1. Introduction

In the following, we provide information about the collection of personal datawhen using

• our website https://www.eacp-aero.eu/
• our profiles in social media.

Personal data is any data that can be related to a specific natural person, such astheir name or IP address.

1.1 Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data ProtectionRegulation (GDPR) is Hamburg Aviation e. V., Wexstraße 7, Hamburg, Germany,email: info@hamburg-aviation.com. We are legally represented by Michael Vollrath, General Manager.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5,10117 Berlin,
www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposesand legal bases

We detail the scope of data processing, processing purposes and legal basesbelow. In principle, the following come into consideration as the legal basis fordata processing:

• Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operationsfor which we obtain consent.
• Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing ofpersonal data is necessary for the performance of a contract, e.g. if a sitevisitor purchases a product from us or we perform a service for him. Thislegal basis also applies to processing that is necessary for pre-contractualmeasures, such as in the case of inquiries about our products or services.
• Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processingpersonal data, as may be the case, for example, in tax law.
• Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely onlegitimate interests to process personal data, e.g. for cookies that arenecessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside theEEA, the security of the data during the transfer is guaranteed by adequacydecisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canadaand Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for thedata transfer is an adequacy decision of the EU Commission if the service providerhas also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the datatransfer are usually, i.e. unless we indicate otherwise, standard contractual clauses.These are a set of rules adopted by the EU Commission and are part of thecontract with the respective third party. According to Art. 46 para. 2 lit. b GDPR,they ensure the security of the data transfer. Many of the providers have givencontractual guarantees that go beyond the standard contractual clauses toprotect the data. These include, for example, guarantees regarding the encryptionof data or regarding an obligation on the part of the third party to notify datasubjects if law enforcement agencies wish to access the respective data.

1.4 Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deletedas soon as they are no longer required for their intended purpose and no legalobligations to retain data conflict with the deletion. If the data are not deletedbecause they are required for other and legally permissible purposes, theirprocessing is restricted, i.e. the data are blocked and not processed for otherpurposes. This applies, for example, to data that must be retained for commercialor tax law reasons.

1.5 Rights of data subjects

Data subjects have the following rights against us with regard to their personaldata:

• Right of access,
• Right to correction or deletion,
• Right to limit processing,
• Right to object to the processing,
• Right to data transferability,
• Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisoryauthority about the processing of their personal data. Contact details of the dataprotection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

Within the scope of the business or other relationship, customers, prospectivecustomers or third parties need to provide us with personal data that is necessaryfor the establishment, execution and termination of a business or otherrelationship or that we are legally obliged to collect. Without this data, we willgenerally have to refuse to conclude the contract or to provide a service or will nolonger be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7 No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making processin accordance with article 22 GDPR to establish and implement the business orother relationship. Should we use these procedures in individual cases, we willinform of this separately if this is required by law.

1.8 Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g.names and e-mail addresses) will be stored by us in order to answer questions. Thelegal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR)to answer inquiries directed to us. We delete the data accruing in this context afterthe storage is no longer necessary or restrict the processing if there are legalretention obligations.

1.9 Customer surveys

From time to time, we conduct customer surveys to get to know our customersand their wishes better. In doing so, we collect the data requested in each case. Itis our legitimate interest to get to know our customers and their wishes better, sothat the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR.We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from usor purchased goods from time to time by e-mail or other means about our offers, ifthey have not objected to this. The legal basis for this data processing is Art. 6 para.1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47GDPR). Customers can object to the use of their e-mail address for advertisingpurposes at any time without incurring additional costs, for example via the link atthe end of each e-mail or by sending an e-mail to our above-mentioned e-mailaddress.

Interested parties have the option to subscribe to a free newsletter. We processthe data provided during registration exclusively for sending the newsletter.Subscription takes place by selecting the corresponding field on our website, byticking the corresponding field in a paper document or by another clear action,whereby interested parties declare their consent to the processing of their data, sothat the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at anytime, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remainslawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we alsomeasure the opening and click-through rate of our newsletters to understandwhat is relevant for our audience.

• We send newsletters with the tool Brevo of the provider Sendinblue GmbH,Köpenicker Str. 126, 10179 Berlin. The provider processes content, usage,meta/communication data and contact data in the process in the EU. Further information is available in the provider's privacy policy at https://www.sendinblue.com/legal/privacypolicy/.

3. Data processing on our website

3.1 Notice for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g.cookies) or accesses information that is already stored in the terminal equipment(e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions: 

• Insofar as this storage or access is absolutely necessary for us to provide theservice of our website expressly requested by website visitors (e.g., to carryout a chatbot used by the website visitor or to ensure the IT security of ourwebsite), it is carried out on the basis of Section 25 para. 2 no. 2 of theGerman Telecommunications Digital Services Data Protection Act(Telekommunikation-Digitale-Dienste-Datenschutzgesetz, "TDDDG").
• Otherwise, this storage or access takes place on the basis of the websitevisitor's consent (Section 25 para. 1 TDDDG).

The subsequent data processing is carried out in accordance with the followingsections and on the basis of the provisions of the GDPR.

3.2 Informative use of our website

During the informative use of the website, i.e. when site visitors do not separatelytransmit information to us, we collect the personal data that the browser transmitsto our server in order to ensure the stability and security of our website. This is ourlegitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.3 Web hosting and provision of the website

Our website is hosted by Homepage Helden. The provider is Homepage HeldenGmbH, Poststraße 20, DE-20354 Hamburg. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage,meta/communication data or contact data, in the EU. Further information can befound in the provider's privacy policy at https://www.homepage-helden.de/datenschutz/.

It is our legitimate interest to provide a website, so the legal basis of the describeddata processing is Art. 6 para. 1 s. 1 lit. f GDPR.

3.4 Contact form

When contacting us via the contact form on our website, we store the datarequested there and the content of the message. The legal basis for theprocessing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We delete the dataaccruing in this context after the storage is no longer necessary or restrict theprocessing if there are legal retention obligations.

3.5 Vacant positions

We publish vacant positions on our website, on pages linked to the website or onthird-party websites.
The processing of the data provided as part of the application is carried out for thepurpose of implementing the application process. Insofar as this is necessary forour decision to establish an employment relationship, the legal basis is Art. 88para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act(Bundesdatenschutzgesetz). We have marked the data required to carry out theapplication process accordingly or refer to them. If applicants do not provide thisdata, we cannot process the application.Further data is voluntary and not requiredfor an application. If applicants provide further information, the basis is theirconsent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions,religious beliefs and similarly sensitive data in their CV and cover letter. They arenot required for an application. If applicants nevertheless provide suchinformation, we cannot prevent their processing as part of the processing of theresume or cover letter. Their processing is then also based on the consent of theapplicants (Art. 9 para. 2 lit. a GDPR).
Finally, we process the applicants' data for further application procedures if theyhave given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HRdepartment, to our data processors in the area of recruiting and to the employeesotherwise involved in the application process.

If we enter into an employment relationship with the applicant following theapplication process, we delete the data only after the employment relationshiphas ended. Otherwise, we delete the data no later than six months after rejectingan applicant.

If applicants have given us their consent to use their data for further applicationprocedures as well, we will not delete their data until one year after receiving theapplication.

3.6 Third parties

3.6.1 Usercentrics 

We use Usercentrics to manage consents. The provider is Usercentrics GmbH,Sendlinger Straße 7, 80331 Munich. The provider processes meta/communicationdata (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have alegitimate interest in managing the consent of website visitors to cookies in asimple manner.

The data will be deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is available in theprovider's privacy policy at https://usercentrics.com/privacy-policy/.

3.6.2 Cookiebot

We use Cookiebot to manage consents. The provider is Usercentrics A/S,Havnegade 39, DK-1058, Copenhagen. The provider processesmeta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have alegitimate interest in managing the consent of website visitors to cookies in asimple manner.

The data will be deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is available in theprovider's privacy policy at https://www.cookiebot.com/en/privacy-policy/.

3.6.3 etracker

We use etracker for analytics. The provider is etracker GmbH, Erste Brunnenstraße1, 20459 Hamburg. The provider processes usage data (e.g. web pages visited,interest in content, access times), meta/communication data (e.g. deviceinformation, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR.

The processing isbased on consent. Data subjects may revoke their consent at any time bycontacting us, for example, using the contact details provided in our privacy policy.

The revocation does not affect the lawfulness of the processing until therevocation.

The data will be deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is available in theprovider's privacy policy at https://www.etracker.com/datenschutzerklaerung/.

3.6.4 heyData

We have integrated a data protection seal on our website. The provider is heyDataGmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processesmeta/communication data (e.g. IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimateinterest in providing website visitors with confirmation of our data privacycompliance. At the same time, the provider has a legitimate interest in ensuringthat only customers with existing contracts use its seals, which is why a mereimage copy of the certificate is not a viable alternative as confirmation.

As the data is masked after collection, there is no possibility to identify websitevisitors. Further information is available in the privacy policy of the provider at
https://heydata.eu/en/privacy-policy.

4. Data processing on social media platforms

We are represented in social media networks in order to present our organizationand our services there. The operators of these networks regularly process theirusers' data for advertising purposes. Among other things, they create user profilesfrom their online behavior, which are used, for example, to show advertising on thepages of the networks and elsewhere on the Internet that corresponds to theinterests of the users. To this end, the operators of the networks store informationon user behavior in cookies on the users' computers. Furthermore, it cannot beruled out that the operators merge this information with other data. Users canobtain further information and instructions on how to object to processing by thesite operators in the data protection declarations of the respective operators listedbelow. It is also possible that the operators or their servers are located in non-EUcountries, so that they process data there. This may result in risks for users, e.g.because it is more difficult to enforce their rights or because government agenciesaccess the data.

If users of the networks contact us via our profiles, we process the data provided tous in order to respond to the inquiries. This is our legitimate interest, so that thelegal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

4.1 Instagram

We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd., 4Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy isavailable here: https://help.instagram.com/519522125107875.

4.2  YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited GordonHouse, Barrow Street Dublin 4. Ireland. The privacy policy is available here:https://policies.google.com/privacy?hl=de.

4.3 LinkedIn 

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland UnlimitedCompany, Wilton Place, Dublin 2, Ireland. The privacy policy is available here:https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to dataprocessing is via the settings for advertisements:https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. Acurrent version is always available here.
 

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feelfree to contact us using the contact information provided above.