Information about the data protection policies and practices of STRABAG Group companies with respect to the processing of your personal data in conjunction with the sending of newsletters
I. General information
The controller, as defined in Art. 4(7) GDPR, is the STRABAG Group company (hereinafter referred to as STRABAG) sending out the newsletter or in whose name the newsletter is being sent. The name and contact address of the Group company responsible can be found in the imprint section of the newsletter.
II. Name and address of the data protection officer
III. The personal data that will be processed
Personal data means any information referring to an identified or identifiable natural person.
In order to sign up for a newsletter, it is sufficient simply to give us your email address. We ask you, optionally, to give us your title and name for a more personal salutation in the newsletter.
IV. Scope of the data processing and its intended purpose
We send out newsletters, emails and other electronic messages which may contain promotional information (hereinafter referred to as “newsletters”) only with the consent of the recipient or with official permission to do so. Where the contents of the newsletter are specifically described when signing up to receive it, they are material to the users’ consent. Otherwise our newsletters contain, amongst other items, information about the company, its projects, events, construction projects, individuals, offers, seminars and campaigns, as well as general information about our sector.
In this connection, your personal data is processed as outlined below.
- Registration process
If you would like to receive our newsletter, we need a valid email address from you. Furthermore, we ask you to give us a title and your name so that we can address the newsletter to you personally.
Registration for our newsletter is by way of a so-called double opt-in process. This means that, having registered, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure no one can register using other people’s email addresses. The newsletter registrations are logged so as to be able to account for the registration process in line with legal requirements. This includes saving the times of registration and confirmation, as well as the IP address. Changes to the data relating to you held by the dispatch service are also logged.
The logging of the registration process is carried out on the basis of legitimate interest on our part, as set out in Art. 6(1)(1f) GDPR, and proves that consent was given to receive the newsletter
- Dispatch process
The newsletters are in principle always sent out by the dispatch service named in section VI. point 2.
The newsletter is dispatched on the basis of the consent given by yourself in accordance with Art. 6(1)(1a) and Art. 7 GDPR and on the basis of official permission being granted in accordance with Art. 6(1)(1f) in conjunction with section 7(3) Unfair Competition Act (UWG).
You may give notice to cease receiving our newsletter - that is to say, withdraw your consent - at any time. You will find a link to unsubscribe from the newsletter at the end of every newsletter. If users have registered solely to receive the newsletter and then terminate their registration, their personal data will be erased.
- Surveys
We use the email address you have given us to send you links to surveys in which we ask you about your satisfaction with our newsletter.
The legal basis for data processing in this case is Art. 6(1)(1a) and (1f) GDPR.
V. Direct collection of data
STRABAG collects and stores personal data that we have obtained from you.
VI. Data recipients
- Access rights within our organisation
Within STRABAG, the only people who have access to your personal data are those who have an imperative requirement for access in order to be able to dispatch the newsletter as part of their job function and tasks and responsibilities. Depending on the survey, these are generally the contact persons responsible for that survey
The legal basis for data processing in this case is Art. 6(1)(1a) and (1f) GDPR.
- Transmission to external recipients
In addition, we forward your personal data only to those service providers that we have commissioned to provide services to us or who operate/maintain our IT systems.
Our dispatch service provider is Mailingwork GmbH, Birkenweg 7, 09569 Oederan; accordingly, we have a data processing agreement with this provider.
The legal basis for data processing in this case is Art. 6(1)(1a) and (1f) GDPR.
VII. Data processing location
Your personal data is stored in Germany.
VIII. Data erasure
We only store your data for as long as it is required for the purpose for which it was collected and for as long as we have your consent; and for as long as no other legal basis for continuing to process it - in particular, a legal or contractual retention period - arises. This is generally the case when you unsubscribe from the newsletter or withdraw your consent.
IX. Data subjects' rights
In order to exercise your rights, and in the event you wish to complain about an aspect of the processing of your personal data, please contact our data protection officers and/or data protection coordinators (data-protection-de@strabag.com). You can also contact the Group data protection team by emailing data-protection-group@strabag.com.
Every data subject who is a natural person has the following rights:
- the right to information (Art. 15 GDPR)
- the right to rectification of incorrect data (Art. 16 GDPR)
- the right to erasure (Art. 17 GDPR)
- the right to restrict processing of personal data (Art. 18 GDPR)
- the right to data portability (Art. 20 GDPR)
- the right to complain to a data protection supervisory authority (Art. 77 GDPR)
You may object to the processing of your personal data for direct advertising purposes at any time, without stating reasons: this also applies to profiling, where this is linked to such direct advertising.
Furthermore, you have the right, for reasons related to your own particular situation, to object at any time to the processing of personal data concerning your person carried out on the basis of Art. 6(1)(1f) GDPR. In such a case you must state the reasons for your objection; we will cease the processing of your data, unless our interests in processing the data outweigh your interests.
Where your data is being processed on the basis of consent you have given, you may withdraw your consent at any time, which will be effective upon future processing. Please send your cancellation to the email address from which the newsletter was sent. The withdrawal of consent does not affect the lawfulness of the processing of the data up until the revocation, due to the consent that had been given.
X. Status / updates
We will modify this data protection information in the event of changed functionality or a change to the legal basis. We therefore recommend that you review this data protection information at regular intervals. If your consent is necessary, the changes will only take place with your permission.
Status: November 2022