Privacy policy

Information on the processing of personal data when using the EUROGATE Intermodal GmbH websites
and the EUROGATE Intermodal GmbH platform

Last updated: 09.12.2023

1 GENERAL

1.1. In the following, we inform about the processing of personal data when using our website www.egim.eu. Personal data is any information relating to an identified or identifiable natural person (hereinafter “you”), e.g. name, address, e-mail addresses and user behaviour.

2 YOUR RIGHTS

2.1. You have the following rights with respect to us regarding personal data concerning you:

• Right to information: You can request information in accordance with Art. 15 GDPR about your personal data that we process.
• Right to rectification: If the information concerning you is not (or no longer) accurate, you can request a rectification in accordance with Art. 16 GDPR. If your data is incomplete, you can request that it be completed.
• Right to erasure: You can request the erasure of your personal data in accordance with Art. 17 GDPR.
• Right to restriction of processing: According to Art. 18 GDPR, you have the right to request a restriction of the processing of your personal data.
• Right to object to processing: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out on the basis of Article 6(1)(f) GDPR. The controller will then no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. The collection of data for the provision of the website and the storage of log files are absolutely necessary for the operation of the website.
• Right to data portability: In the event that the requirements of Art. 20 (1) GDPR are met, you have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to third parties. The collection of data to provide the website and the storage of log files are absolutely necessary for the operation of the website. They are therefore not based on consent pursuant to Art. 6 (1) a GDPR or on a contract pursuant to Art. 6 (1) b GDPR, but are justified pursuant to Art. 6 (1) f GDPR. The requirements of Article 20 (1) of the GDPR are therefore not met.
• Right to complain: If you believe that the processing of your personal data violates data protection law, you have the right to complain to a data protection supervisory authority of your own choice in accordance with Article 77(1) of the GDPR. This includes the data protection supervisory authority responsible for the controller: The Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Str 22, 20459 Hamburg, 040/428 54 – 4040, mailbox@datenschutz.hamburg.de.

3 PROCESSING OF PERSONAL DATA WHEN CONTACTING EUROGATE INTERMODAL GmbH

3.1. If you contact us by e-mail or via our contact form, the data you provide (e.g. your e-mail address, your name and your telephone number, if applicable) will be processed by us and stored in particular to answer your questions. We handle support requests via the Freshdesk service of Freshworks GmbH, Alte Jakobstraße 85/86, Hof 1, Haus 5, 10179 Berlin (see point 5 of this declaration).

The legal basis for data processing depends on the reason and content of the respective contact request. In the case of inquiries that are related to an existing contractual relationship or the initiation of such a relationship, the legal basis is Art. 6 (1) lit. f GDPR. Our legitimate interest is to process your requests.

We delete the data generated in connection with support requests after storage is no longer required or restrict processing if there are legal retention obligations. The concrete respective periods depend on the reason and content of your contact request.

4 PROCESSING OF PERSONAL DATA WHEN VISITING THE EUROGATE INTERMODAL GmbH WEBSITE

4.1. This declaration applies to the web pages:

• egim.eu

4.2. When you visit our website,we collect and process the following data, which is technically necessary for us to display our website to you and to ensure stability and security:

• IP address
• Date and time of the request
• Time zone difference from Greenwich Mean Time (GMT)
• Content of the request (concrete page)
• Access status / HTTP status code
• Data volume transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software

For the technical operation of our website, we use Amazon Web Services (Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg, “AWS”). In addition, we also use services of WP Engine, Irongate House, 22-30 Duke’s Place, London, EC3A 7LP, United Kingdom, for this purpose. In each case, these are processors within the meaning of Art. 28 GDPR.

4.3. Cookies use

Open cookie settings

4.3.1. When you use our website, cookies are stored on your terminal device. Cookies are pieces of information that we can read, in particular to recognize your terminal device.

4.3.2. You can consent to the use of cookies and third-party services in detail via our cookie consent menu. The cookie consent menu contains a cookie statement with a more detailed description of the cookies used, such as their respective purpose.

4.3.3. For this purpose, we use the service Borlabs Cookie; a technically necessary cookie (borlabs-cookie) to store your cookie consents. Borlabs Cookie does not process any personal data. However, the borlabs-cookie cookie stores the consent you gave when you entered the website. If you wish to revoke these consents, simply delete the cookie in your browser or correct your settings in the Consent Manager menu. In some cases, a “reload” of the website may be necessary. When you re-enter/reload the website, you will be asked again for your cookie consent.

4.3.4. However, you can also set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited. If cookies are used by third-party companies or for analysis purposes, we will inform you about this separately within the framework of this data protection declaration and, if necessary, request your consent.

4.3.5. Regardless, you can find more information about cookies at www.allaboutcookies.org. The website www.allaboutcookies.org can give you detailed instructions on how to set and delete cookies, depending on the browser type. At the bottom of this page, where we can name them, we have shown references to cookie settings in various browsers.

4.3.6. If you consent, the legal basis for the processing of your data is Section 25 (1) TTDSG and Article 6 (1) a GDPR. In addition, you consent pursuant to Art. 49 para. 1 GDPR that providers in the USA also process your data. In this case, it is possible that the transmitted data will be processed by local authorities. Data required for the operation of the website is processed on the basis of Art. 6 (1) lit. f GDPR. Our legitimate interest is to enable the website operation.

4.4. Use of Google Analytics

4.4.7. With your consent, our website uses Google Analytics, a web analytics service provided by Google Inc (“Google”). Google Analytics uses cookies that enable an analysis of your use of our website. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymization is activated on our website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

4.4.8. The IP address transmitted by your browser as part of Google Analytics is not merged with other data from Google.

4.4.9. You may refuse the storage of cookies and the usage of your personal data by selecting the appropriate setting in the cookie banner as well as by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

4.4.10. We use Google Analytics with your consent to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has, despite the ECJ decision on Schrems II, still submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The actual legal basis for the use of Google Analytics is Art. 6 para. 1 lit. a GDPR. In addition, you consent pursuant to Art. 49 (1) GDPR that Google may process your data in the USA. In this case, it is possible that the transmitted data will be processed by local authorities.

4.4.11. Third-party provider information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User terms and conditions: https://www.google.com/analytics/terms/de.html, Privacy policy overview: https://www.google.com/intl/de/analytics/learn/privacy.html, and Privacy policy: https://www.google.de/intl/de/policies/privacy.

4.5. LinkedIn Insight Tag

4.9.1. On our website we use the conversion tool “LinkedIn Insight-Tag” of LinkedIn Ireland Unlimited Company (LinkedIn Ireland). This tool creates a cookie in your web browser, which enables the collection of, among other things, the following data: IP address, device and browser properties, and page events (e.g. page views). LinkedIn Ireland does not transmit any personally identifiable information to us, but provides anonymized reports on website audience and viewing performance. In addition, LinkedIn Ireland offers the possibility of retargeting via the insight tag. With the help of this data, we can display targeted advertising outside of our website without identifying you as a user of the website.

4.9.2. The legal basis for processing your data is your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR. In addition, you consent pursuant to Art. 49 (1) GDPR that LinkedIn may process your data in the USA. In this case, it is possible that the transmitted data will be processed by local authorities. You give your corresponding consent via our cookie banner. Please note that LinkedIn Ireland may also process your data outside the EU/EEA. According to a recent ruling by the European Court of Justice (ECJ), there is no adequate level of data protection in the USA and thus a risk to the protection of your data. For example, under certain circumstances, your data may be processed by US authorities for control and monitoring purposes. If you nevertheless wish to approve or consent to the use of this tool, you can select this via the cookie banner.

4.9.3. For more information about the LinkedIn Insight tag, please see the following link. For more information about privacy at LinkedIn Ireland, please see the LinkedIn Ireland Privacy Policy.

5 USE OF SOCIAL MEDIA

5.1 LinkedIn

5.1.1. As the operator of a LinkedIn page, we, EUROGATE Intermodal GmbH, together with the operator of the social network, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, hereinafter: LinkedIn, the responsible party within the meaning of Art. 26 of the General Data Protection Regulation (GDPR). When you visit our LinkedIn page, personal data is processed by the responsible parties. In the following, we will inform you about what data is involved, how it is processed and what rights you have in this regard.

5.1.2. Decisive for the use of the portal of LinkedIn are the terms of use of LinkedIn at https://www.linkedin.com/legal/user-agreement and the other terms and policies listed there. In particular, the privacy policy can be found at: https://www.linkedin.com/legal/privacy-policy and the Cookie Policy can be found at https://www.linkedin.com/legal/cookie-policy.

5.1.3. For questions regarding the processing of your personal data, for information, blocking, deletion or correction of data, as well as the revocation of consent given and objections, please contact the responsible persons. Information on the handling of personal data by LinkedIn on the LinkedIn portal can be found in their privacy policy at https://www.linkedin.com/legal/privacy-policy, in their cookie policy at https://www.linkedin.com/legal/cookie-policy and from their help pages at https://www.linkedin.com/help/linkedin?trk=microsites-frontend_legal_privacy-policy&lang=de or https://www.linkedin.com/help/linkedin?trk=microsites-frontend_legal_user-agreement&lang=de.

5.1.4. LinkedIn shows you ads customized for you both inside and outside their services. You can choose to be shown personalised ads, but not opt out of other ads.

5.1.5. LinkedIn targets ads (and measures their performance) both inside and outside LinkedIn to members, visitors, and others, directly or through various partners. To do this, LinkedIn uses the following data, either combined or separately (in some cases, this requires your consent, which is requested separately):

• Data from advertising technologies both inside and outside our services, pixels, tags, cookies and device identifiers;
• Information provided by members (for example, contact information, job title, and industry);
• Data from your use of our Services (for example, search history, feed, content you read, who you follow or who follows you, contacts, participation in groups, page visits, videos you watch, clicks on an ad, etc.), including as described in Section 1.3;
• Information from advertising partners, vendors and publishers; and
• Information that may be inferred from the data listed above (e.g., use of a profile’s job titles to infer an industry, career level, and compensation grade; use of graduation data to infer age or use of first names or pronoun usage to infer gender; use of your feed activity to infer your interests; or use of device data to recognize you as a member).

5.1.6. LinkedIn shows you ads labeled Sponsored Content that look like similar, non-sponsored content, except that they are labeled as advertisements (for example, as “ad” or “sponsored”). When you take a social action on these ads (such as “liking,” commenting, or sharing), your action is associated with your name and can be seen by third parties. This includes the provider (EUROGATE Intermodal GmbH) of the advertisement. If you perform a social action on LinkedIn services, this action may (depending on your settings) be mentioned in the context of associated advertisements.

5.2. YouTube video usage

5.2.1. We have integrated YouTube videos into our online offer, which are stored on https://www.YouTube.com and can be played directly from our website.

5.2.2. With your consent, YouTube receives the information that you have accessed the corresponding subpage of our website by visiting the website. In addition, the data mentioned under No. 4.2 of this declaration are transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at YouTube, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

5.3.3. We use Youtube with your consent to analyze and regularly improve the use of our website. The statistics obtained allow us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has, despite the ECJ decision on Schrems II, still submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The actual legal basis for the use of Google Analytics is Art. 6 para. 1 lit. a GDPR. In addition, you consent pursuant to Art. 49 (1) GDPR that Google may process your data in the USA. In this case, it is possible that the transmitted data will be processed by local authorities.

5.4.4. For more information on the purpose and scope of data collection and its processing when you visit our YouTube channel directly, please refer to the privacy policy https://www.youtube.com/intl/ALL_de/howyoutubeworks/user-settings/privacy/. There you will also find further information about your rights and setting options to protect your privacy.

6 NEWSLETTER

6.1. Data used: Title, first name, last name, company, address, zip code, city, e-mail address.

6.2. We use the services of sendinblue for sending newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin.

6.3. sendinblue is a service with which the sending of newsletters can be organized and analyzed. If you enter data for the purpose of receiving newsletters (e.g. e-mail address), this data is stored on sendinblue’s servers in Germany.

6.4. With the help of sendinblue, we can analyze our newsletter campaigns. When you open an email sent with sendinblue, a file contained in the email (so-called web beacon) connects to the servers of sendinblue. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.

6.5. If you do not want any analysis, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in each newsletter message. Furthermore, you can also unsubscribe directly on the website under Newsletter Unsubscribe, by e-mail to egim.sales@eurogate.eu or by sending a message to the contact details provided in the imprint.

6.6. The data processing is based on your consent (Art. 6 para. 1 lit. a GDPR and § 7 UWG). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

6.7. For more details, please see sendinblue’s privacy policy at: https://de.sendinblue.com/datenschutz-uebersicht/.

7 JOB PORTAL

7.1. As part of the application process, we process personal data submitted to us and EUROGATE Group through the integrated applicant portal. The following personal data is regularly processed:

• Surname, first name, etc.
• Contact information (home address, (mobile) phone number, email address)
• Application materials (cover letter, certificates, questionnaires, interviews, qualifications, employment history, earliest available start date, salary expectations).

For candidates under specific job consideration, personality assessments such as the Predictive Index may be conducted during the later stages of the application process. The processed data in this context encompasses:

• Email address
• Access timestamp
• One-time password
• Questionnaire with your responses
• Evaluation of the provided answers

7.2 We process your personal data as part of the application procedure to the extent necessary for determining the establishment of an employment relationship, in accordance with Article 6, Paragraph 1, Letter b of the GDPR.

Unsolicited applications and those kept for future consideration at Eurogate are processed based on your consent, as outlined in Article 6, Paragraph 1, Letter a of the GDPR, and § 26, Paragraph 2 of the BDSG.

The assessment of personality using the Predictive Index may be conducted for potential use in personnel development measures, and it is therefore carried out under the provisions of Article 6, Paragraph 1, Letters b and f of the GDPR.

This process, including its systemic evaluation, utilizes software provided by Predictive Index, LLC, with the legal foundation established through contractual provisions as per Article 28 of the GDPR and the principles outlined in Article 45 and onwards of the GDPR.

Anonymization for statistical purposes, along with its evaluation, is undertaken in accordance with Article 6, Paragraph 1, Letter f of the GDPR. This allows us to gain insights into the job market and our applicants, enabling us to tailor our job advertisements to market conditions.

To fulfill the requirements of an authorized economic operator (AEO) in accordance with Article 76 of the Customs Code (Regulation (EEC) No. 2913/92) and Article 253 et seq. of the Customs Code (Regulation (EEC) No. 2454/93), and/or in compliance with EU regulations on combating terrorism (EC 881/2002 and 2580/2001), random checks are conducted at irregular intervals to ascertain any potential suspicion of involvement in terrorism.

7.3 We do not pass on your data to unauthorized third parties. However, when necessary, data may be shared with the following entities for personnel administration and processing customer orders:

• All responsible, involved employees and bodies, such as the works council for participation in the process.
• With your consent, also to other parts of the EUROGATE group of companies
• External contractors for the hosting and support of the applicant portal in accordance with the principles of Art. 28 GDPR, such as Haufe Service Center GmbH, Munzinger Straße 9, 79111 Freiburg, Germany
• External contractors such as Predictive Index in accordance with Art. 28 GDPR and Art. 45 ff GDPR
• In the event of legal disputes, data may be passed on to lawyers on the basis of § 203 StGB

7.4 Your data is not intended to be transferred to a third country or international organizations, except in the case of the Predictive Index personality assessment procedure. So-called EU standard contractual clauses have been agreed with Predictive Index to demonstrate an adequate level of data protection in accordance with Article 45 and onwards of the GDPR.

7.5 Applications and associated information will be deleted six months after the completion of the application process. This retention period is necessary for defense against claims arising from the AGG. Applications stored for potential future job opportunities at EUROGATE, based on your consent, will be deleted no later than one year.

It is also possible to apply to EUROGATE without giving your consent. This can be done without giving reasons and has no negative consequences.

Test results of the Predictive Index are deleted after 3 months for rejected applicants. The results of the Predictive Index will be added to the personnel file of applicants who are offered employment. The results will also be used in the future to assess any further development of the employee in the company, as a new test would generally lead to distorted findings.

8 DURATION OF THE PROCESSING

8.1. Your personal data will be deleted after expiry of the statutory retention periods, which result, for example, from the German Civil Code (BGB), the German Commercial Code (HGB) and the German Fiscal Code (AO). If data is not affected by this, it will be deleted when the respective processing purpose has been achieved.

9 EXTERNAL LINKS

To provide optimal information, our website offers links to third-party sites. These links will take you to websites that we consider to be helpful. Typically, once you exit our website, we do not process additional personal data. In cases where this is not immediately apparent, we explicitly indicate that it is an external link.

We have no influence on the content and design of websites from other providers and therefore refer to their data protection declarations. Please note that the assurances provided in our data protection declaration do not extend to third-party websites.