using our appointment booking tool. After booking, you will also receive an appointment confirmation by e-mail. The purpose of using this tool is to simplify appointment bookings. The provider is HubSpot Ireland Limited, with which a contract for order processing in accordance with Art. 28 GDPR has been concluded.

Beyond this, we do not pass on your data to third parties. The legal basis for the booking is the implementation of pre-contractual measures in accordance with Art. 6 para. 1 lit. b) GDPR. We store your data for the duration of the contract initiation or for the duration of the contractual relationship with us.

4. USE OF WEB ANALYSIS TOOLS AND COOKIES 

We use cookies to facilitate and improve the use of our website. Cookies are small pieces of text information that can be stored on your computer or smartphone (end device) via the browser when you visit a website. Cookies can also provide us with information about how you use our website so that we can continuously improve the design of the website.

The data processed by necessary cookies are necessary for the purposes listed below to safeguard our legitimate interests in accordance with Art. 6 para. 1 lit. f) GDPR. Any use of cookies that is not absolutely technically necessary constitutes data processing that is only permitted with your express and active consent in accordance with Art. 6 para. 1 lit. a) GDPR. You can use our “Cookie Consent Tool” to set which cookie categories you wish to consent to when you visit our website. You can also revoke or change your consent at any time by clicking on the widget (bottom left of the website).

Once cookies have been saved, you can also delete them at any time via the settings of your web browser. You can also adjust the settings of your web browser so that no cookies are stored. In this case, not all functions of our website may be available.

We may use specialised service providers from the online marketing sector in the context of data processing (with the help of cookies and similar techniques for processing usage data). These process your data on our behalf as processors and are carefully selected and contractually bound in accordance with Article 28 GDPR. All of the above providers work for us as processors.

Consent management via “COOKIEBOT”

To obtain consent under data protection law, we use the cookie consent technology of “Cookiebot” from Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark.

It is used to obtain the legally required consent for the use of cookies and other data processing requiring consent. The legal basis for this is our legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR and the fulfilment of legal obligations pursuant to Art. 6 para. 1 lit. c) GDPR. The legitimate interest is based on the legally compliant documentation and verifiability of consents to fulfil accountability obligations. No personal data is stored.

Use of Google Analytics

This website uses Google Analytics if you give your consent within the meaning of Art. 6 para. 1 lit. a) GDPR and Art. 49 para. 1 lit. a) GDPR. This is a service provided by Google Ireland Limited (“Google”), a company incorporated and operated under Irish law (registration number: 368047) with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC (USA) (“Google”).

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable the use of the website by the user to be analysed. The information obtained by the cookies about your usage behaviour of this website is usually transferred to a Google server in the USA and stored there.   There is an adequacy decision for the USA, so that the data transfer can take place without further measures. You can view Google’s certification here.

We have made the setting that your IP address will be anonymised. IP address anonymisation is carried out by Google, but within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

On behalf of the operator of this website, Google will use this information to analyse your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage.

The anonymised IP address transmitted by your browser as part of Google Analytics is linked to other data about you, such as your search history, personal accounts, usage data from other devices and all other data that Google has about you.

You can view the cookies that are set in connection with Google Analytics in the list above.

You can revoke your consent at any time by making the appropriate settings directly via the cookie banner. The user and event data will be deleted after 2 months. The “Reset user data on new activity” function is activated. This means that if you visit the site again before the retention period expires, your data will not be deleted.

Google ADS (DoubleClick)

We use Google Ads with your consent in accordance with Art. 6 para. 1 lit. a) GDPR to show you adverts on websites of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) and other third-party providers.

Our purpose is to show you adverts that are of interest to you and to make our website more interesting for you. With conversion tracking, we can determine how successful the individual advertising measures are. To do this, we use cookies that can be used to measure certain parameters for measuring reach, such as the display of adverts or clicks by users. If users reach our website via a Google advert, Google Ads stores a cookie on the corresponding end device. We only receive aggregated evaluations of user behaviour, on the basis of which we can determine which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising media.

You can find more information about cookies in the cookie list above. You can find more information on data protection for Google services at: https://policies.google.com/privacy?hl=de

Google Tag Manager

We use the Google Tag Manager of the provider Google Ireland Limited, Google Building Gordon House, Barrow St. Dublin 4, Ireland.

The Google Tag Manager allows website tags to be managed via a single interface. This enables us as marketers to manage website tags via a single interface. Tags are small sections of code that record (track) your activities on our website, for example. The Google Tag Manager itself does not set any cookies, but ensures that other tags, such as Google Analytics, are activated, which in turn may collect data under certain circumstances. Google Analytics itself sets cookies. You can find more information on this in the section “Web tracking measures”.

By implementing the Google Tag Manager, your IP address is transmitted to Google in anonymised form. This may also result in data being transferred to Google servers in the USA. We have concluded an order processing contract with Google in accordance with Art. 28 GDPR. There is an adequacy decision for the USA, so that the data transfer can take place without further measures. You can view Google’s certification here.

In the account settings of the Tag Manager, we have not allowed Google to receive anonymised data from us. The storage duration of the integrated tracking tools, such as Google Analytics, depends on the tool used, which is loaded via the Google Tag Manager.

Integration of YouTube videos

We embed videos on our websites that are not stored on our servers. To ensure that accessing our websites with embedded videos does not automatically result in the third-party provider’s content being loaded, we only display locally stored preview images of the maps in a first step. This means that the third-party provider does not receive any information.

Only after you click on the preview image or give your consent via the cookie consent banner will content from the third-party provider be reloaded. As a result, the third-party provider receives the information that you have accessed our site, as well as the usage data technically required in this context. We have no influence on further data processing by the third-party provider. By clicking on the preview image, you give us your consent to load content from the third-party provider. The embedding takes place on the basis of your consent in accordance with Art. 6 para. 1 lit. a) GDPR, provided that you have previously given your consent by clicking on the preview image. There is an adequacy decision for the USA, so that the data transfer can take place without further measures. You can view the certification of Google (YouTube) here.

Provider of the video service:
Google Ireland Limited/Google LLC (USA) (“YouTube”)

Revocation of consent
If you have clicked on a preview image, the content of the third-party provider will be reloaded immediately. If you do not want such reloading on other pages, please do not click on the preview images or revoke your consent for reloading via the cookie consent banner.

5. MAILING OF NEWSLETTERS

You can subscribe to our newsletter on our website. Our newsletters contain information, offers or promotions. When you subscribe to the newsletter, we collect and store the data you enter in the input mask. You are only required to enter your e-mail address. All other details such as first name and surname are provided on a voluntary basis.

After submitting the registration form, you will receive an e-mail from us with a confirmation link. As soon as you click on the link contained therein, you give us your consent to receive our newsletter and have successfully subscribed to it. You will be informed of this by another e-mail. You also give us your consent to process your e-mail address and, if applicable, your other data. This ensures that no third party or unauthorised person registers for our newsletter (compliance with the double opt-in procedure).

The legal basis for sending the newsletter is your consent in accordance with Art. 6 para. 1 lit. a) GDPR.

You can unsubscribe from the newsletter at any time by clicking on the “Unsubscribe” link at the end of each newsletter. If you withdraw your consent, your data will be deleted immediately. We store the proof of cancellation for a further three years so that we can comply with our accountability obligation in accordance with Art. 5 para. 2 GDPR. This storage is based on our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR. The legal basis for the confirmation email is our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR, which is based on being able to prove that you have given your consent. The burden of proof for the controller is set out in Art. 5 (2) GDPR.

We do not pass on the data to third parties. The newsletter is sent by our processor HubSpot Ireland Limited. 

The success of newsletters is measured using a so-called “web beacon”, a small file that sends information to the server when the newsletter is opened. Technical data such as browser type, system information, IP address and retrieval time are recorded. This data helps to technically improve the service and to analyse the reading behaviour of the target group, for example based on the location (determined by the IP address) or access times.

We also statistically record whether and when newsletters are opened and which links are clicked on. Although this information can technically be assigned to individual recipients, it is neither our aim nor that of the mailing service provider to observe individual users. Instead, these analyses are used to tailor the content to the reading habits of users and to send different content depending on their interests.

A separate revocation of the performance measurement is not possible; if you do not agree, the entire newsletter subscription must be cancelled.

Data processing in the context of application procedures

You can send us your application documents by e-mail for the purpose of receiving and managing the application and thus for the purpose of (possibly) establishing an employment relationship. You can also send us your application documents via job advertisements on career platforms. Where necessary, data protection agreements are in place with the providers of the platforms regarding the handling of personal data.

As part of the application process, we only collect the data from you that is necessary to establish the employment relationship with us. The legal basis for this data processing is Art. 6 para. 1 lit. b) GDPR.

Within our company, only those persons who are involved in the decision-making process have access to your personal data.

If your application is successful, your personal data will be stored for the duration of your employment relationship. In addition, your tax-relevant data will be archived in accordance with the statutory retention periods after termination of the employment relationship. In the event of an unsuccessful application, your personal data will be deleted 7 months after the rejection.

Operation of social media presences

We maintain the following social media presences: 

LinkedIn: https://www.linkedin.com/company/12587362/
Facebook: https://de-de.facebook.com/zortify/?ref=page_internal
YouTube: https://www.youtube.com/@Zortify_S.A
Instagram: https://www.instagram.com/zortify/?hl=fr

Instagram and Facebook are products of Meta Platforms Inc. (formerly Facebook Inc.): Facebook.com/help/1561485474074139/?helpref=related

Data processing by us:

Data processing by the operator of the social media platform:

In addition to us, there is also the operator of the social media platforms themselves. From a data protection perspective, this is also regarded as another controller that carries out its own data processing. This means that the operator is also a separate controller under the GDPR. However, we only have limited influence on data processing by the operator. Where we can exert influence (e.g. through parameterisation), we work within the scope of our possibilities to ensure that the operator of the social media platform handles data in compliance with data protection regulations. In many places, however, we cannot influence the data processing by the operator of the social media platform and do not know exactly what data they process. The respective operator will inform you about the processing of personal data in its own privacy policy:

 Facebook: www.facebook.com/help/568137493302217
Instagram: help.instagram.com/519522125107875
YouTube: www.policies.google.com/privacy?hl=de
LinkedIn: https://de.linkedin.com/legal/privacy-policy?

When using the platform, your personal data is generally also processed by the respective platform operator on servers in third countries, in particular in the USA. Certain third countries are certified by the European Commission with a so-called adequacy decision. This means that the legal situation for the protection of privacy in these countries is comparable to that in the EU or the EEA. You can find more information on the current countries with an adequacy decision here. Certifications in accordance with the adequacy decision for the USA, the Data Privacy Framework, exist for Meta Platforms Inc (Facebook, Instagram) and Google (YouTube). In all other cases, we conclude so-called standard contractual clauses with the platform operators for the transfer of personal data to third countries.  

Note: The operator of the social media platform uses web tracking methods. Web tracking can also take place regardless of whether you are logged in or registered with the social media platform. As already explained, we unfortunately have little influence on the web tracking methods of the social media platform. For example, we cannot switch it off. Please be aware of this: It cannot be ruled out that the provider of the social media platform may use your profile and behavioural data, for example to evaluate your habits or personal relationships and preferences, etc. We have no influence on the processing of your data by the provider of the social media platform.

Communication via the Microsoft Teams video conferencing system

We use the “Microsoft Teams” tool to organise telephone conferences, online meetings and video conferences. You will receive access to the agreed appointments via a link provided by e-mail. You can enter the video room by clicking on the link. Before joining, you can decide for yourself whether you want to activate the video or not. You are muted by default and, if you wish, you must manually enable your microphone. If you switch on your camera and/or microphone, the data from your microphone and video camera will be processed during the meeting.

If you take part in an online meeting as an external participant, you will receive an access link by email from the meeting host. When registering for the online meeting, you must then enter your name and, if applicable, your e-mail address.

The following additional data may also be processed depending on the type and scope of the specific use:

Furthermore, your personal data may be processed. This also depends specifically on your use, such as the use of the chat and the whiteboard.

We would like to explicitly draw your attention to the fact that any information you provide during the meeting will be processed at least for the duration of the meeting.

Legal basis

The legal basis for data processing for direct contractual partners is Art. 6 para. 1 lit. b) GDPR, for business partners or contact persons at external organisations the legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR. The legitimate interest lies in the organisation of virtual communication and the web conference.

Microsoft Teams is a service of the Microsoft Corporation. Further information on the processing of your data when using “Teams” can be found at: https://privacy.microsoft.com/de-de/privacystatement and https://news.microsoft.com/de-de/datenschutz-und-sicherheit-in-microsoft-teams-nutzer. We cannot rule out the possibility that data may also be routed via Internet servers located outside the EU or the EEA. The adequacy decision for the USA applies to data transfers to Microsoft in the USA. You can view Microsoft’s certification here.

The provider Microsoft necessarily receives knowledge of the above-mentioned data insofar as this is contractually regulated within the framework of our order processing contract in accordance with Art. 28 GDPR. There are no other recipients.

In principle, you are not obliged to communicate with us via Microsoft Teams. Alternatively, meetings can also be held by telephone.

We generally delete personal data when there is no need for further storage.

Rights of data subjects

In accordance with Art. 15 para. 1 GDPR, you have the right to receive information about the personal data stored about you free of charge upon request. Furthermore, if the legal requirements are met, you have the right to rectification (Art. 16 GDPR), erasure (Art. 17 GDPR) and restriction of processing (Art. 18 GDPR) of your personal data. If you have provided the processed data yourself, you have the right to data portability in accordance with Art. 20 GDPR.

If the data processing is based on Art. 6 para. 1 e) or f) GDPR, you have the right to object in accordance with Art. 21 GDPR. If you object to data processing, this will not take place in future unless the controller can demonstrate compelling legitimate grounds for further processing which override the interests of the data subject in objecting.

If the data processing is based on consent in accordance with Art. 6 para. 1 lit. a), Art. 9 para. 2 lit. a) or Art. 49 para. 1 lit. a) GDPR, you can revoke your consent at any time with effect for the future without affecting the legality of the previous processing.

You also have the right to lodge a complaint with a data protection supervisory authority. In particular, the complaint may be lodged with a supervisory authority in the EU Member State of your habitual residence, place of work or place of the alleged infringement.

Contact details of the competent data protection authority:
National Commission for Data Protection
15, Boulevard du Jazz
L-4370 Belvaux
https://cnpd.public.lu/en.html

No automated decision-making.
We do not carry out automated decision-making or profiling.

Provision
Unless otherwise stated in the previous sections, the provision of personal data is not required by law or contract or necessary for the conclusion of a contract.  Failure to provide your personal data may mean that we are unable to respond to your enquiries, for example.

This data protection information was created in cooperation with the consulting firm SCALELINE Datenschutz. The legal texts are subject to copyright.