Privacy Policy
Privacy Policy
OC fulfillment GmbH
Domstraße 20, 50668 Cologne
Office: Schanzenstraße 6-20, Kupferwerk 2.20, 51063 Cologne
hereinafter referred to as “fulfillmenttools” or “we”,
operates the 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 you have any questions.
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
2. Data Protection Officer
The designated contact person for data protection matters (e.g., for inquiries of any 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
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 to restricted information, or contact us in any other way.
The following data or categories of data may be collected in this process:
• Server log file data recorded when the website is accessed: e.g., information aboutthe browser type and version used, the page accessed, the page from which the website was accessed, the amount of data transmitted, the user’s operating system, Internet service provider, and IP address, as well as the date and time of access
• Data you provide when contacting us (including title, first name, last name, emailaddress, phone number, company, position, address, date of registration, date of 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., device ID, 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 and time stamp of the newsletter subscription request and of the click on the link in the confirmation email, as well as the consent statements you have provided)
• Data we receive when you read the newsletter or product recommendations sent via email (opening the email, clicks on links contained in the email, data about the device used, location data based on the IP address, email address availability, 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 a speculative application (personal data, educational background, professional history, cover letter, resume, portrait photo, references)
• Data you provide on career platforms such as Xing and LinkedIn and that we collect as part of the recruitment process (first and last name as provided on the platform, your current position, date we contacted you, your response to ourinquiry)
4. Provision of Data
Providing your data is not required by law. However, some of the data listed is necessary to use the website’s features. Providing other data is voluntary, but may be required to use certain features. When you enter data, we will inform you if the 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 required data, the relevant service or function cannot be provided.
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 requesting computer—including the IP address, the pages you visit on our site, the date and duration of your visit, the identification data of the browser and operating system type used, and the website from which you visit us — as a standard 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 fulfillmenttools’ interest in ensuring the security of IT systems).
5.2. Processing for Advertising Purposes
5.2.1 Newsletter
On our website, you have the option to subscribe to our newsletter. The newsletter provides information about fulfillmenttools as a company and our current products and services. After submitting the registration form, you will receive a confirmation email. Your subscription will not take effect until you have clicked the link in the confirmation email. You can unsubscribe from the newsletter at any time. To do so, simply use the unsubscribe link at the bottom of each email. The legal basis for the data processing described is Art.6(1)(a) GDPR (consent).
5.2.2 Contact (Form)
You can contact us via the contact form, by email, by mail, or by phone. We process your data to respond to your inquiry and, if necessary, to send you requested informational materials. Your data may be transferred to the department responsible for your inquiry. The legal basis for the data processing described is Article 6(1)(b) and (f) of the GDPR (pre-contractual measures, performanceof a contract, or balancing of interests, based on fulfillmenttools’ interest in responding to inquiries).
5.2.3 Contests
From time to time, you may have the opportunity to participate in contests on our website that are advertised through our website. To conduct a contest, we process your data (name, email address, mailing address, and, if necessary, other data required for the contest). We process your data to verify eligibility, determine and notify the winner, send the prize, and, if applicable, publish the 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 process your 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 date we contacted you internally. If an application process ensues, the provisions in the following section “Job Application” apply. If you are not interested in the 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, where applicable, Art. 88 GDPR in conjunction with § 26 BDSG (balancing of interests,based on fulfillmenttools’ interest in recruiting new employees for the company).
5.2.4.2 Job Applications
On our website, you can find out about career opportunities and job openings at fulfillmenttools. 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 a speculative application.
The legal basis 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 an employment relationship) and Art. 6(1)(f) GDPR (balancing of interests, based on fulfillmenttools’ interest in providing you with a user-friendly website and facilitating your search).
We also offer you the option of conducting the interview via Google Hangouts video call. This allows us to reduce personal contact, as requested by the German government. We would like to point out that this is an offer and not an obligation. If you do not agree to the use of Google Hangouts, this will not have any negative impact on the application process. In this case, we will arrange a telephone interview or, if possible, an in-person interview. Regarding data processing by Google Ireland Limited, please refer to the relevant privacy notices: https://policies.google.com/privacy. Data processing within Google Hangouts video calls is based on your consent and thus in accordance with Art. 6(1)(a) GDPR, § 26(2) BDSG. You may revoke your consent at any time with future effect. Even in the event of revocation, this will not have 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
• Job title (optional)
• Business email
• Phone number (optional)
The data collected during registration will be processed exclusively for the purpose of presenting our products to a prospective customer, unless you also wish to subscribe to the newsletter by checking the corresponding checkbox. The legal basis for the processing of your data is our legitimate interest pursuant toArt. 6(1)(f) GDPR (balancing of interests, based on our interest in providing trial access to prospective customers to demonstrate the functionality of our products and with the aim of concluding a contract for the full product).
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 makes navigation easier and enhances user-friendliness. Cookies and other technologies also help us identify particularly popular sections of our website.
Cookies are small text files that are stored on the hard drive of your device. They allow us to retain information over a certain period of time and to identify your device. We use persistent cookies to improve user guidance and provide personalized content. We also use so-called session cookies, which are automatically deleted when you close your browser. You can set your browser to notify you when cookies are placed. This makes the use of cookies transparent to you. Important: If you completely disable the use of cookies, you may not be able 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 and partners. 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 fulfillmenttools’ 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 cookies and other technologies are described in detail in the so-called cookie banner under “Services.” You can view these at any time in the “Privacy Settings” in the website footer. Please ensure that you have disabled all privacy/pop-up blockers for the website in your browser so that the cookie banner can be displayed to you.
Statistical cookies and other technologies are necessary to understand how our visitors use our portal, to identify errors, and to continuously improve the portal. They are 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 the subsequent data processing). Data processing begins only after you have provided the corresponding opt-in (consent). You may revoke your consent to data 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 all privacy/pop-up blockers for the website in your browser so that the cookie banner can be displayed to you.
You can also revoke your consent at any time in the:
Marketing cookies and other technologies are used to understand your interests and to display personalized content that is relevant to you. Their use is based on the legal 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 the subsequent data processing). Data processing begins only after you have provided the corresponding opt-in (consent). You may revoke your consent to data 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 can also withdraw your consent at any time in the:
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 the respective company logo. If you follow these links, you will be directed to fulfillmenttools’ profile on the social media service. When you click a link to a social media service, a connection is established with the servers of that social media service. This transmits information to the social media service’s servers indicating that you have visited our website. In addition, further data is transmitted to the provider of the social media service. This includes, for example:
• 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 — and possibly even your real name — from the transmitted data and associate this information 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 other countries outside the European Union. The data may therefore also be processed by the social media service provider in countries outside the European Union. Please note that companies in these countries are subject to data protection laws that generally do not protect personal data to the same extent as is the case in the member states of the European Union.
Please note that we have no influence over the scope, nature, and purpose of data processing by the social media service provider. For more information on how your data is used by the social media services integrated into our website, please refer to the privacy policy of the respective social media service.
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-party provider that hosts the videos is loaded. As a result, YouTube primarily receives the usage data technically required in this context. We have no influence over further data processing by the third-party provider. However, when embedding the videos, we have ensured that the enhanced privacy mode offered by YouTube is activated. The enhanced privacy mode ensures that the third-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, public relations, 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.
5.6 Documentationof Compliance with Legal Obligations
To demonstrate that we have complied with your data subject rights, we retain appropriate records of such compliance. In the event of a request for erasure, after reviewing the request and carrying out the erasure, we retain only your pseudonymized user ID in connection with the erasure request and the corresponding date. In the event of a request for information, we store the information we provided to you along with the corresponding date. In the event of a withdrawal of consent you previously provided, we store the date and time of the withdrawal. In the event of a valid objection to processing based on legitimate 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 on our legitimate interest in demonstrating compliance with our legal obligations to 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 have access to your data. These are service providers in the following categories:
• Hosting service providers for the operation of our servers
• Development service providers for the programming, development, maintenance, and support of software applications
• Email delivery service providers for sending emails
• The vendors/recipients of data mentioned in this Privacy Policy in connection with cookies and other technologies
• Ad network operators for advertising campaigns and the display of online advertising (remarketing and retargeting)
• Service providers for the delivery and performance measurement of online advertising
• Analytics service providers for the evaluation of data and analysis of the use of electronic media (e.g., Fulfillmenttools App)
• Social media operators for the provision of social plugins
• HR service providers to assist with applicant selection
The service providers we use must meet specific confidentiality requirements. They are granted access to your data only to the extent and for the duration necessary to perform their tasks.
7. Is data processed outside the European Union?
We also use service providers located in third countries outside the European Union to process your data. Countries outside the European Union handle the protection of personal data differently than countries within the European Union. There is currently no decision by the European Commission that these third countries generally provide an adequate level of protection. We have therefore taken special measures to ensure that your data is processed in these third countries with the same level of security as within the European Union. When we use third-country service providers, we verify whether the service provider is based in a country for which an adequacy decision has been issued by the European Commission, or whether a service provider based in the United States is certified under the Data Privacy Framework. Otherwise, we enter into the data protection agreement(Standard Data Protection Clauses) provided by the European Commission for the processing of personal data in third countries and conduct processing-related transfer impact assessments. These measures provide appropriate safeguards for the 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 respective processing purposes. If the data is no longer necessary for fulfilling the processing purposes specified in this Privacy Policy, it will be deleted, unless its retention is still required to comply with commercial or tax-related retention obligations. As a rule, we delete your data after these periods or determine the deletion period based on these criteria:
• Data regarding usage behavior on the website is deleted after 37 months
• We delete data collected during participation in a contest three months after the contest ends. We store the personal data of winners for three years from the end of the year in which the contest ended, based on Sections 195 and 199 of the German Civil Code (BGB). If tax-related retention obligations apply, we may store data for up to 10 years
• Data related to a customer service inquiry for at least 3 months, but no longer than 10 years after the matter is resolved
• Data related to an application for a posted position for six months after the application process is completed
• In connection with the newsletter, we generally store and process your data for as long as you have subscribed to the newsletter. After you unsubscribe from the newsletter or revoke your consent, we will stop sending the newsletter and delete your data, unless we are legally required to retain it for specific purposes, including the defense against legal claims
• Information regarding the retention period for data collected in connection with cookies and other technologies can be found on the website/app under “Privacy Settings.”
9. Automated Decision-Making, Profiling
We do not use your personal data for automated decision-making or profiling.
10. Your Data Subject Rights
To the extent that we process your personal data, you, as the data subject, are entitled to the following rights in particular, subject to the requirements of data protection law.
10.1. Right of Access
You may request 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 to erasure depends on the existence of a legitimate reason. Furthermore, there must 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. Please note that a claim for restriction of processing depends on the existence of a legitimate 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 safeguard legitimate 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 demonstrate compelling 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 supervisory authority if you object to the processing of your data.
10.7. Right to Data Portability
You have the right to receive the personal data you have provided to us in an electronic format.
10.8. Right to Withdrawal Your Consent
You have the right to withdraw your consent to the processing of your data, which you have provided to us, at any time. The easiest way to withdraw your consent is to contact us via email using the contact information provided above. The withdrawal of consent does not affect the lawfulness of the processing of your data 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 alternative to this incident reporting system, you may report an incident directly to or contact us via email at isb@fulfillmenttools.com.