Privacy Policy Interconnection Flex

I. General
InterconnectionFlex is a Product of the DE-CIX Management GmbH. We, the DE-CIX Management GmbH, Lichtstrasse 43i, 50825 Cologne (hereinafter referred to as “DE-CIX”), take the protection of your personal data very seriously, and we strictly comply with the regulations of the data protection statutes. The following declaration provides you with an overview as to how we ensure this protection. In particular, we would like to explain to you – as a visitor to our website, a subscriber to our newsletter, as a guest at one of our numerous events, or as an applicant to DE-CIX – which types of data we gather, why we collect these types of data, how we use this data, and how you at any and all times can determine how your personal data is treated.
According to the General Data Protection Regulation (GDPR) you have various rights which you can assert in relation to us. This includes, among others, the right to withdraw consent to the processing of data, in particular data processing for the purposes of marketing. The possibility to withdraw consent is typographically highlighted.
Should you have questions regarding this Privacy Policy, you can contact our company data protection officer at any time. The contact details can be found below.
II. Name and contact details of the person responsible for processing and the company data protection officer
This Privacy Policy applies to the processing of data by DE-CIX Management GmbH, Lichtstrasse 43i, 50825 Köln (“person responsible”).
Our company data protection officer, Mr. Jan Stumpf, can be contacted via the email address dataprotection@de-cix.net, by post to: DE-CIX Management GmbH, Mr. Jan Stumpf, Lichtstrasse 43i, 50825 Cologne, with the keyword “Data Protection,” or by fax at the number +49 (221) 70 00 48-111.
III. Purpose of data processing, legal basis, and legitimate interests that are pursued by DE-CIX or a third party, and categories of recipients
1. Surfing on this website
DE-CIX gathers and automatically stores log file information in its server, which your browser deposited with us while you were surfing.
In brief, here is the key data that we store:
• Type of browser/browser version
• The operating system used
• Referrer URL (the page visited previously)
• URLs / pages on this website that have been accessed
• IP address of the accessing computer along with its name
• Time of the server request
• Visitor history, which we sometimes consolidate with comparable information about other visitors and depict in a form that cannot be personally identified in features like top content.
Furthermore, we record the complete Uniform Resource Locator (URL) clickstream through and from our website, in anonymized form – i.e. the order of the pages on our internet presence that you access, including date and time, cookie or Flash-cookie number, the content that you looked at or that you searched for.
During your visits, we sometimes use JavaScript in order to gather and evaluate information, including the time it takes a website to load, download errors, the duration of the visit on a subpage, information regarding the interaction between pages (e.g. scrolling, clicking, mouse-overs) and leaving the page.
The legal basis for the processing of the IP address is Article 6, Para 1f) of the GDPR. Our legitimate interest results from the following list of purposes of the data processing. Please note on this point that it is not possible for us to draw any direct conclusions about your identity on the basis of the data collected, nor do we attempt to draw such conclusions.
The IP address of your device and the remaining data listed above is used by us for the following purposes:
• Ensuring a seamless establishment of the connection
• Ensuring the comfortable use of our website
• Assessing the system security and stability.
The data is saved for a period of 7 days, after which it is automatically deleted or anonymized. IP addresses are anonymized by deleting the last 3 digits.
Further, we make use of so-called cookies and tracking tools for our website. Exactly what process is undertaken and how your data is used for these is clarified in Section III.4. below.
2. Data processing for marketing purposes
The following information concerns the processing of personal data for marketing purposes. The GDPR declares such data processing on the basis of Article 6 Para. 1f) as conceivable in principle and to be a legitimate interest. The duration of data storage for marketing purposes does not follow any strict precepts and is oriented around the question of whether the storage is necessary for marketing purposes. How this proceeds in the case of the withdrawal of your consent is clarified in section III.2.3.
2.1. Marketing purposes of DE-CIX
Insofar as you have concluded a contract with us regarding participation in an event, we will process your postal contact address apart from of a concrete declaration of consent, in order to occasionally in this way provide you with news on the company or forthcoming events. We process your email address in order to provide you with information regarding our own similar products apart from of a concrete declaration of consent.
2.2. Marketing on the basis of interests
To ensure that you only receive marketing information for which you are putatively interested, we categorize and supplement your customer profile with further information. For this, both statistical information and information regarding your person (e.g. the basic data of your customer profile) is used. The objective is to only provide you with marketing that is oriented to your actual or putative needs and not to burden you with unnecessary marketing.
2.3. Right to withdraw consent
You can withdraw your consent to the data processing for the purposes set out above at any time, without incurring costs, for each channel independently, and with effect for the future. For this, an email or letter to the contact details listed in Section II suffices. There are no costs other than the transmission costs according to the basic tariffs.
Insofar as you withdraw consent, the affected contact addresses will be blocked for further marketing-related data processing. Please note that in exceptional cases, it is possible that further sending of marketing material may take place temporarily, even after receiving your withdrawal of consent. This is technically due to the necessary lead-in time for advertisements and does not mean that we will not comply with your objection. Thank you for your understanding.
3. Contactform and Email Contact
On our website, you have the option of getting in contact with us via a contact form or via email. The information you impart via the contact form is usually:
• Surname
• First-name
• Email
• Phone
• Company
• Function
The personal data imparted to us will be used exclusively for the purpose of processing your enquiry and will be deleted after processing your query. The legal basis for this is your consent within the meaning of Art. 6 No. 1) a GDPR, as well as Art. 6 No. 1) f GDPR. The proper processing of your enquiry is to be regarded as a legitimate interest within the meaning of the GDPR. You can withdraw your consent to the processing of the personal data imparted to us at any time with effect for the future, using the contact information provided under II. From the moment of withdrawal, it will no longer be possible to process your enquiry.
4. Online Presence on Social Media
In addition to this website, we also maintain an online presence on the social media channels Facebook, Twitter, Xing, Linked-in, and Youtube. You can access these by clicking on the corresponding menu items on our website.
We would like to point out that your use of these pages and their functions lies within your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating).
When visiting such a page, personal data may be transferred to the provider of the social media channel. The social media provider collects and processes your IP address, the type of processor and browser version used, including plug-ins and, where applicable, other information.
The data collected about you in this context will be processed by the provider of the social media channel and in some instances may be transferred to countries outside of the European Union.
If you are logged in with your personal user account of the respective channel during your visit to such a website, this channel can assign the visit to your account.
If you wish to avoid this, you should log out of the social media channel before visiting our online presence or deactivate the “remain logged in” function, delete the cookies present on your device, and exit and restart your browser. In this way, information which could be used to directly identify you is deleted.
The purpose and scope of the data collection and the further processing and use of the data by the provider of the respective social media channel, as well as your relevant rights and setting options for the protection of your privacy, can be found under the respective privacy policy information of the respective medium:
Facebook: https://de-de.facebook.com/about/privacy/
Twitter: https://twitter.com/privacy?lang=de
Xing: https://www.xing.com/privacy
Linked-In: https://www.linkedin.com/legal/privacy-policy
Youtube: https://www.google.de/intl/de/policies/privacy/
As the operator of the respective online presence, we do not collect or process any further data from your use of the corresponding social media channel.
5. Online presence and website optimization
5.1. Cookies
Our Internet sites use so-called cookies at numerous points. Insofar as these cookies contain personal data, the use of these takes place on the basis of Article 6 Para 1f) of the GDPR. Our interest in optimizing is thereby to be seen as legitimate in the sense of the aforementioned regulation. Cookies are small text files that are automatically generated by your browser and saved on your device (laptop, tablet, smartphone, etc.). Cookies do not cause any damage to your device and they do not contain any viruses, Trojans, or other malware. In the cookie, information is stored which results from the connection with each specific device respectively. However, this does not mean that we gain any direct knowledge regarding your identity. The use of cookies serves on the one hand the purpose of improving the user experience of our Internet presence. We therefore use so-called “session cookies” in order to recognize that you have already visited individual pages on our website. These are deleted automatically after the end of your visit. In addition to this, also for the purpose of increasing user-friendliness, we make use of temporary cookies that are saved on your device for a specific period of time. When you visit our website again, it will be automatically recognized that you have visited the site previously, and what input you made or settings you activated, so that you do not have to input them again.
These cookies are automatically deleted after a respectively defined period of time. You can, however, configure your browser so that no cookies are stored on your computer, or so that a warning always appears before a new cookie is created. However, the complete deactivation of cookies can result in your not being able to use all functions on our website. The storage duration of the cookies is dependent on their purpose and is not the same for all.
5.2. Google Analytics
For the purposes of needs-oriented design and continual optimization of our webpages, we use Google analytics, a web analytics service from Google Inc (“Google”) on the basis of Article 6, Para 1f) of the GDPR. In conjunction with this, anonymized usage profiles are generated and cookies are used. The information generated through the cookie about your use of this website, such as
• Browser type/version,
• Operating system in use,
• Referrer URL (the previously visited website),
• Host name of the computer accessing the site (IP address),
• Time of the service request,
is transferred to and stored on a Google server in the USA. The information is used in order to analyze the use of the website, create reports on website activities, and to deliver further services in connection with the use of the Internet for the purposes of market research and the needs-oriented design of these webpages. This information is also, if necessary, forwarded to third parties, insofar as this is required by law or data processing is outsourced to said third party. Under no circumstances will your IP address be merged with any other data from Google. The IP addresses are anonymized, so that correlation is not possible (so-called IP masking). You can prevent cookies from being saved by using the corresponding settings in your browser software; however, we wish to inform you that, in that case, this may result in you not being able to make complete use of all functions on this website. You can also prevent the collection of data by Google related to your use of the website (including your IP address) generated through this cookie, and the processing of this data by Google, by downloading and installing the Browser-Plugin available here.
You can also prevent data collection by Google Analytics by clicking on the following link. This will set an Opt-Out cookie, which will prevent the future collection of your data when visiting this website:
Deactivate Google Analytics for this website
Further information regarding data protection in connection with Google Analytics can be found on the Google Analytics website.
IV. Your rights
1. Overview
Alongside the right to withdraw the consent given to us, you also have the following rights, when the respective legal conditions are extant:
• Right of information regarding your personal data stored by us in accordance with Article 15 of the GDPR; in particular, you can obtain information about the purpose of processing, the category of personal data, the category of recipient for whom your data is or has been made available, the planned period of retention, the origin of your data, insofar as it was not collected directly from you,
• Right of rectification of erroneous or to completion of correct data in accordance with Article 16 of the GDPR,
• Right to deletion of your data stored by us in accordance with Article 17 of the GDPR, insofar as there are no legal or contractual requirements to retain the data, or other legal obligations or rights to the continued retention of the data,
• Right to limit the processing of your data in accordance with Article 18 of the GDPR, insofar as you dispute the correctness of the data, the processing is illegal, but you oppose the deletion of said data; the data controller no longer requires the data, but you require said data for the assertion, exercise or defense of legal claims, or you have filed an objection to the processing in accordance with Article 21 of the GDPR,
• Right to data portability in accordance with Article 20 of the GDPR, i.e. the right to receive selected data about you stored by us in a standard, machine-readable format, or to have this transmitted to another data controller,
• Right to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your normal place of residence or work, or of our company headquarters to do this.
2. Right to object
Under the conditions of Article 21, Para 1 of the GDPR, the data processing can be objected to on grounds arising out of the special situation of the person affected.
The above general right to object applies for all purposes of processing described in this Privacy Policy that are processed on the basis of Article 6, Para 1f) of the GDPR. In contrast to the special right to object to data processing for marketing purposes (see Section III.3.3. above), we are, according to the GDPR, only obligated to implement such a general right to object if you can provide grounds of superordinate importance (e.g. a possible risk to life or health).
V. Forwarding to third parties
The data collected by us are not sold. We provide information that we obtain to third parties exclusively to the extent described in the following:
1. Affiliated companies
Affiliated companies that are under the control of DE-CIX, if they are either subject to this Privacy Policy or adhere to guidelines that offer at least as much protection as this Privacy Policy.
2. Service providers
We commission other companies and individuals to fulfill tasks for us. Examples include supporting with the organization of events (e.g. competence groups, congresses, or LocalTalks), the sending of letters or emails, the maintenance of our contact lists, the analysis of our data bases, marketing measures (including the making available of search results and links), and the handling of payments (credit cards, bank transfers, and purchase order invoicing). These service providers have access to personal information that is necessary for fulfilling their tasks. However, they are not permitted to use this for other purposes. In addition to this, they are obligated to handle the information in accordance with this Privacy Policy and applicable data protection laws.
3. Protection of DE-CIX and third parties
We disclose personal data when we are legally obliged to do so, or when such disclosure is necessary to protect our rights and those of third parties.
4. Recipients outside of the EU
With the exception of the processing described in section III.4. we do not forward your data to recipients with headquarters outside of the European Union or the European Economic Area. The processing outlined in section III.4. triggers a data transferal to the servers of the newsletter sender commissioned by us. These servers are located in the USA. The data transfer takes place on the basis of the so-called EU-US-Privacy Shield.
VI. Further information and notes
Our website, services, and initiatives evolve continuously. Equally, this Privacy Policy and our conditions of use change on occasion. Therefore, you should regularly visit our website and take note of any changes. Insofar as nothing is regulated in another manner, the use of all information that we have about you is subject to this Privacy Policy. We assure you that significant changes to our Privacy Policy that would result in weakened protection of already collected data will always only be made with your agreement as the respective affected party
Your trust is very important to us. Therefore, we are available to answer your questions at any time regarding the processing of your personal data. If you have questions that could not be answered in this Privacy Policy, or if you would like more detailed information on one of the points, please contact our data protection officer, Mr. Jan Stumpf, at any time at the email address dataprotection@de-cix.net, at the postal address: DE-CIX Management GmbH, Lichtstrasse 43i, 50825, Cologne (keyword “Data Protection”) or by fax to the number +49 (0)221 70 00 48-111.
Cologne, Updated: October 2019