We are pleased about your visit on our website. Protecting your privacy is very important to us and we want you to feel safe and secure. We therefore only collect, process and use personal data if you have consented to its collection, processing and use or if this is permitted by law. Personal data are individual details 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 on which data we collect, when and for which purpose.
Below we inform you in detail about the type, scope and purpose of the personal data collected, used and processed by us and clarify your rights as a data subject.
1. Name and address of the person responsible
The person responsible 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 provisions of data protection law:
Managing Directors: Dr. Niklas Hellemann, Lukas Schaefer, Felix Schürholz
Landline: +49 221 2910 5993
2. Name and address of data protection officer
The data protection officer of the person responsible is
Mrs Madeleine Heuts
3. Access data in server log files
You can visit our website without providing 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, transferred data volume, browser used, operating system used, IP address, requested URL, referrer URL (URL you visited immediately before) and the requesting provider.
Temporary storage of the IP address by the system is necessary to enable delivery of the website to your terminal device. For this purpose, your IP address must remain stored for the duration of the session. The legal basis for the temporary storage of your data and log files is Art. 6 para. 1 lit. f GDPR.
This data is used exclusively to ensure the trouble-free operation of the website, as well as for transmission to law enforcement authorities in the event of a cyber attack, to ensure the security of our information technology systemsand to improve our services, and does not allow us to draw any conclusions about your person.
These purposes also include our legitimate interest in data processing pursuant to Art. 6 Para. 1 lit. f GDPR. The collection of data for the provision of the website and the storage of data in log files is mandatory for the operation of our website. Consequently, there is no possibility of appeal.
4. Data collection and use for contract processing and registration
We collect personal data when you voluntarily provide us with it when you contact us or register on our e-learning platform. Which data is collected can be seen from the respective input forms. This includes the following data:
- email address
- telephone number
- documents or texts that contain personal data transmitted by you
- your organization (e.g. employer)
We use the data provided by you for the processing of contracts and your enquiries. We will also notify you by email of information regarding your registration or our services, such as changes to our system or the scope of our offerings, and notify you of technical circumstances. After complete completion of the contract or deletion of your user account, your data will be blocked for further use and deleted at the end of the statutory retention periods, unless you have expressly consented to further use of your data or we reserve the right to further use of 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 take place by a message to the contact possibility described below.
If you have registered on our e-learning platform (available at https://elearning.sosafe.de) and are starting to use it, we will also collect and process the following personal data:
- Progress in e-learning 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 e-learning modules
Legal basis for the processing of your data after your consent is Art. 6 para. 1 lit. a GDPR, as well as for the fulfillment of the contract Art. 6 para. 1 lit. b GDPR.
In order to make visiting 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 mobile device.
Cookies enable 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 permanent cookies (“persistent cookies”), on the other hand, remain on your end device and enable us, for example, to recognize you on your next visit.
Analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies we learn how the website is used by you and can thus constantly optimize our offer.
In these purposes also our legitimate interest lies in the processing of personal data in accordance with Art. 6 para. 1 lit. f GDPR.
You can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or whether to exclude the acceptance of cookies in certain cases or in general. If cookies are not accepted, the functionality of our website may be restricted. In addition, you can delete cookies that have already been set via your browser at any time. The transmission of Flash cookies cannot be prevented via the settings of your browser, but by changing the settings of the Flash Player. This also applies to all third party cookies listed below.
6. Using analysis tools
6. a) Matomo
Data is collected and stored 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”) on the basis of our legitimate interest in statistical analysis of user behaviour for optimisation and marketing purposes in accordance with Art. 6 para. 1 lit. f GDPR. From this data, pseudonymised user profiles can be created and evaluated for the same purpose. Cookies can be used for this purpose. The cookies enable, among other things, the recognition of the Internet browser. The data collected using Matomo technology (including your pseudonymised IP address) is processed on our servers.
The information generated by the cookie in the pseudonymous user profile is not used to personally identify the visitor to this website and is not merged with personal data about the bearer of the pseudonym.
If you do not agree with the storage and evaluation of this data from your visit, you can object to its storage and use at any time by clicking the respective checkbox at https://www.sosafe-awareness.com/privacyin the corresponding section on Matomo. In this case, a so-called opt-out cookie will be stored in your browser, which means that Matomo does not collect any session data. Please note that any subsequent complete deletion of your cookies carried out by you will result in the Opt-Out cookie also being deleted and possibly having to be 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, 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://sosafe-awareness.com/privacy/ 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 specific data you have entered in this social network, further information may also be collected, processed or used by the provider of the social network.
In addition, the social networking provider may collect, process and use the most important information about the computer system from which you visit it, such as your IP address, processor type used, browser version and plug-ins.
If you are logged in with your personal user account of the respective network during the visit of 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 before visiting our social media presence and delete the cookies.
The legal basis for the processing of personal data is Art. 6 para. 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. 6 para. 1 lit. a GDPR.
We maintain a presence in the respective social networks in order to communicate with you and inform you about our services. In these purposes also our legitimate interest lies in the processing of personal data in accordance with Art. 6 para. 1 lit. f GDPR.
For further information on the purpose and scope of data collection and 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 the LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland.
Xing is operated by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany.
8. Use of SendGrid for demo mail dispatch
We use the services of SendGrid, Inc., 1801 California Street, Suite 500, Denver, CO 80202, USA for sending mails as part of our phishing demo/showcase (via https://demo.sosafe.de), but not for our phishing simulations as part of an official contract.
SendGrid is a service with which, among other things, the sending of e-mails and newsletters can be organized and analyzed. If you provide data, such as an e-mail address, it will be 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 USA, which is intended to ensure compliance with European data protection standards in the USA.
SendGrid enables us to analyze the sending of e-mails. This enables us to determine whether a message has been opened and which links have been clicked. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type and operating system). They serve exclusively for the statistical analysis of messages as well as for the preparation of the evaluation of the demo/showcase mail dispatch.
Data processing is based on your consent (Art. 6 para. 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.
For further details, please refer to the SendGrid data protection regulations at: https://sendgrid.com/policies/privacy/privacy-shield-certification/.
9. Incorporated content and services of third parties
10. Communication channels
You can register to receive our newsletter. For the dispatch of our newsletter we use the newsletter dispatch service Newsletter2GO, which is operated by Newsletter2Go GmbH, Nürnberger Str. 8, 10787 Berlin (“Newsletter2GO”). We have concluded an order data processing contract 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. The registration takes place in a so-called double opt-in procedure. After registration you will receive a confirmation email from us in which you have to confirm your registration again. This entire process is documented and stored. This includes the storage of the registration and confirmation time as well as your IP address. By subscribing to our newsletter, you agree to receive it.
Your data will be stored on the servers of Newsletter2GO. Newsletter2GO uses this information to send and evaluate the newsletter. The evaluation takes place on our behalf, but Newsletter2GO can also use the data for quality assurance and improvement of its own service.
You can cancel the receipt of our newsletter at any time, whereby your consent to its dispatch and the storage of your data for statistical purposes is revoked.
Please use the link at the end of the newsletter to cancel your subscription.
b. Email and Forms
Due to legal requirements, we provide information on our website that enables us to be contacted quickly and electronically and to communicate directly with you. This includes above all our email address. If you contact us by email, the personal data you provide will be stored automatically.
The legal basis for processing the data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the purpose of the contact is to conclude a contract, the additional legal basis for the processing is Article 6(1)(b) GDPR.
Here we process the following personal data from you:
- First name and surname
- email address
- telephone number
- Individual cover letter
The data provided will of course always be treated confidentially.
However, we use the personal data transmitted by you exclusively for the processing of your specific enquiry. The data provided will always be treated confidentially.
Your data can be stored in a customer relationship management system (so-called CRM system) or another organization tool for customer data.
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data sent by e-mail, this is the case when the respective conversation with you has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.
You can revoke 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 be continued.
c. Feedback survey
On the information/learning pages belonging to our simulated phishing mails (links start with https://learning.sosafe.de/…) as well as within the eLearning platform (https://elearning.sosafe.de), we offer you the possibility to leave feedback, praise or criticism. The evaluation entered (on a scale of 1-5) and the optional free text will be made available to your employer in order to give them an overview of the feedback from the workforce regarding the IT security training offered. If you wish to provide anonymous feedback, please refrain from mentioning your name or other identification features in the free text field.
Optionally, it is also possible to enter your e-mail address separately. This information is only used to enable SoSafe to react to a point of criticism and, for example, to ask you for further information. However, any e-mail address you enter in this field will never be returned to the employer, i.e. your anonymity will be safeguarded at this point.
11. Data security
We secure our website and other systems through technical and organizational measures against loss, destruction, access, alteration or distribution of your data by unauthorized persons. However, despite regular checks, complete protection against all hazards is not possible.
The website uses the industry standard SSL (Secure Sockets Layer) for encryption. This guarantees the confidentiality of your personal data via the Internet.
12. Legal basis for the processing of personal data
Insofar as we obtain your consent for the processing of personal data, Art. 6 para. 1 lit. a GDPR serves as the legal basis for the processing of personal data.
Art. 6 para. 1 lit. b GDPR serves as the legal basis for the processing of personal data required for the fulfilment of a contract to which you are a party. This shall also apply to processing operations necessary for the implementation of pre-contractual measures.
If the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
In the event that your vital interests or the vital interests of another natural person necessitate the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
If the processing is necessary to safeguard a legitimate interest of our company or a third party and if your interests, fundamental rights and fundamental freedoms do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR shall serve as the legal basis for the processing.
If the processing of your personal data is based on Article 6 I f GDPR, our legitimate interest, unless otherwise stated, is the conduct of our business. For the rest, we have stated our purposes and interests within the scope of the above list of processing in each case.
13. Disclosure of personal data
Furthermore, we will not pass on personal data without your express consent, unless there is a legal basis for permission, e.g. if we are legally obliged to disclose data (information to criminal prosecution authorities and courts; information to public bodies that receive data on the basis of statutory provisions, e.g. social insurance carriers, tax authorities, etc.) or if we involve third parties who are obliged to maintain professional secrecy in order to enforce our claims.
14. Data erasure and storage duration
The deletion of the stored personal data takes place if you revoke your consent to storage or if knowledge of this data is no longer necessary for the fulfilment of the purpose pursued with the storage. In addition, storage can take place if this has been provided for by the European or national legislator in Union regulations, laws or other regulations to which the person responsible is subject.
We regularly check whether the purpose pursued by the storage is still given and delete your data immediately if this is no longer the case. The deletion, however, only takes place after the expiration of the periods of the tax and commercial law regulations.
15. Right of access
You have the right to receive information about your personal data stored by us on request and free of charge.
You also have the right to access the following information:
- the processing purposes,
- the categories of personal data to be processed,
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations,
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration,
- the existence of a right to the rectification or erasure of personal data concerning him or her or to the limitation of the processing by the controller or of a right to object to such processing,
- the existence of a right of appeal to a supervisory authority,
- if the personal data are not collected from the data subject: all available information on the origin of the data as well as,
- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the EU-GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject.
You also have a right to know whether personal data has been transferred to a third country or to an international organisation. If this is the case, you are otherwise entitled to receive information about the appropriate guarantees in connection with the transmission.
16. Right of correction
In case of incorrect data you have the right to correction. We are obliged to carry out the correction immediately.
17. Right of restricted processing
You have the right to demand that we restrict processing if one of the following conditions is met:
- The accuracy of the personal data is contested by the data subject for a period of time which allows the data controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests 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 them for the assertion, exercise or defence of legal claims.
- The data subject has lodged an objection against the processing pursuant to Art. 21 (1) GDPR and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the data subject.
Where the processing of personal data concerning you has been restricted, such data may not be processed, with the exception of their storage, without your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or for reasons of an important public interest of the Union or of a Member State.
If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by us before the restriction is lifted.
18. Right of deletion
You have the right to demand that we delete your personal data immediately if one of the following reasons applies and if 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 on which the processing was based pursuant to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR and there is no other legal basis for the processing.
- The data subject objects to the processing under Article 21(1) GDPR and there are no overriding legitimate reasons for the processing or the data subject objects to the processing under Article 21(2) GDPR.
- Personal data have been processed unlawfully.
- The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.
- The personal data were collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
If we have made the personal data public and we are obliged to delete the personal data as the person responsible pursuant to Art. 17 (1) GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform other data controllers who process the published personal data that the data subject has requested the deletion of all links to this personal data or copies or replications of this personal data from these other data controllers, insofar as the processing is not required.
The right of deletion does not exist insofar as processing is necessary:
- on the exercise of freedom of expression and information;
- to fulfil a legal obligation which the processing requires under the law of the Union or of the Member States to which the controller is subject or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
- for archival purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the law referred to under section a) presumably makes it impossible or seriously impairs the attainment of the objectives of such processing, or
- to assert, exercise or defend legal claims.
19. Right of information
If you have asserted the right to correction, deletion or limitation of processing against us, we are obliged to notify all recipients to whom the personal data concerning you have been disclosed of this correction or deletion or limitation of processing, unless this proves impossible or involves disproportionate effort.
You have the right vis-à-vis us to be informed of these recipients.
20. Right of data transferability
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 data controller without any hindrance on our part, provided that the processing is based on the consent pursuant to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR or on a contract pursuant to Art. 6 para. 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 in the public interest or in the exercise of official authority assigned to us.
Furthermore, when exercising your right to data transferability pursuant to Art. 20 (1) GDPR, you have the right to obtain that the personal data is transferred directly by us to another responsible person, insofar as this is technically possible and insofar as this does not impair the rights and freedoms of other persons.
The right to data transfer does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
21. Right of objection
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 letters e or f GDPR. This also applies to profiling based on these provisions.
In the event of objection, we will no longer process the personal data unless we can prove compelling reasons for the processing worthy of protection which outweigh your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.
If we process your personal data in order to conduct direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising. This also applies to profiling in so far as it is related to such direct marketing. If you object to our processing for direct marketing purposes, we will no longer process your personal data for these purposes.
You also have the right to object to the processing of your personal data concerning you by us for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR for reasons arising from your particular situation, unless such processing is necessary for the performance of a task in the public interest.
You can contact us at any time to exercise your right to object. You are also free to exercise your right of objection 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 data processing consent
You have the right to revoke your consent to the processing of personal data at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
23. Right to automated decisions in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effect against you or which similarly significantly affects you, provided that the decision
- is not necessary for the conclusion or performance of a contract between you and us or
- is permitted by the laws of the Union or of the Member States to which we are subject and those laws contain adequate measures to safeguard your rights and freedoms and your legitimate interests, or
- with your explicit consent.
Is the decision
- necessary for the conclusion or performance of a contract between you and us or
- it takes place with your explicit consent,
we will take reasonable steps to protect your rights and freedoms and your legitimate interests, including, as a minimum, the right of us to obtain the intervention of any person in order to present our point of view and challenge the decision.
24. Existence of an automated decision making process
We do not perform automated decision making or profiling.
25. Right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of presumed infringement, if you consider that the processing of your personal data is in breach of the GDPR.
The supervisory authority to which the complaint was submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
26. Contact us
Please contact us directly if you have any questions regarding the collection, processing or use of your personal data, for information, correction, blocking or deletion of data or general questions and suggestions on the subject of privacy:
50823 Cologne, Germany
Ms Madeleine Heuts has been appointed as our Data Protection Officer and can be reached at privacy(at)sosafe.de or +49 221 2910 5993.
Managing Directors: Dr. Niklas Hellemann, Lukas Schaefer, Felix Schürholz
Commercial Register: HRB96220, Cologne Local Court
Status: August 2019