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Privacy Policy

We are delighted that you have taken an interest in our company. Data protection is a top priority for the management of Wegweiser Research & Strategy GmbH and its subsidiary Wegweiser Media & Conferences GmbH (hereinafter referred to as the Wegweiser Group). In principle, it is possible to use the Wegweiser Group’s websites without providing any personal data. However, should a data subject wish to make use of specific services offered by our company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally seek the consent of the data subject.

The processing of personal data, such as a data subject’s name, address, email address or telephone number, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to the Wegweiser Group. Through this privacy policy, our company aims to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this privacy policy informs data subjects of their rights.

The WegweiserGroup, as the data controller, has implemented numerous technical and organisational measures to ensure the most comprehensive possible protection of the personal data processed via this website. Nevertheless, internet-based data transmissions may, in principle, be subject to security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, any data subject is free to provide us with personal data via alternative means, such as by telephone.

1. Definitions

The Wegweiser Group’s privacy policy is based on the terminology used by the European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use the following terms, amongst others:

a) personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as the ‘data subject’). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c) processing

Processing means any operation or set of operations which is carried out on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of restricting its future processing.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements of that natural person.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.

g) Controller

The controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of the Member States.

h) Data processor

A data processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

i) Recipient

A recipient is a natural or legal person, public authority, body or other organisation to whom personal data are disclosed, irrespective of whether they are a third party or not. However, public authorities which may receive personal data in the course of a specific investigation mandate under Union law or the law of the Member States shall not be regarded as recipients.

j) Third party

A third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.

k) Consent

Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes, by a statement or by a clear affirmative action, by which the data subject indicates that they consent to the processing of personal data relating to them.

2. Name and address of the data controller

The data controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions relating to data protection is:

Wegweiser GmbH Berlin Research & Strategy

Novalisstr. 7
10115 Berlin
Germany

Tel.: +493028488120
Email:oliver.lorenz@wegweiser.de
Website:www.wegweiser.de

3. Data Protection Officer

The Data Protection Officer at Wegweiser can be contacted as follows:

CONTEX CONSULTING MITTELSTANDS- UND MANAGEMENTBERATUNG GMBH
Olaf Scheuring
Leibnizstraße 9
68165 Mannheim

Email: ds@wegweiser.de

4. Cookies

The websites of the Wegweiser Group use cookies. Cookies are text files that are placed and stored on a computer system via a web browser.

Numerous websites and servers use cookies. Many cookies contain what is known as a cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that enables websites and servers to be assigned to the specific web browser in which the cookie was stored. This enables the websites and servers visited to distinguish the data subject’s individual browser from other web browsers that contain different cookies. A specific web browser can be recognised and identified via the unique cookie ID.

By using cookies, the Wegweiser Group can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Cookies enable us to optimise the information and content on our website to better suit the user’s needs. As already mentioned, cookies enable us to recognise users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to re-enter their login details every time they visit the website, as this is handled by the website and the cookie stored on the user’s computer system. Another example is the shopping basket cookie in an online shop. The online shop uses a cookie to remember the items a customer has placed in the virtual shopping basket.

The data subject may prevent our website from setting cookies at any time by adjusting the settings of their web browser accordingly, thereby permanently objecting to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via a web browser or other software programmes. This is possible in all common web browsers. If the data subject disables the setting of cookies in the web browser they are using, it may not be possible to make full use of all the functions of our website.

5. Collection of general data and information

The Wegweiser Group’s website collects a range of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the server’s log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (known as the referrer), (4) the sub-pages on our website accessed via an accessing system, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, the Wegweiser Group does not draw any conclusions about the data subject. Rather, this information is required in order to (1) deliver the content of our website correctly, (2) to optimise the content of our website and the advertising displayed on it, (3) to ensure the long-term functionality of our IT systems and the technology underpinning our website, and (4) to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. This data and information, collected anonymously, is therefore analysed by the Wegweiser Group both for statistical purposes and with the aim of enhancing data protection and data security within our organisation, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

6. Registration on our website

The data subject has the option of registering on the data controller’s website by providing personal data. The personal data transmitted to the data controller in this process is determined by the relevant input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the data controller and for its own purposes. The data controller may arrange for the data to be passed on to one or more data processors, such as a parcel delivery service, who will also use the personal data exclusively for internal purposes attributable to the data controller.

Furthermore, when registering on the data controller’s website, the IP address assigned by the data subject’s internet service provider (ISP), as well as the date and time of registration, are stored. This data is stored on the basis that this is the only way to prevent the misuse of our services, and, where necessary, to enable the investigation of criminal offences. In this respect, the storage of this data is necessary to safeguard the data controller. As a general rule, this data is not disclosed to third parties, unless there is a legal obligation to do so or the disclosure serves the purposes of criminal prosecution.

The registration of the data subject, involving the voluntary provision of personal data, enables the data controller to offer the data subject content or services which, by their very nature, can only be made available to registered users. Registered users are free to amend the personal data provided during registration at any time or to have it completely deleted from the data controller’s database.

The data controller shall, upon request, provide any data subject at any time with information regarding which personal data relating to that data subject is stored. Furthermore, the data controller shall rectify or erase personal data at the request or upon notification by the data subject, provided that this does not conflict with any statutory retention obligations. A Data Protection Officer named in this privacy policy and all employees of the data controller are available to the data subject as points of contact in this regard.

7. Subscription to our newsletter

On the Wegweiser Group’s website, users are given the opportunity to subscribe to our company’s newsletter. The personal data transmitted to the data controller when subscribing to the newsletter is determined by the input form used for this purpose.

The Wegweiser Group informs its customers and business partners at regular intervals about the company’s offers via a newsletter. In principle, the data subject can only receive our company’s newsletter if (1) the data subject has a valid email address and (2) the data subject registers to receive the newsletter. For legal reasons, a confirmation email is sent using the double opt-in procedure to the email address first provided by a data subject when registering for the newsletter. This confirmation email serves to verify whether the holder of the email address, as the data subject, has authorised the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) to the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to be able to trace any (potential) misuse of a data subject’s email address at a later date and therefore serves to provide legal protection for the data controller.

The personal data collected as part of a newsletter subscription is used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be informed by email where this is necessary for the operation of the newsletter service or for registration purposes, as might be the case with changes to the newsletter content or alterations to the technical conditions. No personal data collected as part of the newsletter service is passed on to third parties. The data subject may cancel their subscription to our newsletter at any time. Consent to the storage of personal data, which the data subject has given to us for the purpose of sending the newsletter, may be withdrawn at any time. A link for withdrawing consent is provided in every newsletter. Furthermore, it is possible to unsubscribe from the newsletter at any time directly on the data controller’s website or to notify the data controller of this in another way.

8. Newsletter Tracking

The newsletters from the Wegweiser Group contain so-called web beacons. A web beacon is a miniature graphic embedded in emails sent in HTML format, to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Using the embedded web beacon, the Wegweiser Group can determine whether and when an email has been opened by a data subject and which links contained in the email have been clicked by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and analysed by the data controller in order to optimise the distribution of the newsletter and to tailor the content of future newsletters even more closely to the data subject’s interests. This personal data is not disclosed to third parties. Data subjects are entitled at any time to withdraw the separate declaration of consent given in this regard via the double opt-in procedure. Following withdrawal, this personal data will be deleted by the data controller. The Wegweiser Group automatically interprets unsubscribing from the newsletter as a withdrawal of consent.

9. Contact details via the website

In accordance with legal requirements, the Wegweiser Group’s website contains information that enables you to contact our company quickly by electronic means and to communicate directly with us, which also includes a general electronic mail address (e-mail address). If a data subject contacts the data controller by email or via a contact form, the personal data provided by the data subject is automatically stored. Such personal data, provided voluntarily by a data subject to the data controller, is stored for the purposes of processing or contacting the data subject. This personal data will not be disclosed to third parties.

10. Comment function on the blog on the website

The Wegweiser Group offers users the opportunity to leave individual comments on specific blog posts via a blog located on the data controller’s website. A blog is a portal hosted on a website, usually accessible to the public, on which one or more people, known as bloggers or web bloggers, can post articles or record their thoughts in so-called blog posts. The blog posts can usually be commented on by third parties.

If a data subject leaves a comment on the blog published on this website, in addition to the comments left by the data subject, details of the time the comment was submitted and the username (pseudonym) are stored and published. Furthermore, the IP address assigned by the data subject’s Internet Service Provider (ISP) is also logged. This IP address is stored for security reasons and in the event that the data subject infringes the rights of third parties through a comment posted or publishes unlawful content. The storage of this personal data is therefore in the data controller’s own interest, so that the controller may, if necessary, be able to exonerate itself in the event of a legal infringement. This personal data collected is not disclosed to third parties, unless such disclosure is required by law or serves to defend the legal position of the controller.

11. Subscribing to comments on the blog on the website

Comments posted on the Wegweiser Group’s blog may, in principle, be subscribed to by third parties. In particular, a commenter may subscribe to comments posted in response to their own comment on a specific blog post.

If a data subject chooses the option to subscribe to comments, the data controller will send an automatic confirmation email to verify, via a double opt-in procedure, that the holder of the email address provided has indeed opted for this option. The option to subscribe to comments can be cancelled at any time.

12. Routine erasure and blocking of personal data

The data controller processes and stores the data subject’s personal data only for the period necessary to fulfil the purpose of storage, or insofar as this is provided for by the European legislator or another legislator in laws or regulations to which the data controller is subject, provided for.

If the purpose of storage ceases to apply or if a retention period prescribed by the European legislative and regulatory authorities or another competent legislator expires, the personal data shall be routinely blocked or deleted in accordance with statutory provisions.

13. Rights of the data subject

a) Right to confirmation

Every data subject has the right, as granted by the European legislative bodies, to request confirmation from the data controller as to whether personal data concerning them is being processed. Should a data subject wish to exercise this right to confirmation, they may contact our Data Protection Officer or another member of staff of the controller at any time.

b) Right of access

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to obtain from the controller, free of charge, information at any time regarding the personal data stored about them and a copy of that information. Furthermore, the European legislative and regulatory authorities have granted the data subject the right to access the following information:

  • the purposes of the processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular where recipients are in third countries or are international organisations
  • where possible, the envisaged period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
  • the existence of a right to rectification or erasure of personal data concerning them, or to restriction of processing by the controller, or a right to object to such processing
  • the existence of a right to lodge a complaint with a supervisory authority
  • where the personal data are not collected from the data subject: any available information as to the source of the data
  • the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the GDPR and — at least in such cases — meaningful information about the logic involved, as well as the significance and the intended consequences of such processing for the data subject

Furthermore, the data subject has the right to be informed as to whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject is also entitled to receive information about the appropriate safeguards in connection with the transfer.

Should a data subject wish to exercise this right of access, they may contact our Data Protection Officer or another member of staff of the controller at any time.

c) Right to rectification

Any data subject affected by the processing of personal data has the right, as granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to request the completion of incomplete personal data — including by means of a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may contact our Data Protection Officer or another member of staff of the data controller at any time.

d) Right to erasure (right to be forgotten)

Any data subject affected by the processing of personal data has the right, as granted by European legislation, to request that the controller erase personal data relating to them without undue delay, provided that one of the following grounds applies and insofar as the processing is not necessary:

  • The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
  • The data subject withdraws their consent on which the processing was based pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data has been processed unlawfully.
  • The erasure of the personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data was collected in relation to information society services offered in accordance with Article 8(1) of the GDPR.

If any of the above grounds apply and a data subject wishes to request the erasure of personal data stored by the Wegweiser Group, they may contact our Data Protection Officer or another member of staff of the controller at any time. The Data Protection Officer of the Wegweiser Group or another member of staff will ensure ensure that the request for erasure is complied with without delay.

If the personal data has been made public by the Wegweiser Group and our company, as the data controller, is obliged to erase the personal data in accordance with Article 17(1) of the GDPR, the WegweiserGroup shall, taking into account the available technology and the costs of implementation, take appropriate measures, including technical measures, to ensure that other data controllers processing the published personal data that the data subject has requested that these other data controllers delete all links to this personal data or any copies or replicas of this personal data, insofar as the processing is not necessary. The Data Protection Officer of the Wegweiser Group or another member of staff will take the necessary steps on a case-by-case basis.

e) Right to restriction of processing

Any data subject affected by the processing of personal data has the right, granted by the European legislator, to request that the controller restrict processing if one of the following conditions is met:

  • The data subject disputes the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful; the data subject objects to the erasure of the personal data and requests, instead, that the use of the personal data be restricted.
  • The controller no longer requires the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims.
  • The data subject has objected to the processing in accordance with Article 21(1) of the GDPR, and it has not yet been determined whether the controller’s legitimate grounds override those of the data subject.

If any of the above conditions are met and a data subject wishes to request the restriction of personal data stored by the Wegweiser Group, they may contact our Data Protection Officer or another member of staff of the data controller at any time. The Data Protection Officer of the Wegweiser Group or another member of staff will arrange for the processing to be restricted.

f) Right to data portability

Any data subject affected by the processing of personal data has the right, as granted by European legislation, to receive the personal data concerning them—which they have provided to a data controller—in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability under Article 20(1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, provided that this is technically feasible and does not adversely affect the rights and freedoms of others.

To exercise the right to data portability, the data subject may at any time contact the data protection officer appointed by the Wegweiser Group or another member of staff.

g) Right to object

Any data subject affected by the processing of personal data has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

In the event of an objection, the Wegweiser Group will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to establish, exercise or defence of legal claims.

Where the Wegweiser Group processes personal data for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purposes of such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to the Wegweiser Group’s processing for the purposes of direct marketing, the Wegweiser Group will no longer process the personal data for these purposes.

Furthermore, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them carried out by the Wegweiser Group for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact the Data Protection Officer of the Wegweiser Group or another member of staff directly. The data subject is also free to in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by means of automated procedures using technical specifications.

h) Automated individual decision-making, including profiling

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning them or similarly significantly affects them, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject, and that law provides for appropriate measures to safeguard the data subject’s rights and freedoms as well as their legitimate interests; or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is made with the data subject’s explicit consent, the Wegweiser Group shall take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

If the data subject wishes to exercise rights relating to automated decision-making, they may contact our Data Protection Officer or another member of staff of the controller at any time.

i) Right to withdraw consent to the processing of personal data

Any data subject affected by the processing of personal data has the right, granted by European legislation, to withdraw their consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact our Data Protection Officer or another member of staff of the data controller at any time.

14. Data protection in relation to job applications and the recruitment process

The data controller collects and processes the personal data of job applicants for the purpose of managing the recruitment process. Processing may also take place electronically. This is particularly the case where an applicant submits the relevant application documents electronically, for example by email or via a web form on the website. If the data controller enters into an employment contract with an applicant, the data provided will be stored for the purpose of managing the employment relationship in accordance with the relevant legal provisions. If the data controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the data controller preclude such deletion. Other legitimate interests in this context include, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

15. Legal basis for processing

Article 6(1)(a) of the GDPR serves as the legal basis for our company’s processing operations where we obtain consent for a specific processing purpose. Where the processing of personal data is necessary for the performance of a contract to which the data subject is a party – as is the case, for example, with processing operations required for the delivery of goods or the provision of other services or consideration – the processing is based on Article 6(1)(b) b of the GDPR. The same applies to processing operations necessary for the implementation of pre-contractual measures, such as in cases of enquiries regarding our products or services. Where our company is subject to a legal obligation which necessitates the processing of personal data, such as to fulfil tax obligations, the processing is based on Article 6(1)(c) of the GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and their name, age, health insurance details or other vital information subsequently had to be disclosed to a doctor, a hospital or other third parties. In such cases, the processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases, where the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not take precedence. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, the legislator took the view that a legitimate interest might be assumed if the data subject is a customer of the controller (Recital 47, second sentence, of the GDPR).

16. Legitimate interests in processing pursued by the controller or a third party

Where the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

17. Period for which personal data is stored

The criterion for the duration of the storage of personal data is the relevant statutory retention period. Once this period has expired, the relevant data is routinely deleted, provided it is no longer required for the performance of a contract or for entering into a contract.

18. Legal or contractual requirements regarding the provision of personal data; necessity for the conclusion of a contract; the data subject’s obligation to provide personal data; possible consequences of non-provision

We would like to inform you that the provision of personal data is, in some cases, required by law (e.g. tax regulations) or may also arise from contractual provisions (e.g. details of the contracting party). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we must subsequently process. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with them. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact our Data Protection Officer. Our Data Protection Officer will explain to the data subject, on a case-by-case basis, whether the provision of personal data is required by law or contract, or is necessary for the conclusion of the contract; whether there is an obligation to provide the personal data; and what the consequences of failing to provide the personal data would be.

19. Use of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.