In the following, we provide information about the processing of personal data when using
Personal data is all data that can be related to a specific natural person, e.g. their name or IP address.
The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Five Glaciers Consulting GmbH, Methfesselstraße 26, 20257 Hamburg, Germany, e-mail: info@fiveglaciers.com. We are legally represented by Merlin Christopher Köhnke, Kevin Möller.
Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.
The scope of data processing, processing purposes and legal bases are explained in detail below. The following legal bases for data processing can generally be considered:
Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 para. 3 GDPR guarantee the security of the data of both transfers, insofar as these are available, as is the case, for example, for the UK, Canada and Israel.
In the case of data transfer to service providers in the USA, the legal basis for data transfer is an adequacy decision by the EU Commission if the service provider is also certified under the EU-US Data Privacy Framework.
In other cases (e.g. if there is no adequacy decision), the legal basis for data transfer is usually standard contractual clauses, i.e. unless we indicate otherwise. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they guarantee the security of data transfer. Many of the providers have provided contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding the obligation of the third party to inform the data subject if law enforcement agencies wish to access data.
Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.
Data subjects have the following rights vis-à-vis us with regard to the personal data concerning them:
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities can be found athttps://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.htmlabrufbar.
In the context of a business relationship or other relationship, customers, interested parties or third parties must only provide us with the personal data that is necessary for the establishment, execution and termination of the business relationship or for the other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory information is marked as such.
In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. Should we use these procedures in individual cases, we will inform you separately if this is required by law.
When you contact us, e.g. by email or telephone, the data you provide us with (e.g. names and email addresses) will be stored by us in order to answer your questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in answering inquiries addressed to us. We delete the data collected in this context after storage is no longer necessary, or restrict processing if there are statutory retention obligations.
From time to time, we conduct customer surveys to get to know our customers and their wishes better. We collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6(1)(f) GDPR. We delete the data once the results of the surveys have been evaluated.
We reserve the right to inform customers who have already used our services or purchased goods about our offers from time to time by email or other means if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in direct advertising (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time at no additional cost, for example via the link at the end of each email or by sending an email to our email address stated above.
We send newsletters using the HubSpot tool from the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy:https://legal.hubspot.com/de/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the EU.
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), the details of which can be found in the following sections.
This storage and access takes place on the basis of the following provisions:
Downstream data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.
When using the website for informational purposes, i.e. when visitors to the site do not send us information separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.
These data are:
This data is also stored in log files. They are deleted when their storage is no longer required, at the latest after 14 days.
Our website is hosted by Webflow. The provider is Webflow, Inc, 398 11th St., Floor 2, San Francisco, CA 94103, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the USA. Further information can be found in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.
It is our legitimate interest to provide a website, so that the legal basis for the data processing described is Art. 6 para. 1 sentence 1 lit. f GDPR.
The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided that the third country offers an adequate level of protection as part of an adequacy decision in accordance with Art. 45 (3) GDPR.
We use the Webflow content delivery network for our website. The provider is Webflow, Inc, 398 11th St., Floor 2, San Francisco, CA 94103, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication or contact data, in the USA. Further information can be found in the provider's privacy policy at https://webflow.com/legal/eu-privacy-policy.
We have a legitimate interest in using sufficient storage and delivery capacities in order to ensure optimal data throughput even during large load peaks. The legal basis for the data processing described is therefore Art. 6 para. 1 sentence 1 lit. f GDPR.
The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided that the third country offers an adequate level of protection as part of an adequacy decision in accordance with Art. 45 (3) GDPR.
When you contact us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in responding to inquiries addressed to us. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR.
We delete the data arising in this context after the storage is no longer necessary or restrict the processing if there are legal storage obligations.
We publish job vacancies in our company on our website, on pages linked to the website or on third-party websites.
The data provided in the application is processed in order to carry out the application procedure. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 BDSG. We have marked the data required to carry out the application process accordingly or refer to it. If applicants do not provide this data, we will not be able to process the application.
Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 sentence 1 lit. a GDPR).
We ask applicants to refrain from providing information on political opinions, religious beliefs and similar sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the CV or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).
Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.
We pass on applicants' data to the responsible employees in the HR department, to our processors in the area of recruiting and to the other employees involved in the application process.
If we enter into an employment relationship with the applicant following the application process, we will only delete the data after the employment relationship has ended. Otherwise, we will delete the data no later than six months after rejecting an applicant.
If applicants have given us their consent to use their data for further application procedures, we will only delete their data one year after receipt of the application.
Our website uses cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the website more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "technically necessary cookies"), the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we set technically necessary cookies for the following purpose or purposes:
We use Hotjar for analysis. The provider is Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's, STJ 3141, Malta. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation.
The data will be deleted if the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://www.hotjar.com/legal/policies/privacy/.
We use HubSpot to generate leads, automate marketing and for analysis. The provider is HubSpot, Inc, 251st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and inexpensive way.
The data will be deleted if the purpose of its collection no longer applies and there are no retention obligations to the contrary. Further information can be found in the provider's privacy policy at https://legal.hubspot.com/privacy-policy.
We use Google Analytics for analysis. The provider is Google LLC, 1600 Amphitheatre Parkway Mountain View, CA94043, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided that the third country offers an adequate level of protection as part of an adequacy decision in accordance with Art. 45 (3) GDPR.
The data will be deleted if the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.
We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided that the third country offers an adequate level of protection as part of an adequacy decision in accordance with Art. 45 (3) GDPR.
We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.
We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data protection compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative to confirmation.
The data is masked after collection so that there is no longer any personal reference. Further information can be found in the provider's privacy policy at https://heydata.eu/datenschutzerklaerungabrufbar.
We are represented on social media networks in order to present our organization and our services. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to display advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the network operators store information on user behavior in cookies on the user's computer. It is also possible that the operators may combine this information with other data. Users can find further information and information on how users can object to processing by the site operators in the privacy policies of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, meaning that they process data there. This may result in risks for users, e.g. because the enforcement of their rights is made more difficult or government agencies gain access to the data.
When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.
We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. You can object to data processing via the settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are jointly responsible for processing the data of visitors to our profile on the basis of an agreement with Facebook within the meaning of Art. 26 GDPR. Facebook explains exactly which data is processed athttps://www.facebook.com/legal/terms/information_about_page_insights_data.Betroffene can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Those affected will therefore receive faster feedback if they contact Facebook directly.
We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.
We maintain a profile on X. The operator is X Corp, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here:https://twitter.com/de/privacy. You can object to data processing via the settings for advertisements:https://twitter.com/personalization.
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here:https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. You can object to data processing via the settings for advertisements:https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
We maintain a profile on Xing. The operator is New Work SE, Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available here: https://privacy.xing.com/de/datenschutzerklaerung.
We reserve the right to amend this privacy policy with effect for the future. A current version is always available here.
If you have any questions or comments regarding this privacy policy, please do not hesitate to contact us using the contact details above.
