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<!DOCTYPE html>
<html lang="en">
<head>
<meta charset="UTF-8">
<meta name="viewport" content="width=device-width, initial-scale=1.0">
<title>Privacy Information for the Remote Signature System signFLOW</title>
<title>Data Protection Information for the Remote Signature System signFLOW</title>
<link rel="stylesheet" href="css/privacy-policy.min.css">
</head>
<body>
<header>
<h1>Privacy Information for the Remote Signature System signFLOW</h1>
<p><strong>Last updated:</strong> 19.09.2024</p>
<h1>Data Protection Information for the Remote Signature System signFLOW</h1>
<p><strong>As of:</strong> 19.09.2024</p>
</header>
<section>
<h2>1. General Information</h2>
<p>In today’s fast-paced and increasingly digital world, personal data is a valuable resource. Your data is important and must be handled with care as mandated by various laws and regulations (GDPR, TDDDG, ...).</p>
<p>As a provider of on-premise solutions, the manufacturer of signFLOW, Digital Data GmbH, places a clear emphasis on data protection and data security. For you, this means that only the necessary data is collected and stored (data minimization). Additionally, the processing is done using the latest and considered secure technologies.</p>
<p><strong>Manufacturer's Contact Information:</strong></p>
<p>In today's fast-paced and increasingly digital world, personal data is an important resource. Your data is
valuable and must therefore be handled with the care required by various laws and regulations (GDPR, TDDDG,
...).</p>
<p>As a provider of local solutions (OnPremise), the manufacturer of signFLOW, Digital Data GmbH, places a clear
focus on data protection and data security. For you, this means that only the necessary data is collected
and stored (data minimization). Furthermore, current and secure technologies are used in processing.</p>
<p><strong>Contact details of the manufacturer:</strong></p>
<address>
Digital Data GmbH<br>
Ludwig-Rinn-Straße 16<br>
@@ -25,12 +30,13 @@
<a href="mailto:info-flow@digitaldata.works">info-flow@digitaldata.works</a><br>
Phone: 0049 641 202360<br>
</address>
<p><strong>Contact for Data Protection:</strong> <a href="mailto:privacy-flow@digitaldata.works">privacy-flow@digitaldata.works</a></p>
<p><strong>Contact the Data Protection Officer:</strong> <a
href="mailto:privacy-flow@digitaldata.works">privacy-flow@digitaldata.works</a></p>
</section>
<section>
<h2>2. Responsible Party for Data Processing</h2>
<p>Your data will be processed confidentially by:</p>
<h2>2. Responsible Entity for Data Processing</h2>
<p>Your data is processed with confidence by:</p>
<address>
Digital Data GmbH<br>
Ludwig-Rinn-Straße 16<br>
@@ -39,85 +45,241 @@
<a href="mailto:info-flow@digitaldata.works">info-flow@digitaldata.works</a><br>
Phone: 0049 641 202360<br>
</address>
<p><strong>Contact our Data Protection Officer:</strong> <a href="mailto:privacy-flow@digitaldata.works">privacy-flow@digitaldata.works</a></p>
<p><strong>Contact our Data Protection Officer:</strong> <a
href="mailto:privacy-flow@digitaldata.works">privacy-flow@digitaldata.works</a></p>
</section>
<section>
<h2>3. Data Collection</h2>
<h3>3.1 The following categories of personal data are processed:</h3>
<h3>3.1 The following categories of personal data are processed</h3>
<ul>
<li>Names: First and last names, and your digital signature</li>
<li>Names: First and last names as well as your digital signature</li>
<li>Contact details: Phone number, mobile phone number, and email address</li>
<li>Technical data: IP address, time of access, or attempted access</li>
<li>Technical data: IP address, time of access, or access attempts</li>
</ul>
<h3>3.2 Source of personal data</h3>
<p>You have previously provided the data listed in 3.1 to your business partner (the responsible party). This submission may have occurred orally by phone, in person, via email, or through a contact form.</p>
<p>You submit your digital signature independently when signing a document.</p>
<h3>3.2 Source of the personal data</h3>
<p>You have previously provided the data mentioned under 3.1 to your business partner (the responsible entity).
This transmission may have occurred verbally over the phone, in personal contact, via email, or via a
contact form.</p>
<p>You transmit your digital signature independently when signing a document.</p>
<h3>3.3 Retention periods / storage duration</h3>
<h3>3.3 Retention periods / Storage duration</h3>
<ul>
<li>Automatic email correspondence is stored for 6 years.</li>
<li>Signed contracts are stored for the duration of their term plus 10 years.</li>
<li>The technical process is stored indefinitely in the signFLOW software solution depending on the type of document or contract.</li>
<li>Signed contracts are retained for the duration of their term + 10 years.</li>
<li>The technical process is stored in the signFLOW software solution indefinitely, depending on the
document or contract type.</li>
</ul>
<p>Your personal data will generally be anonymized when:</p>
<ul>
<li>The contract has expired and the legal retention period has passed.</li>
<li>The contract has expired, and the statutory retention period is over.</li>
<li>The contract was rejected by you or never signed.</li>
</ul>
<p>The legal bases for these retention periods include:</p>
<p>The legal basis for these retention periods includes:</p>
<ul>
<li>Commercial Code (HGB)</li>
<li>Tax Code (AO)</li>
<li>Principles for the proper management and storage of books, records, and documents in electronic form and access to data (GoBD)</li>
<li>Principles for the Proper Keeping and Retention of Books, Records, and Documents in Electronic Form and
for Data Access (GoBD)</li>
</ul>
<p>
Depending on the specific type of document, the retention period may vary. Additionally, the periods may be
extended in case of irregularities, such as a pending or ongoing legal dispute.
</p>
<h3>3.4 Purpose of processing</h3>
<p>The personal data defined in 3.1 is processed to enable the technically necessary process. This includes identity verification, application review, billing, and documentation obligations.</p>
<p>The personal data defined under 3.1 is processed to:</p>
<ul>
<li>Support or provide the technically necessary process.</li>
<li>Enable you, as the end user, to sign a document digitally. This requires the identification of the
applicant, application verification and processing, billing, and compliance with documentation
requirements.</li>
</ul>
<p>In individual cases, data is processed separately by the IT department, particularly in response to support
requests, or possibly forwarded to the manufacturer for further processing.</p>
<p>Data processing also occurs to ensure information security, especially for the identification and prevention
of attacks, and for conducting internal and external audits, export controls, and sanctions list checks.
Information may also be transmitted to the relevant authorities in accordance with Section 8 (2) VDG.</p>
<h3>3.5 Lawfulness of processing</h3>
<p>Your data is collected based on a developing or existing business relationship.</p>
<p>The legal basis for transferring data to responsible authorities is §8 para. 2 VDG.</p>
<h3>3.5 Legality of processing</h3>
<p>Your data is collected based on an impending or already existing business relationship.</p>
<p>The legal basis for the transmission to competent authorities is Section 8 (2) VDG. Requests from data
subjects are processed in accordance with Articles 12 to 23 of the GDPR and Sections 32 to 37 of the Federal
Data Protection Act (BDSG).</p>
<h3>3.6 Legitimate interests</h3>
<p>There is a legitimate interest of the responsible party according to Art. 6 para. 1 lit. f GDPR, especially in information security and damage prevention.</p>
<p>A legitimate interest of the responsible entity in accordance with Article 6 (1) (f) GDPR exists in the
following cases:</p>
<p>Measures are taken for information security, which include both preventive technical and organizational
measures as well as incident handling. The aim is to assess and avoid potential harm to the company, the
individuals affected by data processing, and the users of trust services.</p>
<h3>3.7 Necessity of the data</h3>
<p>The data collected represents the minimum necessary for the purpose of a digital signature.</p>
<h3>3.7 Necessity of data</h3>
<p>The collected data represents the minimum necessary for the digital signature. Without the data mentioned
under 3.1, the service cannot be operated.</p>
<p>It is particularly important to provide a mobile number or a German landline number, as this is used for
authentication and signature triggering as a second factor. Without this security mechanism, the service
cannot be provided.</p>
<h3>3.8 Data sharing</h3>
<p>Data is only shared with the manufacturer in exceptional cases for support services.</p>
<h3>3.8 Data transfer</h3>
<p>Systematic data transmission does not take place.</p>
<p>Data is only forwarded to the manufacturer for support services in exceptional cases. A valid data processing
agreement (DPA) exists with the manufacturer, which ensures the security and integrity of the handling of
your data.</p>
</section>
<section>
<h2>4. Use of Cookies</h2>
<p>Temporary cookies are used when visiting certain pages, which are necessary for the technical provision of the services.</p>
<p>
When visiting certain pages, temporary cookies are used, which are necessary for the technical provision of
the services. These so-called session cookies do not contain any personal data and are automatically deleted
after the session ends. Methods such as Java applets or Active-X controls that could track user behavior are
not used.
</p>
</section>
<section>
<h2>5. Rights of Data Subjects</h2>
<p>If you have questions about your data or wish to request rectification, deletion, or restriction of processing, please send your inquiry by post or email to the address listed above. You can also object to the processing under Art. 21 GDPR.</p>
<h2>5. Rights of Affected Persons</h2>
<p>
If you have questions about your data or wish to request correction, deletion, or restriction of processing,
please send your request by mail or email to the address provided above. This also applies if you wish to
object to the processing in accordance with Article 21 GDPR or request data portability.
</p>
<p>
If you have questions or complaints about a procedure, you can also contact us using the contact details
provided. If you have further grounds for complaint, you can contact our supervisory authority. You can find
out which supervisory authority is responsible for you here:
<a href="https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html">Laender-node.html</a>
</p>
</section>
<section>
<h2>6. Whistleblower System</h2>
<p>We have established an independent, neutral, and confidential whistleblower system that allows internal and external whistleblowers to submit reports anonymously. This system serves to uncover serious violations of applicable law and other significant matters.</p>
<p>
Compliance with legal regulations and internal guidelines, including our Code of Conduct and the Code of
Conduct for Business Partners, is our (the data processing entity's) top priority. This applies both to our
own business operations and to our supply chains.
</p>
<p>
It is important to us to identify risks early and avoid violations. We aim to take appropriate measures in a
timely manner to prevent potential harm to affected persons, customers, employees, business partners, and
our corporate group.
</p>
<p>
For this reason, we have established an independent, neutral, and confidential whistleblower system that
enables internal and external whistleblowers to submit reports, including anonymously. Through our
transparent complaint procedure, we offer the greatest possible protection, especially to the affected
persons, whistleblowers, and employees involved in investigating reported incidents.
</p>
<p>
Under this procedure, any actual or alleged violations of legal requirements, our Code of Conduct, or the
Code of Conduct for Business Partners may be reported. Human rights or environmental risks, as well as
breaches of duty along the entire supply chain of our group companies and in our own business operations,
can also be the subject of a report.
</p>
<p>
Standardized and swift processes, as well as confidential and professional handling of the reports by
internal experts, form the basis of this fair procedure. Discrimination or punishment of whistleblowers and
individuals responsible for handling complaints and reports will not be tolerated.
</p>
<h3>6.1 Purpose and legal basis of data processing</h3>
<p>The purpose of the processing is to manage the whistleblower system, which fulfills legal obligations under Art. 6 para. 1 lit. c GDPR.</p>
<h3>6.1 Purpose and Legal Basis of Data Processing</h3>
<p>
The purpose of processing personal data is to manage the whistleblower system, which also includes
identifying serious violations or potential violations of applicable law and other serious matters. The
processing of this data is necessary to comply with legal obligations imposed on us, in accordance with Art.
6 para. 1 sentence 1 lit. c) GDPR. This refers to the law that enhances the protection of whistleblowers
(Whistleblower Protection Act - HinSchG).
</p>
<p>
Additionally, the processing serves the legitimate interest of identifying serious violations or potential
violations of applicable law and other serious matters, in accordance with Art. 6 para. 1 sentence 1 lit. f)
GDPR.
</p>
<p>
Regarding the processing of special categories of personal data, this is necessary based on the
Whistleblower Protection Act for reasons of significant public interest, in accordance with Art. 9 para. 2
lit. g) GDPR. The processing of such special data is carried out in accordance with Art. 9 para. 2 lit. f)
GDPR in conjunction with Art. 6 para. 1 sentence 1 lit. f) GDPR to establish, exercise, or defend legal
claims.
</p>
<p>
Affected persons are those about whom a report is made. These can be employees, contractors, or other
individuals in a business relationship with the data processing entity. Furthermore, we process personal
data of the whistleblower if they provide their contact details or other identifying information.
Whistleblowers should be aware that we may process personal data about them during the handling of the
reported case.
</p>
<h3>6.2 Categories of personal data</h3>
<p>General personal data, data related to criminal convictions, and special categories of personal data may be processed.</p>
<h3>6.2 Categories of Personal Data</h3>
<p>
Reports can be made anonymously, in which case no personal data of the reporting person will be processed.
The type of personal data processed depends on the information provided. If the reporting person provides
personal data about another individual, including the reported individual or persons, that data will also be
processed. The following categories of personal data may be processed:
</p>
<ul>
<li>General personal data (e.g., first name, last name, address, email address, phone number, etc.)</li>
<li>Personal data related to criminal convictions or suspicions</li>
<li>Special categories of personal data (information about racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, health data, and information about a
person's sex life or sexual orientation)</li>
</ul>
<p>
We ask the reporting person to only provide information relevant to the case and to avoid reporting
sensitive information unless it is essential for handling the reported case.
</p>
<h3>6.3 Obligation to provide personal data</h3>
<p>Providing personal data is not mandatory, as anonymous reporting is also possible.</p>
<h3>6.3 Obligation to Provide Personal Data</h3>
<p>
It is not mandatory to provide the personal data mentioned in section 6.2, as anonymous reporting is also
possible. However, please note that we may be unable to process the report if no personal data is provided.
</p>
<h3>6.4 Recipients of personal data</h3>
<p>Reports are processed by the relevant department and forwarded to the appropriate divisions. Data is only shared when legally required or with the consent of the whistleblower.</p>
<h3>6.4 Recipients of Personal Data</h3>
<p>
Reports are logged in the system of the data processing entity as cases. After evaluation, these cases are
forwarded internally to the relevant departments, and follow-up actions may be initiated. If a report
involves one of the group companies of the data processing entity, the relevant cases are forwarded to the
responsible individuals at the respective company, who will then conduct an internal evaluation and take
action if necessary. When transferring personal data, the principle of data minimization is observed,
meaning only the data strictly necessary for handling the report is shared.
</p>
<p>
Personal data of the whistleblower will be shared with authorities when necessary to address serious
violations or issues, or to safeguard the right to defense of the affected persons. In other cases, personal
data of the whistleblower will only be shared with their consent. Data about persons other than the
whistleblower will only be shared in connection with the investigation of a reported case or to address
serious violations or issues.
</p>
<p>
The reporting platform is provided by the processor WhistleB Whistleblowing Centre AB, based in Stockholm,
Sweden. Further information about WhistleB and the corresponding terms of use can be found at:
<a
href="https://report.whistleb.com/content/documents/whistleb_terms_of_use.pdf">whistleb_terms_of_use.pdf</a>
</p>
<h3>6.5 Retention period</h3>
<p>Personal data that proves irrelevant will be anonymized or deleted. Archived reports are deleted after 3 years following the conclusion of the process and documentation obligations.</p>
<h3>6.5 Retention Period</h3>
<p>
Personal data that is found to be irrelevant to the processing of a reported case, as well as reports deemed
unfounded, will be immediately classified as "not relevant." In this case, the personal reference is removed
unless the report was anonymous from the outset. To meet the legally required documentation obligations and
deletion periods pursuant to § 11 para. 1 and para. 5 HinSchG, the report is initially archived without
personal reference but is not yet deleted. Archived cases serve solely to fulfill these documentation
obligations and can no longer be used for further processing.
</p>
<p>
Reports and personal data collected during the processing of a report form the basis for further handling
and are anonymized as soon as possible. However, if it is necessary to take follow-up actions pursuant to §§
3 para. 8 and 18 HinSchG, it may be necessary to deviate from anonymization, whether due to official orders
or to protect legal claims. In such cases, pseudonymization is generally sought, unless other directives
apply, such as a court order. Documentation is deleted three years after the conclusion of the process, but
it may be retained longer if required to meet the requirements of this law or other legal provisions, as
long as it remains necessary and appropriate.
</p>
</section>
</body>
</html>