Data Protection - webSignature Office

Data Protection

PERSONAL INFORMATION

In cases in which Users are asked for personal data, they will be treated confidentially and in compliance with the laws on data protection. Personal data is only collected and used when needed to configure or process the content of the commitments acquired. Users may at any time request information on their personal data at no charge. Users may also request deletion of their personal data, as long as they have fulfilled all the commitments in the contract and the retention of their data is not mandatory.
Web-based applications such as webSignatureOffice keep a log of the start and end of sessions and, of the user’s IP-Address and the user’s activities on the web-based application, for example, for billing or statistical purposes, as proof of transactions (for example, to create an audit trail as part of the digital signature services) and to optimise products. Please note the terms of use of the web-based application and the data protection provisions.
The operator stores so called session cookies on the computer of the user for e.g. checking if the user is logged in. The operator may use permanent cookies. Furthermore the operator uses cookies of third parties service providers to analyze data in compressed form.

NON-PERSONAL DATA

• Location of the visitors (without indicating the specific place, only the country)
• Web browser type
• Date and time of the visit to our website
• Pages visited on our website
• Data accessed on our website
• Duration of the visit to the different sections of our website
• Visits resulting from search engines
General: Transmitting data over the internet may entail security risks, so it is possible that third parties may manage to access these data. Total security is not possible.

DATA ABUSE

The contact data published owing to the duty of disclosure of the legal notice may not be used for sending advertising and information materials that have not been explicitly requested. StepOver International GmbH reserves the right to take legal action in case of receiving unsolicited promotional information, as well as spam.

Data storage time periods

Data collected for invoices will be stored until the expiration of a 10 year time limit. Information about the contractional relationship required by commercial law and taxation law up to the legally imposed time limits according to article 6, paragraph 1, sentence 1, letter c GDPR.
During this time period, the data will only be processed again in case of an examination by fiscal authorities. After the expiration of this time limit, the data collected for invoices will be deleted or the access to it will be blocked if deletion is not possible. If the we do not process your data (anymore) for operational purposes, the data is saved until the expiration of the time limit of at most 6 months.

Google Analytics

We use Google Analytics on our website. This is a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter referred to as "Google". We process data with the help of Google Analytics for the purpose of optimising our website and for marketing purposes on the basis of your consent pursuant to Art. 6 (1) lit. a. DSGVO. Usage and user-related information, such as IP address, location, time or frequency of visits to our website, is transferred to a Google server in the USA and stored there. The data collected in this way is in turn used by Google to provide us with an evaluation of the visit to our website and the usage activities there. This data may also be used to provide other services related to the use of our website and the use of the internet. Google states that it will not associate your IP address with any other data. Google also provides further information on data protection at: https://www.google.com/intl/de/policies/privacy/partners Google also provides you with further information on data protection law, including information on how to prevent the use of your data. The concrete storage period of the processed data cannot be influenced by us, but is determined by Google Ireland Limited. Further information can be found in the data protection declaration for Google Analytics: https://policies.google.com/privacy. In addition, Google offers a so-called deactivation add-on at https://tools.google.com/dlpage/gaoptout?hl=de offers a so-called deactivation add-on together with further information on this. This add-on can be installed with the usual Internet browsers and offers you further control over the data that Google collects when you call up our website. The add-on informs the JavaScript (ga.js) of Google Analytics that information about your visit to our website should not be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services. Of course, you can also find out whether and which other web analytics services we use in this privacy policy.

Google AdWords with conversion tracking

In our website, we use the advertising component Google AdWords and the so-called conversion tracking. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereinafter referred to as "Google". We process your data with the help of Google Ads for the purpose of optimising our website and for marketing purposes on the basis of your consent pursuant to Art. 6 para. 1 lit. a. DSGVO. If you click on an ad placed by Google, the conversion tracking we use saves a cookie on your terminal device. These so-called conversion cookies lose their validity after 30 days and do not serve to identify you personally. If the cookie is still valid and you visit a specific page of our website, both we and Google can evaluate the fact that you have clicked on one of our advertisements placed with Google and that you have subsequently been redirected to our website. Google uses the information obtained in this way to create statistics for us about visits to our website. In addition, this provides us with information about the number of users who clicked on our ad(s) and about the pages of our website that were subsequently accessed. However, neither we nor third parties who also use Google AdWords are able to identify you in this way. You can also prevent or restrict the installation of cookies using the appropriate settings in your internet browser. At the same time, you can delete cookies already stored at any time. However, the steps and measures required for this depend on the specific internet browser you use. If you have any questions, please use the help function or documentation of your Internet browser or contact its manufacturer or support. Furthermore, Google also offers the following services at:
https://services.google.com/sitestats/de.html
https://www.google.com/policies/technologies/ads/
http://www.google.de/policies/privacy/

Google also offers further information on this topic and in particular on the possibilities of preventing the use of data.

Google Tag Manager

Type and scope of processing

We use the Google Tag Manager provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is used to manage website tags through one interface and allows us to control the precise integration of services on our website. This allows us to flexibly integrate additional services to evaluate user access to our website.

Purpose and legal basis

Google Tag Manager is used on the basis of our legitimate interests, i.e. interest in optimising our services in accordance with Art. 6 para. 1 lit. f. DSGVO.

Storage period

The specific storage period of the processed data cannot be influenced by us, but is determined by Google Ireland Limited. Further information can be found in the privacy policy for Google Tag Manager: https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/.

Usercentrics

Type and scope of processing

We have integrated Usercentrics on our website. Usercentrics is a consent solution provided by Usercentrics GmbH, Rosental 4, D- 80331 Munich, Germany, which can be used to obtain and document consent to store cookies. Usercentrics uses cookies or other web technologies to recognise users and to store the consent given or revoked.

Purpose and legal basis

The service is used on the basis of obtaining the legally required consent for the use of cookies in accordance with Art. 6 para. 1 lit. c. DSGVO.

Storage period

The specific storage period of the processed data cannot be influenced by us, but is determined by Usercentrics GmbH. Further information can be found in the privacy policy for Usercentrics: https://usercentrics.com/privacy-policy/.

Qualified Electronic Signature

For the service of the Qualified Electronic Signature (QES) we use the following sub-processors:

Data Processing purpose Legal Entity GDPR Documentation & Datacenter location
Digital Signing Plattform SIGNIUS S.A.
ul. Krasińskiego 16
60-830 Poznań
Poland
https://signius.eu/en/privacy-policy/

Datacenter:
Warsaw, Poland

Remote Identity Verification identity Trust Management AG
Lierenfelder Straße 51
40231 Düsseldorf
Germany
identity.tm.PrivacyPolicy.pdf

Datacenter:
ScanPlus GmbH, Germany

Remote Identity Verification Nect GmbH
Großer Burstah 21
20457 Hamburg
Germany
https://nect.com/de/data-protection/
Remote Identity Verification Verimi GmbH
Oranienstraße 91
10969 Berlin
Germany
https://verimi.de/en/data-protection/
https://verimi.de/wp-content/uploads/2020/10/Verimi_White-Paper_Security_EN.pdf

Datacenter:
Open Telekom Cloud, Germany

Qualified Electronic Signatures Eurocert Sp. z o.o.
Puławska 474
02-884 Warsaw
Poland
https://eurocert.pl/en/category/documents/

Datacenter:
Eurocert Sp. z .o.o., Warsaw, Poland

SMS Gateway for sending OTPs Link Mobility Poland Sp. z o.o.
ul. Toszecka 101
44-100 Gliwice
Poland
https://www.smsapi.com/en/terms

Datacenter:
Atman S.A,
ul. Grochowska 21 a,
04-186 Warszawa

Remote Identity Verification IDENTT Sp. z o.o.
Romana Dmowskiego 17
50-203 Wrocław
Poland
https://www.identt.pl/gdpr
https://www.identt.pl/privacy-policy

Datacenter:
AWS, Frankfurt, Germany

Server hosting for SIGNIUS Chmura Krajowa Sp. z o.o.
ul. Grzybowska 62
00-844 Warszawa
Poland
https://chmurakrajowa.pl/en/
https://chmurakrajowa.pl/pdf/Polityka_prywatnosci.pdf

Responsible under the terms of article 4, paragraph 7 GDPR is:

StepOver International GmbH
Otto-Hirsch-Brücken 17
70329 Stuttgart

If you have any queries about data protection at StepOver, please contact:

DataProtection@stepover.com

We would like to make you aware of the rights afforded to you by the EU General Data Protection Regulation
You have the following rights:

Article 15
Right of Access by the Data Subject

(1 The data subject shall have the right to obtain from the controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D–70329 Stuttgart) confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
(a the purposes of the processing;
(b) the categories of personal data concerned;(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f the right to lodge a complaint with a supervisory authority;
(g where the personal data are not collected from the data subject, any available information as to their source;
(h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

(2) Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

(3) The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

(4) The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16
Right to Rectification

The data subject shall have the right to obtain from the controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D–70329 Stuttgart) without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17
Right to Erasure (“Right to be Forgotten”)

(1) The data subject shall have the right to obtain from the controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D–70329 Stuttgart) the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

(2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

(3) Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims

Article 18
Right to Restriction of Processing

(1) The data subject shall have the right to obtain from the controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D – 70329 Stuttgart) restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

(2) Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

(3) A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 19
Notification Obligation Regarding Rectification or Erasure of Personal Data or Restriction of Processing

The controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D – 70329 Stuttgart) shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

Article 20
Right to Data Portability

(1) The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D – 70329 Stuttgart), in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
(b) the processing is carried out by automated means.

(2) In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

(3) The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

(4) The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21
Right to Object

(1) The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller (StepOver International GmbH – Otto-Hirsch-Brücken 17 – D – 70329 Stuttgart) shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

(2) Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

(3) Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

(4) At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

(5) In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

(6) Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Your right to lodge a complaint with a supervisory authority

You are entitled to file a complaint with your competent data protection authority at any time. If you would like to assert your right to lodge a complaint, you may do so with the following authority:
Baden-Württemberg

State Commissioner for Data Protection and Freedom of Information in Baden-Württemberg:

Dr Stefan Brink
Postfach 10 29 32
D–70025 Stuttgart
or:
Königstraße 10a
D–70173 Stuttgart

Tel.: +49 (0)711/615541-0
Fax: +49 (0)711/615541-15

Email: poststelle@lfdi.bwl.de