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We are pleased that you are visiting a social media page of PHOENIX International Holdings GmbH, Pfingstweidstraße 10-12, 68199 Mannheim, Germany. To present our company and to communicate directly with you, we use social media platforms of providers such as LinkedIn, Xing and Co. ("Provider"), through which we maintain our presence (e.g. within the scope of company and employee profiles) and process your data.
The Provider of the social media platform is solely responsible for the processing of personal data on the respective social media platform itself. If data is collected on our social media presence that both the Provider and we process and use for joint purposes (e.g. in the context of analysis or advertising), there is a joint responsibility of the Provider and us according to Art. 26 DSGVO. Often, this function cannot be deactivated by us. You can therefore contact the Provider in question as well as us with your request. We currently use the following Providers:
Below you will find links to the privacy policies and information of the respective Providers, from which you can obtain information on the handling of your data by the respective Provider:
1. Informative use of the social media presence
You can visit our social media presence without providing any personal information. If you only use our social media presence for information purposes, i.e. if you do not register or otherwise provide us with personal information, we do not process any personal data, with the exception of the data that the Provider collects and transmits to us as part of the cookies it uses.
For the purpose of analysing and tracking the use of its social media platform and our social media presence, the Provider uses cookies that enable an evaluation of your surfing behaviour. This is to improve the quality of the platform and the social media presence as well as their content. We learn how the platform and the social media presence are used and can thus constantly optimise our offer.
Web analysis is the collection and evaluation of data on the behaviour of visitors to websites. A web analysis service collects, among other things, data about the website from which a data subject came to a website (so called referrers), which subpages of the website were accessed or how often and for how long a subpage was viewed. Web analysis is regularly used to optimise an internet site and to analyse the costs and benefits of internet advertising. In the process, it may also happen that the information obtained in the course of the analysis and tracking of our social media presence is merged with your other data collected in the course of using the social media presence and the platform. If you register on the platform, the Provider may link data regarding your platform activities with your personal information (including name/email address) on the basis of a given consent, thus collecting personal data and inform you individually and in a targeted manner about your preferred topics, among other things.
However, we have no influence on the collected data and data processing procedures, as the respective Provider is responsible under data protection law. With regard to the information known to us concerning, for example, the scope of data collection, the purposes of processing, the storage periods or information on deletion by the Provider, we refer to the data protection declarations of the Providers of the platforms listed under section B.
In some cases, social media platforms provide anonymous usage statistics (insights) that allow us to understand user behaviour, preferences and the content of our posts. These are based on the actions and interaction of our followers (e.g. likes, comments). We can only influence the statistics provided by the platform Provider to a limited extent and cannot switch them off. The data processing in this regard is the sole responsibility of the Provider of the social media platform. However, we make sure that no additional optional statistics are made available to us. For further information on Insights, please refer to the data protection policies of the providers mentioned in section B.
If the Providers of the respective social media platform process your data in the context of interest based advertising, you can access or adjust information on this and the settings options for your profile and your advertising preferences on the following websites of the respective social media platform:
We process your personal data on the following legal bases:
2. Active us of our social media presence
In addition to the purely informative use of our social media presence, you can also actively use our social media presence to contact us. In addition to the processing of your personal data described above for purely informational use, we will then also process further personal data from you that we require, for example, to process your enquiry. This also applies in the event that we actively use the social media presence, e.g. to contact you on our own initiative or to initiate business contacts with you. The specific data that can be viewed by the public depends on your profile settings or you can share data on your own responsibility. Please take care not to publish or share sensitive or confidential data, such as health data, bank details or job application documents, via social media platforms. This data should be exchanged with us via a secure transmission channel (e.g. post or email).
a) Share, publish and interact with posts, reviews, photos, etc.
You can comment on, share or otherwise interact with (like, recommend, review, etc.) posts, videos, etc. created by us on the Provider's platform and on our social media presence. We may share your content on our presence if this is a feature of the Provider's platform and communicate with you via the platform. Public messages etc. may be published by the Provider, but will not be used or processed by us for any other purpose at any time.
In the case of reviews, we may publish a statement (e.g. to clarify a problem, feedback on the review, further information, goodwill actions) in response to your message and invite you to contact us further. In this context, the personal data you voluntarily published in the review may be processed.
Furthermore, we reserve the right to delete content if this should be necessary due to violations of applicable law or the respective community guidelines. This is the case, for example, with posts that violate the law or are illegal, hate comments, lewd comments (explicitly sexual content) or attachments (e.g. pictures or videos) that may violate copyright, personal rights or criminal laws.
We process your personal data on the following legal bases:
b) User requests
In order to process your enquiries to us, e.g. via contact forms, a chat or our e-mail address, to answer them specifically and to provide you with the requested information, we process the personal data you provide in this context. This includes your contact details in order to send you an answer or to make any necessary queries, as well as any other information that you provide to us in this context.
If you send us a request via the platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the required response. You always have the option of sending us confidential enquiries to our address stated in the imprint or in this Social Media Privacy Policy or our privacy policy. We may contact you electronically, by telephone or by post, depending on the subject of the enquiry and the need.
We process your personal data to respond to user enquiries, requests for materials, etc. on the basis of the following legal bases:
3. Other legal bases for processing
We also process your personal data in order to fulfil other legal obligations in accordance with Art. 6 Para. 1 lit. c GDPR in connection with commercial, trade or tax law, insofar as we are obliged to record and store your data.
Your personal data may also be processed in order to assert our rights and enforce our legal claims. We also process your personal data in order to be able to defend ourselves against legal or statutory claims. Finally, we process your personal data to the extent necessary to defend against or prosecute criminal offences, infringements of copyright or proprietary rights, etc. Processing for these purposes is carried out to protect our legitimate interests in accordance with Art. 6 Para. 1 lit. f GDPR.
Initially, only our employees receive knowledge of your personal data.
Your data will only be passed on to third parties if this is permitted or required by law or if you have given your consent. We also share your data to the extent necessary with the service Providers we use, e.g. IT service Providers, agencies, legal advisors and public bodies and institutions, insofar as we are obliged to do so. In some cases, our service Providers receive your data as data processors and are then strictly bound by our instructions when handling your data. In some cases, the recipients act independently with your data that we transmit to them. The respective Provider of the social media platform may pass on your data to further categories of recipients on its own responsibility without us having any influence on this. Further information on the recipients of the data of the platform Providers can be found in the privacy policies of the Providers linked in section B or can be requested directly from them.
In the context of social media use, your data may be transmitted by the platform Provider to countries outside the European Union, including the USA. We have no influence on this. Further information is available in the data protection declarations of the platform Providers linked under section B or please enquire directly with them.
In order to fulfil the abovementioned processing purposes, we also transfer your personal data to recipients who are based outside the EU/EEA. Furthermore, if service Providers in the third country are used and we are able to influence them, we conclude EU standard contractual clauses with these recipients to ensure an adequate level of protection for your personal data. You can access the EU standard contractual clauses used via the URL eur-lex.europa.eu/legal-content/DE/TXT/PDF/. For further information, please contact our data protection officer.
During the purely informational use of our social media presence, the Provider stores your personal data on its servers. Personal data and dropped cookies are usually deleted by the Provider. The storage and deletion periods specified by the respective Provider can be taken from the respective data protection declarations linked in section B or can be requested directly from the Provider of the respective social media platform.
When you actively use our website or our social media presence, we initially store your personal data for the duration of the response to your enquiry or for the duration of our business relationship. This also includes the potential future and actual initiation of a contract (precontractual legal relationship) and the processing of a contract. We usually delete direct messages to us within one month. Otherwise, we usually delete your personal data immediately after the legal basis ceases to exist, if they are no longer required for the above mentioned purposes and there is no other legal basis (e.g. retention periods under tax and commercial law).
It is also possible that the Provider of a social media platform processes your data partially automatically with the aim of evaluating certain personal aspects (profiling). This may be done in order to provide you with targeted information and advice about products and services. Furthermore, in the context of advertisements, anonymised information is used by the Provider of a social media platform so that we can place target group specific advertisements. This processing enables communication and advertising tailored to your needs, including market and opinion research.
1. Right to information
Within the framework of Article 15 GDPR, you are entitled to request information free of charge and at any time regarding the data that is processed by us, the processing purposes, the categories of recipients, the planned storage period or, in the case of third-country transfers, the appropriate guarantees. You are also entitled to receive a copy of your data.
2. Right to rectification, deletion, restriction of processing
If your data processed by us is incorrect, incomplete or their processing is inadmissible, you may ask us to correct your data, to supplement it, restrict processing or to delete the data to the extent permitted by law, according to Article 16, 17 and 18 GDPR.
The right to deletion does not exist, among other reasons, if the processing of personal data is required for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (for example statutory storage obligations) or (iii) enforcement, exercise or defence of legal claims.
3. Right to data portability
If you provide us with your data based on your consent or contractual relationship with us, upon request we will provide you with that data in a structured, current and machine readable format or, if technically possible, submit the data to a third party that you have appointed.
4. Right of objection
If we process your data on the basis of a legitimate interest, you can object to this processing for reasons that arise from your particular situation, according to Article 21 GDPR. The right of objection only exists within the limits provided for in Article 21 GDPR. In addition, our interests may preclude termination of processing, so we may, despite your opposition, still be entitled to process your personal data.
5. Right of appeal
You are also entitled, under the provisions of Article 77 GDPR, to lodge a complaint with a supervisory authority, in particular in the member state of your place of residence, your place of work or the place of the alleged breach, if you believe that the processing of data concerning you violates the GDPR. The right of appeal is without prejudice to any other administrative or judicial remedy.
The contact person for exercising your rights is primarily the Provider of the respective social media platform, who alone has direct access to the required information of the platform and can take immediate appropriate measures. As a rule, the Irish data protection authority (Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02RD28, Ireland) is responsible for social media platform Providers based abroad. However, you can also address your complaints to the following German supervisory authorities:
If necessary, we will of course be happy to support you. For the contact person or the data protection supervisory authority responsible for us please refer to our privacy policy (see section C. VI. of this Social Media Privacy Policy).
However, we recommend that you always first address a complaint to our data protection officer (see section D. II of this Social Media Privacy Policy) or the data protection contact of the respective platform Provider.
Our data protection officer is available to you as a contact person for data protection related concerns towards PHOENIX International Holdings GmbH:
PHOENIX International Holdings GmbH
Pfingstweidstraße 10-12
68199 Mannheim, Germany
Telephone.: +49 621/8505-0
Email: dataprotection(at)phoenixgroup.eu
We reserve the right to change this Social Media Privacy Policy at any time. Any changes will be announced by publishing the amended Social Media Privacy Policy on our website www.phoenixgroup.eu/de/social-media. Unless otherwise stated, such changes will take effect immediately. Therefore, please check this Social Media Privacy Policy regularly to see the latest version.
Last updated: November 2023
