Data Protection Statement
As of 29 November 2018
Thank you for visiting our website www.drooms.com and for your interest in our company and our offers.
We collect, use and store your personal data only within the context of the provisions of the GDPR. Below, we inform you about the type, scale and purpose of data collection and use.
1. Controller for processing of your personal data
The controllers within the meaning of the EU General Data Protection Regulation ("GDPR") are Drooms GmbH and Drooms AG (hereinafter: "we").
Eschersheimer Landstr. 6, 60322 Frankfurt am Main, Germany
Phone: +49 69 4786400
Headquarter: Frankfurt am Main
Managing director: Alexandre Grellier
Industriestrasse 13 c, 6003 Zug, Switzerland
Phone: +41 41 7674410
Headquarter: Zug (Switzerland)
Managing Directors: Alexandre Grellier, Jan Hoffmeister
Vertreter für die Drooms AG i.S.d. Art. 27 DSGVO:
Drooms GmbH, Eschersheimer Landstr. 6, 60322 Frankfurt am Main, Deutschland
2. Collection and recording of personal data as well as the type and purpose of their use
a) When you visit our Drooms website
Any access to our website and any call of a file stored on this website will be logged. The following data are recorded without any action on your end and stored until automatic erasure:
- internet protocol address of the requesting computer, as well as device identifier or individual device ID and device type,
- name of the filed called up and data volume transferred, as well as date and time of the call,
- a report on successful calling up,
- requesting domain,
- description of the type of internet browser used and the operating system of your end device, as well as the name of your access provider,
- location data, including location data of your mobile unit. Please note that you can control or deactivate use of location services in the setting menu of most mobile devices.
Our legitimate interest according to sect. 6 para. 1 s. 1 (f) GDPR on collection of the files is based on the following purposes:
- ensuring a smooth connection setup and comfortable use of the website,
- evaluation of system security and stability, as well as
- for further administrative and statistical purposes.
In no case shall we use any collected personal data for the purpose of drawing conclusions about your person. Further personal data are only recorded if you freely provide additional information while using the website as described below.
b) When using our contact form
We offer you the option of contacting us using a form provided on the website. You need to enter at least a valid email address and your (first/last) name, as well as the name of the company and registered office to let us know who the query comes from and in order to enable us to reply to it. Additional information can be provided freely in the input screen used for this.
Processing activities for the purpose of contacting us shall take place according to sect. 6 para. 1 s. 1 (a) GDPR based on your freely given consent.
The personal data are not passed on to any third parties.
Alternatively, you may contact us via the email addresses listed on the contact request website or the email address provided for support, firstname.lastname@example.org, if you have any general questions, issues with setup and use, as well as software error messages. In this case, the personal data of the user transmitted in the email will be stored for the purpose of processing the request based on sect. 6 para. 1 s. 1 (b) GDPR.
The personal data collected by us for use of the contact form and the personal data indicated by you when you use our contact email addresses will be deleted automatically after completion of the request filed by you, provided that the contact request did not lead to any contractual or pre-contractual relationship or such a relationship was already present, so that processing is not required on the legal basis of sect. 6 para. 1 s. 1 (b) GDPR.
c) When downloading the Drooms Whitepapers and sending requests concerning the software demo
On our website, we offer you the option of a free download of the Drooms Whitepapers and free online presentation of our Drooms demo data room by phone and internet.
However, concluding this offered service requires indication of some data (such as name, email address, etc.) without which we would be unable to implement the desired information. We will inform you within the context of the input process when provision of personal data is required for the respective service ("mandatory field").
Processing takes place on the legal basis of sect. 6 para. 1 s. 1 (a) GDPR, based on your freely given consent. Any personal data collected within the context of this process will be deleted automatically after the requested service is rendered, provided that further processing is not required for any other purposes, such as based on sect. 6 para. 1 s. 1 (b) GDPR, in order to perform a contract or pre-contractual measures.
d) When concluding a contract via our online shop
On our website https://shop.drooms.com/home/, we collect the following personal data when concluding a contract via our Drooms online shop or when you register as user of a data room via our Drooms online shop:
- Data that identify you in person, such as your email address and possibly name,
- IP address,
- any data that identify your company, such as company name, address, communication data (email address, phone number), VAT ID or tax ID,
- any information on your method of payment,
- other personal data, that we are required or permitted to collect and process by law and that we need for your authentication, identification or to verify the data collected by us.
The data named are processed for processing the contractual relationship. The data will be processed based on sect. 6 para. 1 (b) GDPR. The storage period is limited to the contractual purpose and, if present, statutory and contractual archiving obligations.
e) When using payment service providers
We also cooperate with payment service providers charged by us with the payment for contracts concluded with us subject to fees. We will pass on your payment data to the payment service provider charged within the context of payment processing – with the specific purpose of the payment – if this is required for processing of the payment. The legal basis for forwarding of the data is sect. 6 para. 1 (a) GDPR.
f) When registering for our newsletter
You may sign up for our Drooms newsletter by way of double opt-in in various locations of our website and thus freely give your consent to this. We refer to the declaration of consent and this data protection statement.
We will use your email address, your (first/last) name and the form of address (Mr or Ms/Mrs) that you transmitted in the input screen on our website for this purpose when subscribing to the newsletter, on the legal basis of sect. 6 para. 1 s. 1 (a) GDPR in order to regularly send you our newsletter.
When you sign up for the newsletter, we will further store your internet protocol address and the date and time of the registration. Collection of these data takes place to legally secure the controller for processing.
The newsletter of Drooms AG and Drooms GmbH is sent at regular intervals (approx. once per month) by email and informs about news, functions and updates concerning any Drooms products and services, business activities and events of the Drooms group and events in the economic, social or legal context with the business environment of Drooms companies, as well as the option of participating in surveys for customer satisfaction.
Unsubscription is possible at any time, e.g. using the link at the end of a newsletter. Alternatively, you can also send your unsubscription request to email@example.com by email at any time (best using the subject: "Unsubscription from Newsletter").
Data entered to set up your subscription will be deleted in case of unsubscription. If data have been submitted to us for any other purposes and in any other location, they will continue to remain with us.
The personal data collected within the context of registration for the newsletter will only be used to send out our newsletter.
We use external processors for sending out the newsletter with whom we have concluded a contract on processing for complete performance of the statutory data protection specifications.
Newsletter-Tracking: The Drooms newsletters contain counting pixels that permit statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded counting pixel. Drooms will be able to see whether and when an email was opened by a data subject and which links in the email the data subject called up. The legal basis for this is sect. 6 para. 1 s. 1 (f) GDPR. Such personal data collected in the counting pixels contained in the newsletters are stored by the controller for processing and evaluated in order to optimise newsletter dispatch and to adjust the contents of future newsletters to the interests of the data subject even better in future. These personal data will not be passed on to any third parties. Drooms will automatically consider unsubscription from the newsletter to be a revocation.
g) Use of a live support system
On this website, your indicated chat name and chat contents given will be collected and stored for the course of the chat for the purpose of operating a live chat system to answer live requests. The chat and your indicated chat name will be stored only in the RAM (Random-Access Memory) and deleted at once when we or you have ended the chat conversation, but at the latest 2 hours after the last message in the chat history. Personal data such as your name, email address, etc., will only be used when they are provided freely. Cookies are used for operation of the chat function. The cookies permit recognition of the web browser of the page visitor, in order to ensure differentiation of the individual users of the chat function of our website.
If the information collected in this manner refers to a person, further processing will take place according to sect. 6 para. 1 s. 1 (b) to perform or prepare a contractual relationship or according to sect. 6 para. 1 s. 1 (f) based on our legitimate interest in effective customer support and statistical analysis of the user behaviour for optimisation purposes.
In order to avoid storage of cookies, you may set your web browser so that no cookies can be stored on your computer anymore, or that cookies already stored will be deleted. Deactivation of all cookies may, however, render you subsequently unable to use the chat function on our website.
3. Processing and passing on of personal data
Your data will not be transferred to any third parties for any other than the purposes listed below. We shall only pass on your data to third parties if:
- you have explicitly consented to this (sect. 6 para. 1 s. 1 (a) GDPR),
- this is required for processing of contractual relationships with you (sect. 6 para. 1 (b) GDPR),
- there is a legal obligation to pass them on (sect. 6 para. 1 (c) GDPR),
- forwarding is required for assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding protection-worthy interest in your data not being passed on (sect. 6 para. 1 s. 1 (f) GDPR).
In such cases, the scope of the data transmitted is limited to the required minimum, however.
Our provisions on data protection are in harmony with the applicable provisions on data protection and the data will generally only be processed within Member States of the European Union and/or Switzerland. Switzerland is viewed as a third country that ensures an appropriate level of the protection of personal data by the European Commission. In this respect, the European Commission has no reservations concerning data transmission to Switzerland and transmission is possible based on sect. 44 GDPR. If your personal data are transmitted to any third countries, this shall only be done if a suitable safeguard has been given according to sect. 46 para. 2 (c) GDPR. If this is not available, the data shall be transmitted based on the exception according to sect. 49 GDPR.
4. Rights of data subjects
Right to confirmation and information: Upon request, we will gladly inform you of whether any and, if so, which personal data concerning you are stored by us (sect. 15 GDPR), in particular concerning the processing purposes, category of personal data, categories of recipients to whom your data have been or are disclosed, the planned storage duration, the existence of a right to correction, erasure, restriction of processing or objection, existence of a right to complaint, origin of your data if they were not collected at our site, and the existence of automated decision-making, including profiling.
Right to rectification: You also have the right to have any inaccurately collected personal data rectified, or incompletely collected data completed (sect. 16 GDPR).
Right to restriction of processing: Furthermore, you have the right to demand that we restrict processing of your data, provided that the statutory prerequisites for this are present (sect. 18 GDPR).
Right to data portability: You have the right to demand to receive the personal data concerning you in a structured, common and machine-readable format or to demand their transfer to another controller (sect. 20 GDPR).
Right to erasure (right to be forgotten): You also have the "right to be forgotten", i.e. you may demand that we erase your personal data if the statutory provisions for this are met (sect. 17 GDPR).
Independently of this, your personal data will be deleted by us automatically if the purpose of data collection is lost or if data have been processed illegally.
Right to revocation of the declaration of consent under data protection law: According to sect. 7 para. 3 GDPR in conjunction with sect. 17 para. 1 (b) GDPR, you have the right to revoke your consent given to us under sect. 6 para. 1 s. 1 (a) GDPR at any time. This has the consequence that we may no longer continue the processing activities that were based on this consent in future.
Right to objection: You also have the right to object to processing of your personal data at any time if a right to object is stipulated by law. In case of effective revocation, your personal data will also be deleted by us automatically (sect. 21 GDPR).
If you want to exercise your revocation right or right to object, simply send an email to: firstname.lastname@example.org.
In case of violations of the data-protection provisions, you have the right, according to sect. 77 GDPR, to lodge a complaint with the relevant supervisory authority.
The supervisory authority relevant for Drooms is:
The Hessian data protection officer
PO box 3163
5. Data erasure and duration of storage
Erasure, blocking or restriction of processing of the stored personal data shall take place if the user of the website revokes the consent given to storage, if knowledge of the personal data is no longer necessary to meet the purpose pursued by storage and erasure is not opposed by any statutory archiving periods (e.g. archiving periods under commercial or tax law) or if storage is inadmissible for any other legal reasons (section 18 GDPR).
Data for settlement purposes and accounting purposes shall not be affected by a demand for erasure.
The cookie is used to store information that results from the respective context of the specifically used end device. However, this does not mean that we directly gain knowledge of your identity.
The session cookies will be deleted automatically after you leave our website. Furthermore, we also use temporary cookies to optimise user friendliness, which are stored on your end device for a certain specified period. When you visit our site again in order to use our services, it will be automatically recognised that you have visited us before and which input and settings you have made so that you will not have to enter them again.
The personal data processed by cookies are required for the purpose of maintaining our legitimate interests and those of third parties according to sect. 6 para. 1 s. 1 (f) GDPR. Most browsers accept cookies automatically. If you do not want us to recognise information concerning your computer, please set your web browser so that it will delete cookies from your computer hard disc, block all cookies or warn you before storing a cookie. You can find out how to delete or block cookies in the help and support area of your web browser. There, you will find instructions on finding the file or directory in which the cookies are stored.
In any case, please note that the complete deactivation of cookies may render you unable to use all functions of our website in full.
If you leave our website using a link or by clicking any banner ads and you reach any external pages this way, it is possible that the addressee of the clicked target page will also place cookies. We are not legally responsible for these cookies. For use of such cookies and the information stored on them by our advertising partners, please see their data protection statements.
7. Online marketing / Analysis measures
We use online marketing measures and tracking tools on our website in order to analyse behaviour of the users on our website. With this statistical recording, we want to design our website in a demand-oriented manner and adjust it continually to you as our user, and to optimise use. Use of the online marketing and tracking measures we use takes place based on sect. 6 para. 1 s. 1 (f) GDPR, § 15 para. 3 TMG. Our interests named are legitimate within the meaning of the above provision.
a) Google Analytics
For the purpose of demand-oriented design and continuous optimisation of our websites, we use Google Analytics, a web analysis service of Google Inc. (https://www.google.de/intl/en/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter: Google). In this context, pseudonymised user profiles are compiled and cookies are used (also see item 5). The information generated by the cookie concerning your use of this website, such as browser type/version, operating system used, referrer URL (the page visited last), host name of the accessing computer (protocol address) and the time of the server query will be transmitted to a server of Google in the USA and stored there. The information is used in order to evaluate use of the website, to compile reports on the website activities and in order to provide further services connected to use of the website and use of the internet for the purpose of market research and demand-oriented design of these internet websites. These purposes also constitute our justified interest in processing activities. The legal basis for use of Google Analytics is § 15 para. 3 TMG in conjunction with sect. 6 para. 1 (f) GDPR.
This information may also be transferred to third parties if this is required by law or as far as third parties process these personal data based on a contract. In no case will your internet protocol address be combined with any other personal data of Google. The internet protocol addresses are rendered anonymous so that they cannot be assigned (IP masking).
The data sent by us and linked to cookies, user IDs (e.g. User-ID) or advertising IDs are automatically deleted after 14 months. Erasure of data the archiving period of which has expired shall take place automatically once per month.
For more detailed information on the usage conditions and the data protection of Google Analytics, see https://www.google.com/analytics/terms/us.html .
You may prevent installation and storage of the cookies by making the corresponding settings in your browser software; however, note that you may be unable to fully use all functions of the website in such a case.
You may furthermore prevent recording of the data generated by the cookie and referring to your use of the website (incl. your Internet Protocol address) and processing of these personal data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
As an alternative to the browser add-on, in particular for browsers on mobile end devices, you can prevent recording by Google Analytics by clicking this link. An opt-out cookie is set that will prevent the future recording of your personal data when visiting this website. The opt-out cookie will only be valid for this browser and only for our website; it is stored on your device. If you delete the cookies in this browser, you need to set the opt-out cookie again.
b) Google Adwords / Conversion Tracking
We also use the online advertising program "Google AdWords" and conversion tracking within the context of Google AdWords. Google Conversion Tracking is an analysis service provider by Google. If you click an ad placed by Google, a cookie for conversion tracking will be placed on your end device. These cookies will be rendered invalid after 30 days, contain no personal data and are therefore not used to identify you in person. If you visit specific pages of our website before the cookie has expired, Google and we will be able to tell that you have clicked the ad and were forwarded to this site. Every Google AdWords client will receive a different cookie. Therefore, it is not possible for cookies to be tracked across websites of different AdWords customers.
The information collected by the conversion cookie is used to compile conversion statistics for AdWords clients who have decided to use conversion tracking. This way, the clients learn the total number of users who have clicked their ad and have been forwarded to a site supplied with a conversion tracking tag. However, they will not receive any information with which the users can be identified in person. These purposes also constitute our justified interest in processing activities. The legal basis for use of Google AdWords / Conversion Tracking is § 15 para. 3 TMG in conjunction with sect. 6 para. 1 (f) GDPR.
If you do not want to participate in tracking, you may object to this use by preventing installation of the cookies from the domain "googleadservices.com" by setting your browser software accordingly (deactivation option). You will then not be included in the conversion tracking statistics. Further information and the data protection statement of Google can be viewed at: http://www.google.com/policies/technologies/ads/, https://policies.google.com/privacy.
c) Google Remarketing
d) Google Tag Manager
This website uses the Google Tag Manager. The Google Tag Manager makes it possible to manage website tags via an interface. The Tool Tag Manager itself (that implements the tag) is a cookie-free domain that does not collect any personal data. The tool triggers other tags that in turn may record data. Google Tag Manager does not access these data. In case of deactivation on domain or cookie level, this remains present for all tracking tags that are implemented with Google Tag Manager. For more information on the Google Tag Manager, see: https://www.google.com/analytics/tag-manager/use-policy/.
e) Zoho SalesIQ
8. Social Media Plugins
We use social media plugins of the following social networks on our website.
a) Google Plus
Our website uses the "G+1" button of the social network Google+ as provided by Google. The Google+ plugin can be recognised by the sign "Google+" or the addition "G+1". When you click the plugin, a connection with the servers of Google Plus will be established. The content of the plug-in will be directly transmitted to your browser by Google and integrated into the website by it. This way, the information that you have visited our website will be forwarded to Google+.
Note that we as providers of our website do not have any knowledge of the content of the transmitted personal data and their use by Google+. According to Google, no personal data will be collected without clicking the plugin. While you are logged in to the Google+ account, data, including your internet protocol address, will be collected and processed. If you want to prevent this kind of data transmission, you need to log out of your Google+ account before you visit our website.
For the purpose and scale of data collection and further processing and use of the personal data by Google+ as well as your rights in this regard and setting options to protect your privacy, see the data privacy notes of Google+: https://developers.google.com/+/web/buttons-policy.
Our website uses social plugins ("Plugins") of the social network facebook.com, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA ("Facebook"). If you open our website with the plugin, it will directly connect to the servers of Facebook via your browser. This way, information that you have called up the page will be transmitted to Facebook. If you are logged in with your Facebook account, clicking of the plugin may directly assign the visit to our website to your profile. Even if you do not have any profile, it cannot be excluded that your IP address will be stored by Facebook. For the purpose and scale of data collection and further processing and use of the personal data by Facebook as well as your rights in this regard and setting options to protect your privacy, see the data privacy notes (https://www.facebook.com/about/privacy/) of Facebook.
If you are a member of Facebook and do not want Facebook to collect any data concerning you through our website and link them to your stored membership data, you need to log out of Facebook before you visit our website and delete the corresponding Facebook cookies. It is also possible to block Facebook social plugins with add-ons for your browser, such as the "Facebook Blocker".
Our website also integrates functions of the service Twitter. These functions are offered by Twitter Inc., Twitter, Inc. 1355 Market St., Suite 900, San Francisco, CA 94103, USA. Using Twitter and the function "Re-Tweet" will link the website visited by you to your Twitter account and disclose it to other users. Data will also be transmitted to Twitter in the scope of this. Note that we as providers of our website do not have any knowledge of the content of the transmitted personal data and their use by Twitter. For more information on this, see the data privacy statement of Twitter, at https://twitter.com/privacy. You may change your data protection settings at Twitter in your account settings at http://twitter.com/account/settings.
In order to prevent Twitter from collecting the data when you visit our website, log out of Twitter before the visit. In order to prevent general access of Twitter to your data via websites, you can exclude Twitter social plugins with an add-on for your browser (e.g. "Twitter-Blocker", https://disconnect.me).
Our website uses plugins of the social network XING (XING AG, Dammtorstraße 30, D-20354 Hamburg, Germany). When you click the XING button on our website, your browser will briefly connect to the servers of XING with which the "XING Share-Button" functions (in particular calculation/display of the counter value) are rendered, in order to observe your visitor behaviour concerning the "XING Share Button" if necessary. Note that we as providers of our website do not have any knowledge of the content of the actually transmitted personal data and their use by XING. For more information and the latest version of the data protection statement for the "XING Share Button", see: https://dev.xing.com/plugins/share_button/privacy_policy
Our website integrates plugins of the social network LinkedIn. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. When you click the LinkedIn button, a connection with the servers of LinkedIn will be established. The content of the plug-in will be directly transmitted to your browser by LinkedIn and integrated into the website by it. This way, the information that you have visited our website will be forwarded to LinkedIn. If you are logged in with your LinkedIn account, clicking of the LinkedIn button may directly assign the visit to our website to your profile. Even if you do not have any profile, it cannot be excluded that your IP address will be stored by LinkedIn.
Note that we as providers of our website do not have any knowledge of the content of the transmitted personal data and their use by LinkedIn. For more information on the data protection statement of LinkedIn, see https://www.linkedin.com/legal/privacy-policy.
Our website uses plugins of YouTube (belonging to Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). If you open our website, it will directly connect to the servers of YouTube via your browser. This way, information that you have called up the website will be transmitted to YouTube. If you are logged in with your YouTube account, your visit to our website and any interaction you perform in connection with the plugin (e.g. clicking the YouTube button) can be assigned to your YouTube profile and stored by YouTube – even if you do not have any YouTube profile, it cannot be excluded that YouTube will store your IP address. Please also observe the YouTube data protection directive: https://policies.google.com/privacy?hl=en.
In order to prevent YouTube from collecting the data when you visit our website, log out of YouTube before the visit. In order to prevent general access of YouTube to your data via websites, you can exclude YouTube social plugins with an add-on for your browser (e.g. https://www.youtube.com/user/disconnecters).
9. Data privacy in case of applications and the application procedure
10. Daten security
We strive to take all technical and organisational security measures in order to store your personal data so that they are not accessible to any third parties or the public. If you want to contact us by email, please note that confidentiality of the information transmitted cannot be fully ensured on this communication path. We therefore recommend that you only provide us with confidential information by mail.
11. Topicality and changes of this data protection statement
This data privacy statement is currently valid as of May 2018. Further development of our website and offers through it or changed statutory or authority specifications may require changes to this data privacy statement. You may call up and print the respective current data privacy statement at any time on the website at https://drooms.com/en/privacy-policy.
12. Name and contact details of the data protection officer
The data protection officer of Drooms GmbH:
Data Screen Consult
Gesellschaft für Unternehmensberatung mbH
Mr. Arnd Harnischmacher
61348 Bad Homburg v.d.H.