1. Scope of Application

This Personal Data Protection Basic Policy is part of DENPAFLUX GmbH’ Privacy Policy and describes the general rules on how DENPAFLUX GmbH process personal data.

2. Personal Data Processing Principles

DENPAFLUX GmbH processes personal data in accordance with the following principles.

2.1 Lawfulness, Fairness and Transparency
Personal data are processed on basis of the applicable legal permission and in compliance with applicable laws (lawfulness), in consideration of the interests of the affected individual (fairness) and together with reasonable provision of information including the identity of the legal person that controls and is accountable for the processing of personal data (data controller), the purpose of the processing, associated risks, and necessary safeguards (transparency);

2.2 Purpose Limitation
Personal data are processed for a specified, explicit and legitimate purpose and are no further processed in a manner that is incompatible with that purpose;

2.3 Data Minimization
Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed; Accuracy: Personal data are kept accurate and, where necessary, up to date; every reasonable step is taken to ensure that personal data that are inaccurate in respect to the purpose for which they are processed, are erased or rectified without delay;

2.4 Storage Limitation
Personal data are kept in a form which permits identification of the affected individual for no longer than necessary for the purpose for which the personal data are processed;

2.5 Integrity and Confidentiality
Personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Personal data protection is taken into account when new processes are planned and implemented. Technical and organizational measures at DENPAFLUX GmbH are continuously adjusted.

3. Business Partner Data

In course of its business operations, DENPAFLUX GmbH processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use the DENPAFLUX GmbH Website or third party websites on which DENPAFLUX GmbH has posted advertisements and other current and potential business partners (“Business Partners”). These data may also include personal data of Business Partners and in case Business Partners are corporations, of individuals (e.g. employees) affiliated with Business Partners.

3.1 Data Categories
Data include first, middle and last name, academic title, professional status, position, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the business relationship with DENPAFLUX GmbH.

3.2 Data Sources
Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, e-mails, facsimiles, letters, surveys, data collected via active entries on the DENPAFLUX GmbH Website and other electronic or non-electronic communication and interaction between DENPAFLUX GmbH and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by DENPAFLUX GmbH, data of Users that access, browse or otherwise use Website or third party websites on which DENPAFLUX GmbH has posted advertisements and data received from third parties including TDK Group Companies and other Business Partners in compliance with applicable laws.

3.3 Processing Purposes
Personal data are processed for DENPAFLUX GmbH business operations, including Business Partner relationship management, research and development, manufacturing, enterprise resource planning, data analysis for supply, online and offline marketing and sales activities, market observance and orientation, provision of product and service information, making and answering requests and inquiries, making and accepting quotes, offers, and any communication, cooperation, and other activities reasonably related to DENPAFLUX GmbH business operations. Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. DENPAFLUX GmbH may in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners. DENPAFLUX GmbH conducts such analysis activities to understand the needs of its Business Partners, in particular to enhance, develop, present and provide new products to them, online and offline. Online activities include targeted advertisements on the DENPAFLUX GmbH Website, third party websites and in User accounts, online newsletters by email or other electronic means, promotional campaigns and other activities reasonably related to DENPAFLUX GmbH’s business operations. Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to DENPAFLUX GmbH business operations.

3.4 Permission
Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular the initiation and performance of a contract, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which DENPAFLUX GmbH  is subject to and where the processing of personal data is in the legitimate interest of DENPAFLUX GmbH. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities reasonably related thereto to pursue DENPAFLUX GmbH business operations.

4. Recruitment Data

In course of its business operations, DENPAFLUX GmbH processes data related to the recruitment of new personnel. These data may also include personal data of individuals.

4.1. Data Categories
Data processed include first, middle and last name, academic title, professional status, position, birth date, personal status, work history, current position and former positions, education, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the recruitment of new personnel.

4.2. Data Sources
Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, job applications, emails, facsimiles, letters, meetings, entries on the DENPAFLUX GmbH Website and other electronic or non-electronic communication and interaction between an individual and DENPAFLUX GmbH in the course of a job application. Indirect sources include publicly available data, data of Users that access, browse or otherwise use the DENPAFLUX GmbH Website or third party websites on which DENPAFLUX GmbH has posted advertisements and data received in compliance with applicable laws from third parties including TDK Group Companies and other Business Partners in the course of a recruitment process, e.g. recruiting agencies and HR service providers.

4.3. Processing Purposes
Personal data are processed for searching and recruiting new personnel for DENPAFLUX GmbH business operations including any activities reasonably related thereto.

4.4. Permission
Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular where necessary for the job application and the initiation of an employment relationship with DENPAFLUX GmbH, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which DENPAFLUX GmbH is subject and where the processing of personal data is in the legitimate interest of DENPAFLUX GmbH. Legitimate interests are the processing of the job application to find and recruit skilled personnel for DENPAFLUX GmbH and any activities reasonably related thereto.

5. Website Data and Cookies

For information about the processing of personal data on the DENPAFLUX GmbH Website and third-party websites, please refer to Policy for the Handling of Personal Data on the DENPAFLUX GmbH Websites and to the DENPAFLUX GmbH Cookie Policy

6. Retention Periods

Personal data will be removed from DENPAFLUX GmbH systems and records and/or steps are taken to anonymize data if processing is no longer required for the original purpose unless it is necessary to keep personal data to comply with a legal obligation to which DENPAFLUX GmbH is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws, or where DENPAFLUX GmbH has a legitimate interest in retaining information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. DENPAFLUX GmbH has installed and maintains retention policies in compliance with applicable data protection and other laws.

7. Transfer of Personal Data

DENPAFLUX GmbH is part of the 835labs GmbH with joint business operations. DENPAFLUX GmbH may transfer data including personal data to 835labs GmbH , TDK Group Companies, Business Partners, courts, law enforcement agencies and other third parties, which may have access to and/or process personal data. Transfers are made on a need to know basis in compliance with applicable laws and agreements with Business Partners.

7.1 Transfer to 835labs 
The purpose of data transfers to 835labs GmbH is the support of business operations of DENPAFLUX GmbH through the joint utilization of data. This may include joint business operations and the outsourcing of internal functions and the utilization of external resources, e.g. procurement and manufacturing, marketing, data analysis, Business Partner relationship management, research and development, education, administration, IT functions, HR functions, compliance with corporate organization and corporate governance rules and other activities reasonably related to DENPAFLUX GmbH business operations. Categories of personal data transferred are described in 3. and 4. above. 835Labs that act as service providers are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by DENPAFLUX GmbH. The same applies to any sub-providers of DENPAFLUX GmbH service providers.

7.2 Transfer to Business Partners
Purpose of data transfers to Business Partners is to outsource internal functions and utilize external resources, e.g. IT services, HR, recruiting, marketing activities, marketing data analysis, administration of campaigns, offline and online advertisement, publishing, design, legal, tax, financial advisory services and other activities reasonably related to DENPAFLUX GmbH ’business operations. Business Partners that act as service providers for DENPAFLUX GmbH are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by DENPAFLUX GmbH. The same applies to any sub-providers of DENPAFLUX GmbH’ service providers.

7.3 Transfer to government authorities, courts, law enforcement agencies
Purpose of data transfer to government authorities, courts, law enforcement agencies and other public bodies is to comply with obligations to which DENPAFLUX GmbH is subject to under applicable laws, e.g. transfer and disclosure obligations under social security law, civil procedure law, tax, import and export laws.

8. Transfer of Personal Data to Countries outside the EU

To the extent personal data are transferred to and processed in other countries than where DENPAFLUX GmbH is established, DENPAFLUX GmbH transfers personal data in compliance with applicable laws and has established appropriate safeguards by means of data processing and data transfer agreements that oblige the recipient in the other country to establish and adhere to an adequate level of data protection. Qualified service providers (e.g. IT service providers, marketing agencies) are used for the operation, optimization and protection of the DENPAFLUX GmbH Website. When certain tools are used, data may be transferred to recipients outside the EU, where there is not the same level of data protection as provided in the EU in accordance with the GDPR (e.g. USA). More detailed information on the service providers is provided in the DENPAFLUX GmbH Cookie Policy

9. Information Obligations

In compliance with applicable laws, DENPAFLUX GmbH informs individuals about the personal data processing activities as described in the the DENPAFLUX GmbH Cookie Policy. Both online and offline, DENPAFLUX GmbH refers individuals to the DENPAFLUX GmbH Website for information on data protection activities.

10. Consent and Withdrawal of Consent

Where required under applicable data protection and other laws, DENPAFLUX GmbH processes any data only after obtaining consent. Providing consent and data is voluntary. Before obtaining consent, DENPAFLUX GmbH will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with DENPAFLUX GmbH in respect to DENPAFLUX GmbH’ business operations. Consent can be withdrawn at any time with future effect by emailing team@mitai.ai. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

11. Rights of Individuals

Where DENPAFLUX GmbH processes personal data of individuals, each individual may exercise its rights under applicable laws. Any rights can be exercised by sending an email to team@mitai.ai or using the contact details provided under section 12 below. or using the contact details provided under section 12 below. In addition, each individual may lodge a complaint with a competent data protection supervisory authority. Any individual may exercise towards DENPAFLUX GmbH the following rights: (i) Right of access, (ii) Right of rectification, (iii) Right to erasure, (iv) Right to restriction of processing, (v) Right to object to processing, (vi) Right to data portability. Where DENPAFLUX GmbH processes personal data for direct marketing purposes, each individual has the right to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling to the extent related to marketing purposes.

12. DENPAFLUX GmbH Personal Data Protection Organization

DENPAFLUX GmbH is committed to the protection of personal data and privacy rights. If you have any questions about the processing of your personal data, in particular regarding your data subject rights and the right to object to a particular data processing activity or the right to withdraw your consent, you may contact DENPAFLUX GmbH: Rosenheimer Strasse 116a, 81669 Munich, Germany or team@mitai.ai. 

13. Change Management

DENPAFLUX GmbH may change the Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on DENPAFLUX GmbH Websites and the DENPAFLUX GmbH Cookie Policy at any time and without explicit notice. The enactment date and the date of the last revision is shown in the respective document and any prior versions can be requested from DENPAFLUX GmbH

1. Scope of Application

This Policy for the Handling of Personal Data on DENPAFLUX GmbH is part of DENPAFLUX GmbH Privacy Policy. It describes how DENPAFLUX GmbH processes data of users that access, browse or otherwise use the DENPAFLUX GmbH Website, DENPAFLUX GmbH services or third party websites on whichDENPAFLUX GmbH Services has posted advertisements (“Users”). These data include also personal data that Users actively send, transmit or otherwise provide on DENPAFLUX GmbH’s website and that DENPAFLUX GmbH collects or otherwise obtains via cookies. For detailed information about the use of cookies please refer to the DENPAFLUX GmbH Cookie Policy.

2. Purposes

DENPAFLUX GmbH processes data for its Services (3. below) and Marketing (4. below) only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, DENPAFLUX GmbH will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use the DENPAFLUX GmbH Website but may not able to benefit from some or all of the Services. Regarding the withdrawal of consent and other rights of Users, please refer to the Personal Data Protection Basic Policy.

3. Services

DENPAFLUX GmbH processes data including personal data for providing the following services in connection with its business operations (“Services”).

3.1 Inquiries and Requests
DENPAFLUX GmbH offers the possibility to make online inquiries and requests regarding its products and services and strives to revert to the inquirer in due time.

3.2 Promotional Campaigns
DENPAFLUX GmbH invites Users to take part in online promotional and other campaigns to bring DENPAFLUX GmbH’ products and services and other information reasonably related to DENPAFLUX GmbH’ business operations to the attention of current and potential customers and the wider public. DENPAFLUX GmbH asks individuals to provide their comments and opinions about DENPAFLUX GmbH’ products and services. DENPAFLUX GmbH may also send materials and samples and other giveaways and information offline to Users participating in the campaigns.

3.3 Recruitment
DENPAFLUX GmbH may offer information about job vacancies of any kind on its website and invite individuals to file applications via DENPAFLUX GmbH’ website.

4. PC and Mobile Application Software

DENPAFLUX GmbH offers software for specific services and functions alone or together with DENPAFLUX GmbH’ products, services and other activities reasonably related to DENPAFLUX GmbH’ business operations. DENPAFLUX GmbH provides certain support services like software and firmware support. Software applications may create crash reports that helpDENPAFLUX GmbH and third-party software developers to resolve any issues with the software.

5. Marketing

For its marketing activities DENPAFLUX GmbH processes data that Users have actively sent, transmitted or otherwise provided on the DENPAFLUX GmbH Website for Services (see 3. above) and that DENPAFLUX GmbH have collected or otherwise obtained via cookies from its and third-party websites where DENPAFLUX GmbH has posted advertisements. For detailed information about the use of cookies, please refer to the DENPAFLUX GmbH Cookie Policy. DENPAFLUX GmbH analyses such data alone or in combination or together with other data including personal data DENPAFLUX GmbH has lawfully received. Data analysis activities may comprise automated processing including profiling. DENPAFLUX GmbH may, in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Users. DENPAFLUX GmbH conducts such analysis to understand the needs of the Users, in particular to enhance, develop, present and provide new products to them, online and offline. Online activities include targeted advertisements on the DENPAFLUX GmbH Website, third party websites and in User accounts, online newsletters by email or other electronic means, promotional campaigns and other activities reasonably related to DENPAFLUX GmbH’ business operations. Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to DENPAFLUX GmbH’ business operations.