We look forward to your visit to our website. The protection of your privacy is very important to us and we want you to feel safe on our website.
We therefore only collect, process and use personal data if you have consented to the collection, processing and use or if a law permits this. Personal data are individual information about your personal or factual circumstances. This includes in particular your name and your e-mail address, but also data about your use of our website (e.g. your IP address). Below we inform you in detail what data we collect, when and for what purpose.
Below we will inform you in detail about the nature, scope and purpose of the personal data we collect, use and process and clarify your rights as a data subject.
1. Name and address of the person responsible
Responsible persons within the meaning of the EU General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations are:
Ehrenfeld Belt 76
Managing Directors: Dr. Niklas Hellemann, Lukas Schaefer, Felix Schürholz
Landline: +49 221 2910 5993
2. Name and address of data protection officers
The data protection officer of the controller is
Ms Madeleine Heuts
Ehrenfeld Belt 76
3. Access data in server log files
You can visit our website without giving any personal information. We only store access data in so-called server log files. This includes the name of the requested file, date and time of retrieval, amount of data transferred, browser used, operating system used, IP address, requested URL, referrer URL (URL you visited immediately earlier) and the requesting provider.
The temporary storage of the IP address by the system is necessary in order to enable the delivery of the website to its terminal device. To do this, your IP address must be stored for the duration of the session.
The legal basis for the temporary storage of your data and the log files is Art. f GDPR.
This data is used solely to ensure trouble-free operation of the website, as well as for transmission to law enforcement authorities in the event of a cyber attack and to ensure the security of our information technology systems and to ensure the improvement of our offer and do not allow us to draw any conclusions about your person.
In these purposes lies also our legitimate interest in the data processing according to Art. 6 sec. 1 lit. f GDPR.
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of our website. There is therefore no possibility of conflict.
4. Data collection and use for contract processing and registration
We collect personal data when you voluntarily provide it to us when you contact us or when you register on our eLearning platform. The data collected can be seen from the respective input forms. This includes the following data:
- E-mail address
- Telephone number
- Documents or texts you provide that contain personal data
- Related organisation (e.g. employer)
We use the data you provide to process the contract and process your enquiries. We will also inform you by email about information about your registration or our services, such as changes in our system or our range of services, and notify you of technical circumstances. After complete processing of the contract or deletion of your user account, your data will be blocked for further use and deleted after the expiry of the statutory retention periods, unless you expressly consent to further use of your data or we reserve the right to use any additional data, which is permitted by law and about which we inform you below. The deletion of your user account is possible at any time and can be done by sending a message to the contact option described below.
If you have registered on our eLearning platform (available under https://elearning.sosafe.de) and start using it, we also collect and process the following personal data:
- Progress in the eLearning modules (i.e. how many modules have already been started, how many have already been completed, etc.)
- Results of the final quiz questions within the individual eLearning modules
The legal basis for the processing of your data after your consent is Art. 1 lit. a GDPR, as well as for the performance of the contract Art. 1 lit. b GDPR.
In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called “cookies” on our website. These are small text files that are stored on your device.
Cookies allow us, for example, to track and determine your preferences and to identify you individually during a visit to our website. At the end of the browser session, most of the cookies we use are deleted (“session cookies”).
The persistent cookies (“persistent cookies”) remain on your device and enable us to use e.g. recognizing you on your next visit.
The use of analytics cookies is carried out for the purpose of improving the quality of our website and its contents. Through the analysis cookies, we learn how the website is used by you and can thus continuously optimize our offer.
In these purposes, our legitimate interest lies in the processing of personal data in accordance with Article 6(6). 1 lit. f GDPR.
You can set your browser so that you are informed about the setting of cookies and decide individually on their acceptance or exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited. In addition, you can delete cookies that have already been set at any time via your browser. The transmission of Flash cookies cannot be prevented by the settings of your browser, but by changes in the settings of the Flash Player. This also applies to all third-party cookies listed below by us.
6. Using analysis tools
6 a) Matomo
On our website, using the web analysis service software Matomo (www.matomo.org), a service of the provider InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand, (“Matomo”) based on our legitimate interest in the statistical analysis of the User behaviour for optimization and marketing purposes in accordance with Art. f GDPR, data collected and stored. From this data pseudonymized user profiles can be created and evaluated for the same purpose.
If you do not agree with the storage and analysis of this data from your visit, then you can object to the storage and use under https://www.sosafe.de/datenschutz in the corresponding section on Matomo at any time with a mouse click. In this case, a so-called opt-out cookie is stored in your browser, which means that Matomo does not collect any session data. Please note that any subsequent deletion of your cookies, which you have carried out, will also result in the opt-out cookie being deleted and, if necessary, reactivated by you.
6 b) Google Analytics
On our website, using the web analysis service software Google Inc. (Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA) based on our legitimate interest in the statistical analysis of the User behaviour for optimization and marketing purposes in accordance with Art. f GDPR f GDPR, data collected and stored. From this data pseudonymized user profiles can be created and evaluated for the same purpose.
Google uses this information to evaluate the use of the website by visitors and to compile reports on website activity. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. For these purposes, we also have a legitimate interest in processing the data. The IP addresses of the users are anonymized in order to adequately take into account the interest of the users in their protection of personal data.
The data will be deleted as soon as it is no longer needed for our recording purposes. In our case, this is the case after 14 months.
If you do not agree with the storage and analysis of this data from your visit, then you can object to the storage and use under https://www.sosafe.de/datenschutz in the corresponding section on Google Analytics at any time with a mouse click. In this case, a so-called opt-out cookie is stored in your browser, which means that Google does not collect any session data. Please note that any subsequent deletion of your cookies, which you have carried out, will also result in the opt-out cookie being deleted and, if necessary, reactivated by you.
7. Social media
In addition to this website, we also maintain presences in various social networks. If you visit such a presence, personal data may be transmitted to the provider of the social network. It is possible that in addition to the storage of the data you enter specifically on this social network, further information will also be collected, processed or used by the provider of the social network.
In addition, the provider of the social network may collect, process and use the most important data of the computer system from which you visit it – for example, your IP address, the processor type used and browser version including plugins.
If you are logged in with your personal user account of the respective network during your visit to such a network, this network can assign the visit to your account. If you do not wish such an assignment, you must log out with your account and delete the cookies before visiting our social media presence.
The legal basis for the processing of personal data is Article 6(4) of the 1 lit. f GDPR. If you have given your consent to the processing to the respective provider of the social network, the legal basis for the processing of your data is Art. 1 lit. a GDPR.
We maintain the presences on the respective social networks in order to communicate with you and to inform you about our services. In these purposes, our legitimate interest lies in the processing of personal data in accordance with Article 6(6). 1 lit. f GDPR.
For further information on the purpose and scope of the data collection as well as on the further processing and use of your data, please refer to the data protection regulations of the respective network:
Facebook is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Twitter is operated by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
LinkedIn is operated by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland.
Xing is operated by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany.
8. Use of the SendGrid service for demo mailing
For sending the mails as part of our demo (under demo.sosafe.de, but not for our phishing simulations as part of an assignment, we use the services of SendGrid, Inc., 1801 California Street, Suite 500, Denver, CO 80202, USA.
SendGrid is a service that can be used to organize and analyze, among other things, the sending of e-mails and newsletters. If you specify data such as an e-mail address, it is stored on SendGrid’s servers in the United States.
SendGrid is certified according to the “EU-US Privacy Shield”. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European data protection standards in the US.
With SendGrid, we can analyze the sending of emails. This allows you to determine whether a message has been opened and which links have been clicked if necessary. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type and operating system). They are used exclusively for the statistical analysis of messages as well as for the evaluation of the demo mailing.
The data is processed on the basis of your consent (Art. 6 sec. 1 lit. a GDPR). You can revoke this consent at any time. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
9. Embedded content and services of third parties
10. Communication channels
You can register to receive our newsletter. To send our newsletter, we use the newsletter sending service Newsletter2GO, which is operated by Newsletter2Go GmbH, Nürnberger Str. 8, 10787 Berlin (“Newsletter2GO”). We have concluded an order processing agreement with Newsletter2GO, which obliges Newsletter2GO to protect your data, to process it on our behalf in accordance with this data protection declaration and not to pass it on to third parties.
Our newsletter contains information about our products, offers from us and our partners listed on the website as well as news about Zeeno.
To register, you must provide us with your e-mail address. You may voluntarily provide us with additional information, such as your name. Registration takes place in a so-called double opt-in procedure. After registration, you will receive a confirmation email from us, in which you will have to confirm your registration again. This entire process is documented and stored. This includes the storage of the login and confirmation date, as well as your IP address. By subscribing to our newsletter, you agree to receive it.
Your data will be stored on the newsletter2GO servers. Newsletter2GO uses this information for sending and evaluating the newsletters. The evaluation takes place on our behalf, however, Newsletter2GO can also use the data to ensure and improve the quality of its own service.
You can cancel the receipt of our newsletter at any time, which revokes your consent to its dispatch as well as the storage of your data for statistical purposes.
Please use the provided link at the end of the newsletter to cancel.
b. E-mail and forms
On our website, due to legal regulations, we provide information that enables us to quickly contact us electronically and to communicate directly with us. This includes above all our email address. If you contact us by email, the personal data you provide will be automatically stored.
The legal basis for the processing of the data transmitted in the course of sending an e-mail is Article 6(4) of the 1 lit. f GDPR. If the contact is aimed at the conclusion of a contract, the additional legal basis for the processing shall be Article 6(6) of the Treaty. 1 lit. b GDPR.
We process the following personal data from you:
- First and last name
- E-mail address
- Telephone number
- Individual cover letter
The data provided will of course always be treated confidentially.
However, we will only use the personal data you provide for the processing of your specific request. The data provided will always be treated confidentially.
Your information can be stored in a customer relationship management system (so-called CRM System) or another organizational tool for customer data.
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. For the personal data sent by e-mail, this is the case when the respective conversation with you is terminated. The conversation ends if it can be inferred from the circumstances that the facts in question have been finally clarified.
You have the option to withdraw your consent to the processing of your personal data at any time. If you contact us, you can object to the storage of your personal data at any time. In such a case, the conversation cannot continue.
c. Feedback survey
On the information pages associated with our simulated phishing emails (links start with https://learning.sosafe.de/…) as well as within the eLearning platform (under https://elearning.sosafe.de) we offer you the possibility to leave us feedback, praise or criticism. The entered rating (on a scale of 1-5) and the optional free text will be made available to your employer to provide them with an overview of the feedback from the workforce on the IT security training offered. If you want to provide anonymous feedback, please do not mention your name or other identification features in the free text field. You can also optionally provide your e-mail address separately. Their information only serves to ensure that SoSafe can respond to it, for example, in the event of a criticism and, for example, ask you a question. However, your registered e-mail address will never be returned to the employer, i.e. Your anonymity is maintained at this point.
11. Data security
We secure our website and other systems by technical and organizational measures against loss, destruction, access, alteration or dissemination of your data by unauthorized persons. However, despite regular checks, full protection against all hazards is not possible.
The website uses the industry standard SSL (Secure Sockets Layer) for encryption. This ensures the confidentiality of your personal information via the Internet.
12. Legal basis for the processing of personal data
Insofar as we obtain your consent for the processing of personal data, Article 6(4) serves. 1 lit. a GDPR as the legal basis for the processing of personal data.
In the processing of personal data necessary for the performance of a contract to which you are a party, Article 6(4) serves. 1 lit. b GDPR as legal basis. This also applies to processing operations necessary for the implementation of pre-contractual measures.
Insofar as processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Article 6(4) serves. 1 lit. c GDPR as legal basis.
In the event that your vital interests or the vital interests of another natural person require the processing of personal data, Article 6(4) of the 1 lit. d GDPR as legal basis.
If the processing is necessary to safeguard a legitimate interest of our company or a third party and your interests, fundamental rights and fundamental freedoms do not outweigh the former interest, Article 6(4) serves. 1 lit. f GDPR as the legal basis for processing.
If the processing of your personal data is based on Article 6 I lit. f GDPR, is our legitimate interest, unless otherwise stated, the conduct of our business activities. In addition, we have indicated our purposes and interests in the context of the above list of processing.
13. Disclosure of personal data
In addition, we will not disclose personal data without your express consent, unless there is a legal authorisation, e.g. if we are legally obliged to hand over data (information to law enforcement authorities and courts; Information to public authorities receiving data on the basis of legal regulations, e.g. social security institutions, tax authorities, etc.) or when we engage third parties obliged to enforce our claims of professional secrecy.
14. Data erasure and storage time
The deletion of the stored personal data takes place if you revoke your consent to storage or if the knowledge of this data is no longer necessary for the fulfilment of the purpose pursued with the storage. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject.
We regularly check whether the purpose of the storage is still there and delete your data immediately if this is no longer the case. However, the deletion takes place only after the expiry of the time limits of the tax and commercial regulations.
15. Right to information
You have the right to receive information about your personal data stored by us free of charge upon request.
You also have a right of access regarding the following information:
- the processing purposes,
- the categories of personal data that are processed,
- the recipients or categories of recipients to whom the personal data have been or are still being disclosed, in particular to recipients in third countries or to international organisations;
- where possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining that duration;
- the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal with a supervisory authority,
- if the personal data are not collected from the data subject: all available information on the origin of the data and,
- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) GDPR and, at least in these cases, meaningful information on the logic involved, as well as the scope and intended impact of a such processing for the data subject.
You also have a right of access as to whether personal data has been transferred to a third country or to an international organisation. If this is the case, you have the right to obtain information about the appropriate guarantees in connection with the transmission.
16. Right to rectification
If you have incorrect data, you have the right to rectification. We are obliged to make the correction without delay.
17. Right to processing
You have the right to require us to restrict processing if one of the following conditions is met:
- The accuracy of the personal data is disputed by the data subject for a period of time which enables the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses to delete the personal data and instead demands the restriction of the use of the personal data.
- The controller no longer needs the personal data for the purposes of processing, but the data subject needs it to assert, exercise or defend legal claims.
- The data subject has objected to the processing in accordance with Art. 1 GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.
If the processing of personal data concerning you has been restricted, such data may only be used with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of a other natural or legal person or for reasons of an important public interest of the Union or of a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, we will inform you before the restriction is lifted.
18. Right to erasure
You have the right to request that the personal data concerning you be deleted immediately, provided that one of the following reasons applies and that the processing is not necessary:
- The personal data have been collected for such purposes or processed in any other way for which they are no longer necessary.
- The data subject withdraws his consent, which is the subject of the processing in accordance with Article 6(4) of the 1 letter a GDPR or Art. 2 letter a GDPR and there is no other legal basis for the processing.
- In accordance with Article 21(21) of the 1 GDPR objecting to the processing and there are no primary legitimate reasons for the processing or the data subject submits in accordance with Article 21(21) of the 2 GDPR objecting to the processing.
- The personal data were processed unlawfully.
- The erasure of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
- The personal data were collected in relation to information society services offered in accordance with Article 8(4) of the 1 GDPR.
If the personal data has been made public by us and we are the person responsible in accordance with Art. 1 GDPR obliged to delete the personal data, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, in order to other data controllers who are responsible for the to inform that the data subject has been informed by such other data controllers that all links to such personal data or copies or replications have been deleted by the data subject. personal data, insofar as the processing is not necessary.
The right to erasure does not exist to the extent that the processing is necessary:
- the exercise of the right to freedom of expression and information;
- to fulfil a legal obligation requiring processing under the law of the Union or of the Member States to which the controller is subject, or to perform a task which is in the public interest or in the exercise of official authority delegated to the controller;
- for reasons of public interest in the field of public health in accordance with Article 9(4) of the 2 lit. h and i and Article 9(4) 3 GDPR;
- for archival purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Art. 89 Abs. 1 GDPR, in so far as the right referred to in section (a) is likely to make the attainment of the objectives of such processing impossible or seriously impaired, or
- for the assertion, exercise or defence of legal claims.
19. Right to information
If you have asserted the right to rectification, deletion or restriction of processing against us, we are obliged to provide all recipients to whom the personal data concerning you has been disclosed, this rectification or deletion of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed about these recipients.
20. Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, provided that the processing is subject to the consent given in Art. 1 letter a GDPR or Art. 2 letter a GDPR or on a contract pursuant to Art. 1 letter b GDPR and the processing is carried out by means of automated procedures, provided that the processing is not necessary for the performance of a task which is in the public interest or in the exercise of official authority, which is transferred.
In addition, in the exercise of your right to data portability in accordance with Article 20(4). 1 GDPR has the right to obtain that the personal data is transferred directly from us to another controller, insofar as this is technically possible and if this does not affect the rights and freedoms of other persons.
The right to data portability shall not apply to the processing of personal data necessary for the performance of a task which is in the public interest or carried out in the exercise of official authority delegated to the controller.
21. Right to object
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you which may be processed pursuant to Article 6(4) of the 1 letter e or f GDPR, to appeal. This also applies to profiling based on these provisions.
We will no longer process the personal data in the event of an objection, unless we can prove compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert the exercise or defend legal claims.
If we process your personal data for direct marketing, you have the right to object to the processing of your personal data for the purpose of such advertising at any time. This also applies to profiling insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.
You also have the right, for reasons arising from your particular situation, against the processing of your personal data concerning you, which are used by us for scientific or historical research purposes or for statistical purposes in accordance with Article 89(4) of the 1 GDPR is made to appeal, unless such processing is necessary for the performance of a task in the public interest.
In order to exercise the right to object, you can contact us at any time. You are also free to exercise your right to object in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
22. Right to revoke consent under data protection law
You have the right to withdraw your consent to the processing of personal data at any time. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.
23. Right to automated decisions on a case-by-case basis, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, that has legal effect on you or similarly adversely affects you, provided that: the decision
- necessary for the conclusion or performance of a contract between you and us, or
- permitted by Union or Member State laws to which we are subject, and such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
- with your express consent.
If the decision is
- necessary for the conclusion or performance of a contract between you and us, or
- it is carried out with your express consent,
we take reasonable measures to protect your rights and freedoms and your legitimate interests, including at least the right to be granted the intervention of a person by us in expressing his or her own point of view and challenging the decision.
24. Existence of automated decision-making
We do not perform automated decision-making or profiling.
25. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, place of employment or place of the alleged breach if you believe that the processing of personal data concerning you violates the GDPR.
The supervisory authority to which the complaint was lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
If you have any questions about the collection, processing or use of your personal data, information, correction, blocking or deletion of data or general questions and suggestions about data protection, please contact us directly:
Ehrenfeld Belt 76
Ms. Madeleine Heuts, Internal Data Protection Officer, can be contacted at privacy(at)sosafe.de or +49 221 2910 5993.
Managing Directors: Dr. Niklas Hellemann, Lukas Schaefer, Felix Schürholz
Commercial Register: HRB96220, Cologne District Court
As of: August 2019
Mandatory information in accordance with Article 13 GDPR
In the event of initial contact, we are obliged in accordance with Art. 12, 13 GDPR to provide you with the following mandatory information under data protection law: