1. Definitions

These terms used in this policy reflect the terminology of the European General Data Protection Regulations 2016/ 679 (“GDPR”).

2. Name and Address of the Controller

For the purposes of the EU GDPR 2016/679, the data controller is:
Market Logic Software AG
Franklinstraße 28
10587 Berlin
Deutschland
Phone: +49 30 3988 15-150
Email: info@marketlogicsoftware.com
Website: www.marketlogicsoftware.com

3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:
Niccolò Manco
Market Logic Software AG
Franklinstraße 28
10587 Berlin
Deutschland
Phone: +49 30 3988 15-150
Email: dpo@marketlogicsoftware.com
Website: www.marketlogicsoftware.com
Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

4. Collection and use of personal data

4.1 When visiting the website. Our website provider automatically collects information that your browser transmits to us and stores it as “server log files”. Collected information includes: (1) Browser types and versions, (2) Operating system used, (3) Referrer URL (the website from which an accessing system reaches our website), (4) Host name of the accessing computer, (5) Access dates and times, (6) An IP address, (7) The Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems (including but not limited to hardware and software information, crash data, device information etc.)
When collecting general data and information, we do not draw conclusions about you as the data subject. Instead, this information is required to (1) deliver the content of our website correctly, (2) optimize our website’s content and advertisements, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the case of a cyber-attack. Therefore, the Market Logic Software AG analyzes anonymously collected data and information statistically, with the goal of increasing the data protection and data security of our enterprise, and to safeguard an optimal level of protection for the personal data we process. Anonymous data collected of the server log files are stored separately from all personal data you provide.
Art. 6(1) lit. a of the GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

4.2 Subscription to our newsletters. Market Logic Software offers its clients, business partners and the general public email newsletters.
When registering for a newsletter, we store your e-mail address and name, as well as the IP address of the computer system assigned by the Internet service provider (ISP) which is used at the time of the registration, as well as the date and time of registration. Collecting this data is necessary to protect our operating system from the possible misuse of a data subject’s e-mail address in the future.
The personal data we collect as part of a registration will only be used for the purpose of sending the newsletter.
Your information will not be used for direct marketing purposes nor will it be sold to third parties.
If you no longer wish to receive newsletters, your subscription can be terminated at any time by clicking the “unsubscribe” button in each newsletter or by contacting privacy@marketlogicsoftware.com.
Article 6(1) lit. b of the GDPR serves as the legal basis of the processing.

4.3 Newsletter tracking. Our newsletters contain “tracking pixels”. A tracking pixel is a miniature graphic embedded in the newsletter, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we can see whether an e-mail was opened by a data subject (as well as the time it was opened), and the links that were clicked on.
We store and analyze this data to optimize the features and delivery of our newsletter, as well as to adapt the content of future newsletters to the interests of the data subject. As stated above, personal data will not be transferred to any third party. Data subjects are able to revoke their consent by unsubscribing. In that case, the user’s personal data will be deleted from our operating systems within a reasonable time frame.
Art. 6(1) lit. a of the GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

4.4 Registration for webinars. When subscribing to our webinars, you provide us with your name, company position and e-mail address. This information is used to provide by us, to provide you with our webinar. Your information is also shared with speakers at the webinar.
Article 6(1) lit. b of the GDPR serves as the legal basis of the processing.

4.5 Online recruitment applications. We use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. We use Workable to process personal information as a data processor on our behalf. Workable is only entitled to process your personal data in accordance with our instructions.
As part of our online recruitment process, the following information might be collected:

• Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
• Name, email address, address, date of birth qualifications, experience, information relating to your employment history, skills and experience that you provide to us.
• If you contact us, we may keep a record of that correspondence.
• A record of your progress through any hiring process that we may conduct.

Details of your visits to Workable’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s Website and the resources that you access.
Workable provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
Workable’s technology allows us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way, we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally. We use information held about you in the following ways:

• To consider your application in respect of a role for which you have applied.
• To consider your application in respect of other roles.
• To communicate with you in respect of the recruitment process.
• To enhance any information that we receive from you with information obtained from third-party data providers.
• To find appropriate candidates to fill our job openings.
• To help our service providers (such as Workable and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.

We do not use automatic decision-making or profiling.
Article 6(1) lit. b and Article 6(1) lit. f of the GDPR serves as the legal basis of the processing.
The data that we collect from you and process using Workable’s services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
The data that we collect from you and process using Workable’s services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
In particular, your data may be accessible to i) Workable’s staff in the USA or ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed between Workable Software Limited and its overseas group companies, and between Workable Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact us. We will not otherwise transfer your personal data outside of Germany, United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

4.6 Mobile applications of our software. Please review the privacy policy available on the non-mobile version of our applications to inform yourself about the privacy framework of our application.

5. How long we keep your data

The statutory retention period is the criteria used to determine that amount of time that personal data will be stored. The corresponding data is routinely deleted before the expiry of this retention period, as long as it is no longer necessary for the fulfilment or initiation of a contract or for other legal means.
As the data controller, we will process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage as is granted under the GDPR 2016/ 679 or any third country legislation/ regulation we are subject to.
If the storage purpose does not apply, or if a storage period prescribed by the European legislator or another competent legislator expires, personal data will be blocked or erased in accordance with the stated legal requirements.

6. Security Measures

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

7. Your Rights

Under the GDPR you have certain rights. If you want to exercise or discuss any of access rights, please contact us at privacy@marketlogicsoftware.com and please include (i) enough information for us to identify you, (ii)proof or your identity and address, and (iii) let us know to what your request relates. In summary, your rights are the following:

• Your right of information and access

If we are processing your data, you can request to receive access to the personal data we are processing. This means that you can receive a copy of the personal data we hold about you and access to other information including:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed to, such as third countries, which means countries outside the EU or international organisations;
• where possible, the expected period for which the personal data will be stored and if not possible, the criteria that is used to determine that period;
• the existence of the right to request from us the rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data is not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, you have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, you have the right to be informed about the safeguards relating to the information transfer. There might be some rare occasions where we can’t fulfil a request for access (e.g. if this request impacts the rights of another person or company). If we can’t help you, we can still get back to you in a timely fashion and let you know the reason why the request cannot be fulfilled.

• Your right to rectification
• You are entitled to request us to correct any incomplete or inaccurate personal data we hold about you. This rectification will occur swiftly and may include the means of providing a supplementary statement.

Your right to erasure (Right to be forgotten).
In certain circumstances, you can ask us to delete or remove your personal data. There are certain exemptions where we may refuse this request (for instance where personal data is required for compliance with the law or in connection with a legal claim).

• Your right to restrict processing.
• You can ask us to suspend the processing of certain data about you in certain circumstances.
• Your right to data portability.
• You may have the right, to obtain personal information you have provided to us (in a structured, commonly used and machine-readable format) to reuse it elsewhere or ask us to transfer this information to a third party of your choice. This transfer of personal data can be done where it is technically feasible and where doing so does not adversely affect the rights of others.
• Your right to object.
• You may have the right to object to us processing your information in certain circumstances. This applies where we are:
• Processing your information for direct marketing purposes
• Relying on our own or someone else’s legitimate interests to process your personal information, with the exception that we can demonstrate compelling legal grounds to process this information.
• Processing your personal information for research, unless this processing is necessary to perform a task that is carried out in the public interest.
• Your right to withdraw consent.
• If we are relying on your consent as our legal basis for processing your personal data, you have the right to withdraw consent at any time.
• Your right to lodge a complaint with the Supervisory Authority.

As stated above, if you wish to exercise any of these rights, please contact our Data Privacy Officer. You also have the right to submit a complaint with a data protection Supervisory Authority in a Member state of the European Union where you are a resident or where an alleged infringement of Data Protection law has taken place.

8. Third-party functionalities on the website

We may offer functionality from third parties by redirecting you to the third party’s website. While visiting the third-party site, your privacy choices and the data you share with the third party will be subject to the third party’s privacy policy, and not subject to this privacy policy.

8.1 Cookies. Our website makes use of small text files called “cookies”. These cookies are small files that are saved on the hard drive of your computer when you visit our Website. By making use of cookies, we are able to provide you a better overall website experience.
The following cookies are used on this website:
— User-input cookies: these are session cookies that are used to keep track of the user’s input. They are required for the website to work properly. They are temporary files, which are erased when you close your browser.
We do not use any third-party cookies or flash cookies.
You have the option of configuring your Internet browser to notify you when you receive a cookie, allowing you to decide whether to accept it. Further, you can choose to block all cookies. Please note, however, that should you choose to disable cookies you will lose some features and functionality of our website. The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

8.2 Facebook plugin. Our website includes plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For an overview of all the Facebook Plug-ins, see https://developers.facebook.com/docs/plugins/.
When you visit our website, a direct connection between your browser and the Facebook server is established through the plugin. This enables Facebook to receive information that you have visited our site from your IP address. If you click the Facebook “Like button” while you are logged into your Facebook account, you can link the content of our website to your Facebook profile. This allows Facebook to associate your user account with visiting our site.
Through its plugin, Facebook always receives your information when you visit our website if you are logged into Facebook at the time you access our web page. This happens regardless of whether you click on the Facebook component or not. Please note that, as the controller of this website, we do not have knowledge of the content of the data transmitted to Facebook or how Facebook uses this data. If you would like more information, please consult Facebook’s privacy policy at https://facebook.com/about/privacy.
The data protection guideline published by Facebook, which is available at If you do not want Facebook to associate your visit to our site, ensure that you are logged out of your Facebook account when you click on our web page.

8.3 Google Analytics (with anonymization function). Our website uses Google Analytics- a component of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States of America.
Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has comes from, known as the “referrer”. This indicates which sub-pages were visited, or how often and for what duration a sub-page was looked at. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
We have activated the IP anonymization feature on our website. Google shortens your IP address when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyze the traffic on our website. Google consolidates the collected data to provide reports on the use and activity of our website. The IP address that is sent from your browser as a part of Google Analytics will not be merged with other data held by Google.
To see more information and the applicable data protection provisions for Google Analytics, please consult https://www.google.com/intl/en/policies/privacy/ and http://www.google.com/analytics/terms/us.html.

8.4 Google+ plugin. Our website has integrated the Google+ button as a component. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States of America.
Each of our web pages which contain a Google+ button automatically downloads a display of the corresponding Google+ button. During this technical procedure, Google is made aware of what specific sub-page of our website you visited. More detailed information about Google+ is available under https://developers.google.com/+/
If you visit our website at the same time that you are logged into your Google+ account, Google recognizes and collects data on entire duration of your stay on our Internet site, as well as which specific sub-pages of our web pages you visited. This happens regardless of whether you click on the Google+ button.
If you click on the Google+ button integrated on our website to give a Google+ 1 recommendation, Google assigns this information to your personal Google+ user account and stores the personal data- making it publicly available in accordance with the terms and conditions you have with Google+. Further, if you give a Google+ 1 recommendation on this website together with other personal data, such as the Google+ account name and the stored photo, this information is stored and processed on other Google services, such as search engine results of the Google search engine or other places including Internet pages, or in relation to advertisements. Google is also able to link the visit to this website with other personal data stored on Google.
If you do does not wish to transmit personal data to Google, you may prevent such transmission by logging out of his Google+ account before clicking our website.Further information and the data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. More references from Google about the Google+ 1 button may be obtained under https://developers.google.com/+/web/buttons-policy.

8.5 LinkedIn plugin. Our website has integrated the LinkedIn widget as a component. The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, United States of America. For privacy matters outside of the United States, contact LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
By entering into our website, your browser is automatically prompted to download the corresponding LinkedIn plugin. This process gives LinkedIn knowledge of what specific sub-page of our website you have visited. Further information about the LinkedIn plug-in may be accessed at https://developer.linkedin.com/plugins.
If you visit our website while logged into LinkedIn at the same time, LinkedIn detects the specific sub-pages you visit. This information is collected through the LinkedIn component and associated with your respective LinkedIn account. If you click on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to your personal LinkedIn user account and stores the personal data.
LinkedIn receives information via the LinkedIn component that you have visited our website, provided you are logged into your account on LinkedIn at the time you visit our website. This occurs regardless of whether you click on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable to you, then you can prevent this by logging off from your LinkedIn account before a call-up to our website is made.
LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be configured under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy.

8.6 Twitter. Our website has integrated the Twitter button as a component. The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States of America.
By entering into our website, your browser is automatically prompted to download the corresponding Twitter plugin. This process allows Twitter to collect knowledge of the specific sub-page of our website you have visited. Further information about the Twitter plug-in may be accessed at https://about.twitter.com/de/resources/buttons.
If you visit our website while logged into Twitter at the same time, Twitter detects the specific sub-pages you visit and collects information through the Twitter component and your respective Twitter account. If you click on one of the Twitter buttons integrated on our website, then Twitter assigns this information to your personal Twitter user account and stores the personal data in their system.
Twitter receives information that you have visited our website via its component, provided you are logged into Twitter at the time as you enter our website. This occurs regardless of whether you click on the Twitter button or not. If you want to avoid this transmission of information, you can prevent this by logging off your Twitter account before visiting our website.
The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.