To comply with your information obligations under Art. 13 GDPR, you must inform users about the use of Perspective in your privacy policy.
To make this easier, we provide a template that you can adapt to your specific use case and add to your privacy policy.
Disclaimer
Although we do our best to provide useful information to help you draft your privacy policy, our template cannot replace professional legal advice. You are responsible for ensuring that your privacy policy complies with the applicable legal requirements. Data protection law is a complex field whose legal foundations are frequently updated.
We therefore make no warranties or representations regarding the following information. The contents of this article are not to be understood as legal advice and make no claim to be up-to-date or complete. Please note in particular that, depending on your jurisdiction, additional measures may be required in some cases to reflect the use of Perspective in your privacy policy in a legally compliant manner.
General Information
Our clause consists of two parts:
Provision of the online service & contact and inquiry management.
This is because two data processing operations take place with regard to your visitors' data: on the one hand, Perspective processes data that is necessary for the provision of the funnel and is temporarily stored on our servers; on the other hand, Perspective processes data that the user provides to you as part of an inquiry through your funnel.
As of 01.07.2024
Clause for your Privacy Policy
Provision of the Online Service
For the provision of our online service, we use an external service provider: Perspective Software GmbH, Mailbox 659770, D-96035 Bamberg, Germany (hereinafter "Perspective"). Perspective itself stores your data exclusively on European servers. However, there is a possibility that your data may be accessible to facilities in the United States of America, as Perspective uses sub-processors based in the USA. Since July 2023, the EU-US Data Privacy Framework (DPF) adopted by the EU Commission applies as the legal basis for these potential transfers. Perspective's sub-processors thereby commit to a high level of data protection. Nevertheless, there remains a risk that your data may be processed by US authorities for monitoring and surveillance purposes. Therefore, for such data transfers to the United States, Perspective offers additional measures and guarantees in accordance with the requirements of the GDPR to ensure an adequate level of protection — for example, by concluding standard contractual clauses between Perspective and the sub-processors.
I. Description and Scope of Data Processing
Perspective processes your data on our behalf so that we can provide you with our online services. For this purpose, your IP address is automatically transmitted to Perspective in order to deliver the content and functions of our online services to your browser or device.
The following data may be collected:
Information about the browser type and version used
The operating system of your computer
The Internet service provider you are using
The IP address of your device
Date and time of your access to the funnel
Websites from which you accessed our website ("referrer")
II. Legal Basis for Data Processing
Perspective stores the data referred to under I. in so-called log files. This is done to ensure:
the smooth establishment of the website connection,
comfortable use of our website,
the evaluation of system security and stability, and
for further administrative purposes.
The temporary storage of the IP address by the system is also necessary to enable the website to be delivered to your computer. For this, your computer's IP address must remain stored for the duration of the session.
These purposes also constitute our legitimate interest in the data processing. The legal basis for the data processing is therefore Art. 6 (1) sentence 1 lit. f GDPR.
III. Duration of Processing
The personal data processed by Perspective will be deleted as soon as it is no longer required to achieve the purpose for which it was collected:
In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
In the case of the storage of the IP address in log files, this is the case after no more than 7 days.
IV. Data Subject Rights
You have the right at any time to obtain free information about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction, blocking, or deletion of this data. For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time at the address given in the imprint. Furthermore, in the event of violations of the GDPR, you have the right to lodge a complaint with the competent supervisory authority.
Because the data processing is carried out on the basis of Art. 6 (1) sentence 1 lit. f GDPR, you have the right to object at any time to the processing of your personal data on grounds arising from your particular situation. If you object, we will no longer process your personal data concerned, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims (objection pursuant to Art. 21 (1) GDPR). Since the collection of data for the provision of the website and the storage of data in log files is mandatory for the operation of our website, there will usually be no possibility of objection for you.
In addition, you have the right to demand the restriction of the processing of your personal data under certain circumstances. The right to restriction of processing exists in the following cases:
If you contest the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to demand the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to demand the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection in accordance with Art. 21 (1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may — apart from being stored — only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.
Contact and Inquiry Management
For the provision of contact, inquiry, or application forms, we use an external service provider: Perspective Software GmbH, Mailbox 659770, D-96035 Bamberg, Germany (hereinafter "Perspective"). Perspective itself stores your data exclusively on European servers. However, there is a possibility that your data may be accessible to facilities in the United States of America, as Perspective uses sub-processors based in the USA. Since July 2023, the EU-US Data Privacy Framework (DPF) adopted by the EU Commission applies as the legal basis for these potential transfers. Perspective's sub-processors thereby commit to a high level of data protection. Nevertheless, there remains a risk that your data may be processed by US authorities for monitoring and surveillance purposes. Therefore, for such data transfers to the United States, Perspective offers additional measures and guarantees in accordance with the requirements of the GDPR to ensure an adequate level of protection — for example, by concluding standard contractual clauses between Perspective and the sub-processors.
I. Description and Scope of Data Processing
When using Perspective's contact, inquiry, or application forms, the following data is transmitted to Perspective's servers:
Date and time of access
Websites from which you accessed our website ("referrer")
Context information (e.g., button clicks on the pages, selections made on the pages)
Contents of all completed text fields (e.g., contact information such as your name or address, or other personal data, depending on the question depicted in the specific text field)
Files uploaded by you
II. Purpose and Legal Basis of Data Processing
The purpose of this data processing is to ensure the communication you have initiated.
The processing of your data from contact, inquiry, or application forms is therefore initially based on your consent. The legal basis is Art. 6 (1) sentence 1 lit. a GDPR. If a contract initiation takes place via an inquiry form, the legal basis is also Art. 6 (1) sentence 1 lit. b GDPR. The legal basis for the processing of data in an application form may, in addition to Art. 6 (1) sentence 1 lit. f GDPR, also be Art. 88 GDPR in conjunction with § 26 BDSG (German Federal Data Protection Act).
III. Duration of Processing
Your personal data will be retained for as long as it is necessary to fulfill the purpose of processing or until you withdraw your consent. Excluded from this principle is data that Perspective must retain due to legal obligations. This includes, for example, retention obligations under commercial and tax law. These retention periods currently amount to up to ten years. For application data, if no employment relationship is established, your data will be deleted no later than six months after the end of the application process, unless you have expressly consented to longer storage.
IV. Data Subject Rights
You have the right at any time to obtain free information about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction, blocking, or deletion of this data. For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time at the address given in the imprint. Furthermore, in the event of violations of the GDPR, you have the right to lodge a complaint with the competent supervisory authority.
You can revoke your consent to data processing at any time by informal communication to us (e.g., by email). The revocation does not affect the lawfulness of the processing carried out on the basis of the consent until revocation.
In addition, you have the right to demand the restriction of the processing of your personal data under certain circumstances. The right to restriction of processing exists in the following cases:
If you contest the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to demand the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to demand the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection in accordance with Art. 21 (1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may — apart from being stored — only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.