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Privacy Policy

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Privacy Policy

OC fulfillmentGmbH

Domstraße20, 50668 Cologne

Office:Schanzenstraße 6-20, Kupferwerk 2.20, 51063 Cologne

hereinafter referred to as “fulfillmenttools” or “we”,

operatesthe website www.fulfillmenttools.com.

This information provides you with an overview of how your personal data is processed when you visit the website fulfillmenttools.com. We inform you about what data we collect from you and how we use it. We also explain your rights under applicable data protection law and let you know who to contact if youhave any questions.
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1. Data Controller

The data controller under data protection law is: OC fulfillment GmbH; Domstraße 20,50668 Cologne; Office: Schanzenstraße 6-20, Kupferwerk 2.20, 51063 Cologne
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2. Data Protection Officer

The designated contact person for data protection matters (e.g., for inquiries ofany kind or to exercise data subject rights) at the data controller is:

OC fulfillment GmbH

Data Protection Officer

Domstraße20

50668 Cologne

Email: dataprotection(@)fulfillmenttools.com
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3.Processing of Personal Data

We process your personal data when you visit the fulfillmenttools.com website, provide us with information via a contact form on our website, request access torestricted information, or contact us in any other way.

The following data or categories of data may be collected in this process:

• Serverlog file data recorded when the website is accessed: e.g., information aboutthe browser type and version used, the page accessed, the page from which thewebsite was accessed, the amount of data transmitted, the user’s operatingsystem, Internet service provider, and IP address, as well as the date and timeof access

• Data you provide when contacting us (including title, first name, last name, emailaddress, phone number, company, position, address, date of registration, dateof last login)

• Data collected when using our website through the use of cookies, web beacons,advertising IDs, and other unique identifiers and technologies (e.g., deviceID, operating system, pages visited, links clicked, services used, time of use)

• Data you provide when registering for a 30-day free trial (first name, last name,company, job title, business email, phone number)

• Data you provide when subscribing to the newsletter (email address)

• Data we need to verify your consent to receive the newsletter (IP address andtimestamp of the newsletter subscription request and of the click on the linkin the confirmation email, as well as the consent statements you have provided)

• Data we receive when you read the newsletter or product recommendations sent viaemail (opening the email, clicks on links contained in the email, data aboutthe device used, location data based on the IP address, email addressavailability, performing an action on the website after clicking on an offer)

• Data you provide to us when you apply for an advertised position or submit aspeculative application (personal data, educational background, professionalhistory, cover letter, resume, portrait photo, references)

• Data you provide on career platforms such as Xing and LinkedIn and that we collectas part of the recruitment process (first and last name as provided on theplatform, your current position, date we contacted you, your response to ourinquiry)
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4. Provisionof Data

Providing your data is not required by law. However, some of the data listed is necessaryto use the website’s features. Providing other data is voluntary, but may berequired to use certain features. When you enter data, we will inform you ifthe provision of that data is required for the respective service or function.This data is marked as required fields. If you do not provide the requireddata, the relevant service or function cannot be provided.
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5. Scope, Purpose, and Legal Basis of Data Processing

5.1 Web Server Logs

When you visit our websites, we process the connection data of the requestingcomputer—including the IP address, the pages you visit on our site, the dateand duration of your visit, the identification data of the browser andoperating system type used, and the website from which you visit us—as astandard measure to ensure the security of our IT systems. The legal basis for the described data processing is Art. 6(1)(f) GDPR (balancing of interests, based on fulfillmenttols’ interest in ensuring the security of IT systems).

5.2. Processing for Advertising Purposes

5.2.1 Newsletter

On ourwebsite, you have the option to subscribe to our newsletter. The newsletterprovides information about fulfillmenttools as a company and our currentproducts and services. After submitting the registration form, you will receivea confirmation email. Your subscription will not take effect until you haveclicked the link in the confirmation email. You can unsubscribe from thenewsletter at any time. To do so, simply use the unsubscribe link at the bottomof each email. The legal basis for the data processing described is Art.6(1)(a) GDPR (consent).

5.2.2 Contact (Form)

You cancontact us via the contact form, by email, by mail, or by phone. We processyour data to respond to your inquiry and, if necessary, to send you requestedinformational materials. Your data may be transferred to the departmentresponsible for your inquiry. The legal basis for the data processing describedis Article 6(1)(b) and (f) of the GDPR (pre-contractual measures, performanceof a contract, or balancing of interests, based on fulfillmenttools’ interestin responding to inquiries).

5.2.3 Contests

From timeto time, you may have the opportunity to participate in contests on our websitethat are advertised through our website. To conduct a contest, we process yourdata (name, email address, mailing address, and, if necessary, other datarequired for the contest). We process your data to verify eligibility, determine and notify the winner, send the prize, and, if applicable, publishthe winner’s name. The legal basis for the described data processing is Article6(1)(b) of the GDPR (conducting the contest).

5.2.4 Recruiting and Job Applications

5.2.4.1 Recruiting

We processyour personal data if we assess you as a suitable candidate for a specific position on the Xing or LinkedIn platform. For this purpose, you will be contacted by our employees via the platform. We record your name and the datewe contacted you internally. If an application process ensues, the provisionsin the following section “Job Application” apply. If you are not interested inthe position offered, we note this internally so as not to contact you again.This information is deleted after 2 years.

The processing is based on the legal grounds of Art. 6(1)(f) GDPR and, whereapplicable, Art. 88 GDPR in conjunction with § 26 BDSG (balancing of interests,based on fulfillmenttols’ interest in recruiting new employees for thecompany).

5.2.4.2 Job Applications

On ourwebsite, you can find out about career opportunities and job openings atfulfillmenttools. If you wish to apply for a job online, clicking on the joblisting will redirect you tohttps://rewe-digital.dvinci-hr.com/de/p/fulfillmenttools/jobs/weitergeleitet.There, you will find an online application system where you can also submit aspeculative application.

The legalbasis for the data processing described is Article 6(1)(b) of the GDPR and §26(1) sentence 1 of the BDSG (decision regarding the establishment of anemployment relationship) and Art. 6(1)(f) GDPR (balancing of interests, basedon fulfillmenttols’ interest in providing you with a user-friendly website andfacilitating your search).

We alsooffer you the option of conducting the interview via Google Hangouts videocall. This allows us to reduce personal contact, as requested by the Germangovernment. We would like to point out that this is an offer and not anobligation. If you do not agree to the use of Google Hangouts, this will nothave any negative impact on the application process. In this case, we willarrange a telephone interview or, if possible, an in-person interview.Regarding data processing by Google Ireland Limited, please refer to therelevant privacy notices: https://policies.google.com/privacy. Data processingwithin Google Hangouts video calls is based on your consent and thus inaccordance with Art. 6(1)(a) GDPR, § 26(2) BDSG. You may revoke your consent atany time with future effect. Even in the event of revocation, this will nothave any negative impact on the application process.

5.2.5 Registration for a Trial Version

To register for a 30-day free trial of our solution, the following data or categories of data are provided:

• First name (optional)

• Last name

• Company

• Jobtitle (optional)

• Businessemail

• Phonenumber (optional)

The data collected during registration will be processed exclusively for the purpose ofpresenting our products to a prospective customer, unless you also wish tosubscribe to the newsletter by checking the corresponding checkbox. The legalbasis for the processing of your data is our legitimate interest pursuant toArt. 6(1)(f) GDPR (balancing of interests, based on our interest in providingtrial access to prospective customers to demonstrate the functionality of ourproducts and with the aim of concluding a contract for the full product).
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5.3.Cookies and Other Technologies (Website Analytics/Tracking)

We use cookies and other technologies in certain areas of our website, for example, toidentify visitors’ preferences and optimize the website accordingly. This makesnavigation easier and enhances user-friendliness. Cookies and other technologies also help us identify particularly popular sections of ourwebsite.

Cookies aresmall text files that are stored on the hard drive of your device. They allowus to retain information over a certain period of time and to identify yourdevice. We use persistent cookies to improve user guidance and providepersonalized content. We also use so-called session cookies, which areautomatically deleted when you close your browser. You can set your browser tonotify you when cookies are placed. This makes the use of cookies transparentto you. Important: If you completely disable the use of cookies, you may not beable to use certain features of our website.

Depending on the purpose of the cookies and other technologies, we distinguish between necessary, statistical, and marketing cookies.

The necessary cookies and other technologies are required to ensure the website’s core functions and to fulfill our contractual obligations to customers andpartners. Their use is based on the legal basis of Section 25(2)(2) TDDDG inconjunction with Article 6(1)(b) (contract initiation or fulfillment) and (f)of the GDPR (balancing of interests, based on fulfillmenttols’ interest in monitoring the technical performance of the website). Therefore, they cannot be deactivated by you as a website user via our Consent Management System.

All cookiesand other technologies are described in detail in the so-called cookie bannerunder “Services.” You can view these at any time in the “Privacy Settings” inthe website footer. Please ensure that you have disabled all privacy/pop-upblockers for the website in your browser so that the cookie banner can bedisplayed to you.

Statistical cookies and other technologies are necessary to understand how our visitors useour portal, to identify errors, and to continuously improve the portal. Theyare used on the legal basis of Section 25(1) TDDDG (consent for the setting orreading of cookies) in conjunction with Article 6(1)(a) GDPR (consent for thesubsequent data processing). Data processing begins only after you have provided the corresponding opt-in (consent). You may revoke your consent todata processing at any time with future effect. The revocation does not affect the law fulness of the data processing carried out prior to the revocation.

All cookies and other technologies are described in detail in the so-called cookie banner under the Services. You can view these at any time in the “Privacy Settings” in the footer of the website. Please ensure that you have disabled allprivacy/pop-up blockers for the website in your browser so that the cookiebanner can be displayed to you.

You can also revoke your consent at any time in the “Privacy Settings.”

Marketing cookies and other technologies are used to understand your interests and todisplay personalized content that is relevant to you. Their use is based on thelegal basis of Section 25(1) TDDDG (consent for the placement or reading ofcookies) in conjunction with Article 6(1)(a) of the GDPR (consent for thesubsequent data processing). Data processing begins only after you haveprovided the corresponding opt-in (consent). You may revoke your consent todata processing at any time with future effect. The revocation does not affect the lawfulness of the data processing carried out prior to the revocation.

All cookies and other technologies are described in detail in the so-called cookie banner under the Services. You can view these at any time in the “Privacy Settings” in the footer of the website. Please ensure that you have disabled allprivacy/pop-up blockers for the website in your browser so that the cookie banner can be displayed to you.

You canalso withdraw your consent at any time in the “Privacy Settings.”
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5.4.Links to social media services

Our website contains links to the social media services Instagram, LinkedIn, and YouTube.You can recognize links to the websites of these social media services by therespective company logo. If you follow these links, you will be directed tofulfillmenttools’ profile on the social media service. When you click a link toa social media service, a connection is established with the servers of thatsocial media service. This transmits information to the social media service’sservers indicating that you have visited our website. In addition, further datais transmitted to the provider of the social media service. This includes, forexample:

• The address of the webpage on which the activated link is located

• The date and time the webpage was accessed or the link was activated

• Information about the browser and operating system used

• IP address

If you are already logged in to the relevant social media service when you click the link, the social media service provider may be able to determine your username — andpossibly even your real name — from the transmitted data and associate thisinformation with your personal user account on the social media service. You can prevent this association with your personal user account by logging out of your user account beforehand.

The servers of the social media services are located in the United States and othercountries outside the European Union. The data may therefore also be processedby the social media service provider in countries outside the European Union.Please note that companies in these countries are subject to data protectionlaws that generally do not protect personal data to the same extent as is thecase in the member states of the European Union.

Please note that we have no influence over the scope, nature, and purpose of dataprocessing by the social media service provider. For more information on howyour data is used by the social media services integrated into our website,please refer to the privacy policy of the respective social media service.
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5.5 YouTube Embedding

Our website includes videos from YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, which are not stored on our servers.

When you visit our pages containing embedded videos, content from the third-partyprovider that hosts the videos is loaded. As a result, YouTube primarilyreceives the usage data technically required in this context. We have noinfluence over further data processing by the third-party provider. However, when embedding the videos, we have ensured that the enhanced privacy modeoffered by YouTube is activated. The enhanced privacy mode ensures that thethird-party provider does not set cookies unless the video is clicked.

The embedding of YouTube videos is based on Art. 6(1)(f) GDPR in conjunction with §25(2)(2) TDDDG (legitimate interest in an appealing website design, publicrelations, and communication).

If you want to ensure that no cookies are set by YouTube, do not click on the embedded videos. For more information on YouTube/Google’s privacy policy, please visit: https://policies.google.com/privacy?hl=de&gl=de.
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5.6 Documentationof Compliance with Legal Obligations

To demonstrate that we have complied with your data subject rights, we retainappropriate records of such compliance. In the event of a request for erasure,after reviewing the request and carrying out the erasure, we retain only yourpseudonymized user ID in connection with the erasure request and thecorresponding date. In the event of a request for information, we store theinformation we provided to you along with the corresponding date. In the eventof a withdrawal of consent you previously provided, we store the date and timeof the withdrawal. In the event of a valid objection to processing based onlegitimate interests, we store your objection along with the date and time.   

The legal basis for the processing is Art. 6(1)(f) GDPR (balancing of interests, based onour legitimate interest in demonstrating compliance with our legal obligationsto the data subjects).  

 

6.Recipients of Personal Data

Within fulfillmenttools, access to your data is limited to those individuals who need it to perform the tasks assigned to them.

In addition, service providers who assist us in fulfilling our tasks may haveaccess to your data. These are service providers in the following categories:

• Hostingservice providers for the operation of our servers

• Developmentservice providers for the programming, development, maintenance, and support ofsoftware applications

• Emaildelivery service providers for sending emails

• Thevendors/recipients of data mentioned in this Privacy Policy in connection withcookies and other technologies

• Adnetwork operators for advertising campaigns and the display of onlineadvertising (remarketing and retargeting)

• Serviceproviders for the delivery and performance measurement of online advertising

• Analyticsservice providers for the evaluation of data and analysis of the use ofelectronic media (e.g., Fulfillmenttools App)

• Socialmedia operators for the provision of social plugins

• HR service providers to assist with applicant selection

The serviceproviders we use must meet specific confidentiality requirements. They aregranted access to your data only to the extent and for the duration necessaryto perform their tasks.

 

7. Is data processed outside the European Union?

We also useservice providers located in third countries outside the European Union toprocess your data. Countries outside the European Union handle the protectionof personal data differently than countries within the European Union. There iscurrently no decision by the European Commission that these third countriesgenerally provide an adequate level of protection. We have therefore takenspecial measures to ensure that your data is processed in these third countrieswith the same level of security as within the European Union. When we use third-country serviceproviders, we verify whether the service provider is based in a country forwhich an adequacy decision has been issued by the European Commission, orwhether a service provider based in the United States is certified under theData Privacy Framework. Otherwise, we enter into the data protection agreement(Standard Data Protection Clauses) provided by the European Commission for theprocessing of personal data in third countries and conduct processing-relatedtransfer impact assessments. These measures provide appropriate safeguards forthe protection of your data with service providers in third countries.

 

8.Retention Period

We generally store your data only for as long as we need it for the respectiveprocessing purposes. If the data is no longer necessary for fulfilling theprocessing purposes specified in this Privacy Policy, it will be deleted,unless its retention is still required to comply with commercial or tax-relatedretention obligations. As a rule, we delete your data after these periods ordetermine the deletion period based on these criteria:

• Dataregarding usage behavior on the website is deleted after 37 months

• Wedelete data collected during participation in a contest three months after thecontest ends. We store the personal data of winners for three years from theend of the year in which the contest ended, based on Sections 195 and 199 ofthe German Civil Code (BGB). If tax-related retention obligations apply, we maystore data for up to 10 years

• Datarelated to a customer service inquiry for at least 3 months, but no longer than10 years after the matter is resolved

• Datarelated to an application for a posted position for six months after theapplication process is completed

• Inconnection with the newsletter, we generally store and process your data for aslong as you have subscribed to the newsletter. After you unsubscribe from thenewsletter or revoke your consent, we will stop sending the newsletter anddelete your data, unless we are legally required to retain it for specificpurposes, including the defense against legal claims

• Informationregarding the retention period for data collected in connection with cookiesand other technologies can be found on the website/app under “PrivacySettings.”
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9.Automated Decision-Making, Profiling

We do notuse your personal data for automated decision-making or profiling.

10. Your Data Subject Rights

To theextent that we process your personal data, you, as the data subject, areentitled to the following rights in particular, subject to the requirements ofdata protection law.

10.1.Right of Access

You mayrequest information about your personal data processed by us.

10.2. Right to Rectification

If your information is no longer accurate, you may request that your data be corrected.If your data is incomplete, you may request that it be completed.

10.3. Right to Erasure

You have the right to request the erasure of your data. Please note that the right toerasure depends on the existence of a legitimate reason. Furthermore, theremust be no legal requirements obligating us to retain your data.

10.4. Right to Restriction of processing

You have the right to request the restriction of the processing of your data. Pleasenote that a claim for restriction of processing depends on the existence of alegitimate reason.

10.5. Right to Object on basis of Legitimate Interest

If data is collected on the basis of Art. 6(1)(f) GDPR (data processing to safeguardlegitimate interests), you have the right to object to the processing of yourdata for reasons arising from your particular situation. In the event of anobjection, we will no longer process your data unless we can demonstratecompelling legitimate grounds for the processing that override your interests,rights, and freedoms, or the processing is necessary for the establishment,exercise, or defense of legal claims.

10.6.Right to File a Complaint

You have the right to file a complaint with the competent data protection supervisoryauthority if you object to the processing of your data.

10.7. Right to Data Portability

You havethe right to receive the personal data you have provided to us in an electronicformat.

10.8. Right to Withdrawal Your Consent

You have the right to withdraw your consent to the processing of your data, which youhave provided to us, at any time. The easiest way to withdraw your consent isto contact us via email using the contact information provided above. Thewithdrawal of consent does not affect the lawfulness of the processing of yourdata carried out prior to the withdrawal.

10.9.Information Security: Incident Reporting

To submit an incident report regarding fulfillmenttools, please use the provided form(link) for information security incidents. There, you can report an incident,record details, and reliably contact the responsible employee. This process issecure, confidential, and is handled via a separate mailbox. As an alternativeto this incident reporting system, you may report an incident directly to orcontact us via email at isb@fulfillmenttools.com.