Legal
Privacy notice
How we handle your personal data and what rights you have.
Last updated: 21 August 2026 This is a translation for convenience; the German version of this privacy notice prevails.
1. Privacy at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on data protection, please refer to the privacy notice set out below this text.
Data collection on this website
Who is responsible for the data collection on this website?
Data processing on this website is carried out by the website operator. You will find their contact details in the section “Information on the controller” in this privacy notice.
How do we collect your data?
Your data is collected, first, by you providing it to us. This may be data you enter into a contact form, for example.
Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or the time of the page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour.
What rights do you have regarding your data?
You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data. You also have a right to request the rectification or erasure of this data. If you have given consent to data processing, you can withdraw that consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. You further have a right to lodge a complaint with the competent supervisory authority.
You can contact us at any time regarding this and any further questions on the subject of data protection.
Analysis tools and third-party tools
When you visit this website, your browsing behaviour may be evaluated statistically. This is done primarily with so-called analysis programmes.
Detailed information on these analysis programmes can be found in the following privacy notice.
2. Hosting
We host the content of our website with the following provider:
IONOS
The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter IONOS). When you visit our website, IONOS records various log files including your IP addresses. For details, please refer to the IONOS privacy notice: https://www.ionos.de/terms-gtc/terms-privacy.
IONOS is used on the basis of Art. 6 (1) (f) GDPR. We have a legitimate interest in presenting our website as reliably as possible. Where corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 (1) (a) GDPR and § 25 (1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal equipment (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.
Data processing agreement
We have concluded a data processing agreement (DPA) for the use of the service named above. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
3. General information and mandatory disclosures
Data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection provisions and this privacy notice.
When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy notice explains what data we collect and what we use it for. It also explains how and for what purpose this happens.
We point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.
Information on the controller
The controller for data processing on this website is:
Smart CJM GmbH
Heyenbaumstr. 139-141
47802 Krefeld, Germany
Phone: +4921514474700
Email: [email protected]
The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses or similar).
Storage period
Unless a more specific storage period is stated within this privacy notice, your personal data remains with us until the purpose for the data processing no longer applies. If you assert a justified request for erasure or withdraw consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion takes place once those grounds cease to apply.
General information on the legal bases for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, where special categories of data pursuant to Art. 9 (1) GDPR are processed. In the case of express consent to the transfer of personal data to third countries, data processing additionally takes place on the basis of Art. 49 (1) (a) GDPR. If you have consented to the storage of cookies or to access to information in your terminal equipment (e.g. via device fingerprinting), the data processing additionally takes place on the basis of § 25 (1) TDDDG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for pre-contractual measures, we process your data on the basis of Art. 6 (1) (b) GDPR. We further process your data where it is necessary for compliance with a legal obligation on the basis of Art. 6 (1) (c) GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Art. 6 (1) (f) GDPR. The legal bases relevant in each individual case are set out in the following paragraphs of this privacy notice.
Data protection officer
We have appointed a data protection officer.
Jens Wagner EDV-Beratung
Im Bremerkamp 11
46535 Dinslaken, Germany
Email: [email protected]
Information on data transfers to third countries that are not secure under data protection law and on transfers to US companies that are not DPF-certified
Among other things, we use tools from companies based in third countries that are not secure under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in those countries. We point out that in third countries that are not secure under data protection law, a level of data protection comparable to that of the EU cannot be guaranteed.
We point out that the USA, as a secure third country, generally has a level of data protection comparable to that of the EU. A transfer of data to the USA is therefore permissible if the recipient holds a certification under the “EU-US Data Privacy Framework” (DPF) or has suitable additional safeguards in place. Information on transfers to third countries, including the recipients of the data, can be found in this privacy notice.
Recipients of personal data
In the course of our business activities we work with various external bodies. This sometimes also requires the transfer of personal data to these external bodies. We only pass personal data on to external bodies where this is necessary for the performance of a contract, where we are legally obliged to do so (e.g. passing data to tax authorities), where we have a legitimate interest in the transfer pursuant to Art. 6 (1) (f) GDPR, or where another legal basis permits the transfer. Where processors are used, we pass on our customers’ personal data only on the basis of a valid data processing agreement. In the case of joint processing, a joint controller agreement is concluded.
Withdrawal of your consent to data processing
Many data processing operations are only possible with your express consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out up to the withdrawal remains unaffected by the withdrawal.
Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)
If data processing takes place on the basis of Art. 6 (1) (e) or (f) GDPR, you have the right at any time to object, on grounds relating to your particular situation, to the processing of your personal data; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy notice. If you object, we will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (objection pursuant to Art. 21 (1) GDPR).
If your personal data is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is connected with such direct marketing. If you object, your personal data will subsequently no longer be used for the purposes of direct marketing (objection pursuant to Art. 21 (2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of infringements of the GDPR, data subjects have a right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged infringement. This right to complain exists without prejudice to any other administrative or judicial remedy.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place insofar as it is technically feasible.
Information, erasure and rectification
Within the framework of the applicable statutory provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to rectification or erasure of this data. You can contact us at any time regarding this and any further questions on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us about this at any time. The right to restriction of processing exists in the following cases:
- If you contest the accuracy of the personal data we hold about you, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data happened or is happening unlawfully, you can request the restriction of the data processing instead of erasure.
- If we no longer need your personal data but you need it for the exercise, defence or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
- If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may — apart from being stored — only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a member state.
SSL / TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the browser address bar changes from “http://” to “https://” and by the padlock symbol in your browser bar.
When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
4. Data collection on this website
Cookies
Our web pages use so-called “cookies”. Cookies are small data packets and do no harm to your terminal equipment. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are deleted automatically at the end of your visit. Persistent cookies remain stored on your device until you delete them yourself or until your web browser deletes them automatically.
Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable certain services of third-party companies to be integrated within web pages (e.g. cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies may be used to evaluate user behaviour or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. the shopping basket function) or to optimise the website (e.g. cookies for measuring the web audience) — necessary cookies — are stored on the basis of Art. 6 (1) (f) GDPR unless another legal basis is stated. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing takes place exclusively on the basis of that consent (Art. 6 (1) (a) GDPR and § 25 (1) TTDSG); consent can be withdrawn at any time.
You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be limited.
Which cookies and services are used on this website can be found in this privacy notice.
Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser transmits to us automatically. These are:
- browser type and browser version
- operating system used
- referrer URL
- host name of the accessing computer
- time of the server request
- IP address
This data is not merged with other data sources.
This data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website — for this purpose the server log files must be recorded.
Contact form
If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provide there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass this data on without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR where your enquiry is connected with the performance of a contract or is necessary for pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) where this has been requested; consent can be withdrawn at any time.
The data you enter in the contact form remains with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your enquiry has been dealt with). Mandatory statutory provisions — in particular retention periods — remain unaffected.
Enquiry by email, telephone or fax
If you contact us by email, telephone or fax, your enquiry including all resulting personal data (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR where your enquiry is connected with the performance of a contract or is necessary for pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) where this has been requested; consent can be withdrawn at any time.
The data you send us via contact enquiries remains with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your request has been dealt with). Mandatory statutory provisions — in particular statutory retention periods — remain unaffected.
5. Analysis tools and advertising
Matomo
This website uses the open source web analytics service Matomo.
Matomo enables us to collect and analyse data about the use of our website by website visitors. Among other things, this allows us to find out when which page views took place and which region they came from. We also record various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors carry out certain actions (e.g. clicks, purchases and the like).
This analysis tool is used on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its web offering and its advertising. Where corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 (1) (a) GDPR and § 25 (1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal equipment (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.
IP anonymisation
When analysing with Matomo we use IP anonymisation. Your IP address is shortened before the analysis so that it can no longer be clearly attributed to you.
Cookieless analysis
We have configured Matomo so that it does not store any cookies in your browser.
Hosting
We host Matomo exclusively on our own servers, so that all analysis data remains with us and is not passed on.
7. Audio and video conferencing
Data processing
For communication with our customers we use, among other things, online conferencing tools. The individual tools we use are listed below. If you communicate with us by video or audio conference over the internet, your personal data is collected and processed by us and by the provider of the respective conferencing tool.
The conferencing tools record all data that you provide or use in order to use the tools (email address and/or your telephone number). The conferencing tools also process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other “context information” in connection with the communication process (metadata).
The provider of the tool also processes all technical data required to handle the online communication. This includes in particular IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.
Where content is exchanged, uploaded or otherwise made available within the tool, it is also stored on the servers of the tool providers. Such content includes in particular cloud recordings, chat and instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared during use of the service.
Please note that we do not have full influence over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider. Further information on data processing by the conferencing tools can be found in the privacy notices of the tools used, which we have listed below this text.
Purpose and legal bases
The conferencing tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 (1) (b) GDPR). The use of the tools also serves to simplify and speed up communication with us or our company in general (legitimate interest within the meaning of Art. 6 (1) (f) GDPR). Where consent has been requested, the tools in question are used on the basis of that consent; consent can be withdrawn at any time with effect for the future.
Storage period
The data we collect directly via the video and conferencing tools is deleted from our systems as soon as you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.
We have no influence over the storage period of your data that is stored by the operators of the conferencing tools for their own purposes. For details, please enquire directly with the operators of the conferencing tools.
Conferencing tools used
We use the following conferencing tools:
TeamViewer
We use TeamViewer. The provider is TeamViewer Germany GmbH, Jahnstr. 30, 73037 Göppingen, Germany. For details on data processing, please refer to TeamViewer’s privacy notice: https://www.teamviewer.com/de/datenschutzerklaerung/.
Data processing agreement
We have concluded a data processing agreement (DPA) for the use of the service named above. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
Microsoft Teams
We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the privacy statement of Microsoft Teams: https://privacy.microsoft.com/en-gb/privacystatement.
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.
Data processing agreement
We have concluded a data processing agreement (DPA) for the use of the service named above. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
8. Our own services
Handling of applicant data
We offer you the opportunity to apply to us (e.g. by email, by post or via an online application form). Below we inform you about the scope, purpose and use of the personal data collected from you during the application process. We assure you that the collection, processing and use of your data takes place in accordance with applicable data protection law and all other statutory provisions and that your data is treated in strict confidence.
Scope and purpose of the data collection
If you send us an application, we process the personal data associated with it (e.g. contact and communication data, application documents, notes taken during interviews, etc.) insofar as this is necessary for the decision on establishing an employment relationship. The legal basis for this is § 26 BDSG under German law (initiation of an employment relationship), Art. 6 (1) (b) GDPR (general initiation of a contract) and — where you have given consent — Art. 6 (1) (a) GDPR. Consent can be withdrawn at any time. Within our company, your personal data is passed on exclusively to persons involved in processing your application.
If the application is successful, the data you submitted will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6 (1) (b) GDPR for the purpose of carrying out the employment relationship.
Retention period of the data
If we cannot make you a job offer, you reject a job offer or you withdraw your application, we reserve the right to retain the data you transmitted on the basis of our legitimate interests (Art. 6 (1) (f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). The data is then deleted and the physical application documents are destroyed. Retention serves in particular as evidence in the event of a legal dispute. If it is apparent that the data will be required after the 6-month period has expired (e.g. because of impending or pending litigation), deletion only takes place once the purpose for further retention no longer applies.
Longer retention may also take place if you have given corresponding consent (Art. 6 (1) (a) GDPR) or if statutory retention obligations preclude deletion.
Inclusion in the applicant pool
If we do not make you a job offer, there may be the option of including you in our applicant pool. If you are included, all documents and details from the application are transferred to the applicant pool so that we can contact you in the event of suitable vacancies.
Inclusion in the applicant pool takes place exclusively on the basis of your express consent (Art. 6 (1) (a) GDPR). Giving consent is voluntary and bears no relation to the ongoing application procedure. The data subject can withdraw their consent at any time. In that case the data is irrevocably deleted from the applicant pool, unless there are statutory grounds for retention.
The data in the applicant pool is irrevocably deleted no later than two years after consent was given.
Presence on social networks
Data processing by social networks
We maintain publicly accessible profiles on social networks. The individual social networks we use can be found below.
Social networks such as Facebook, X and others can generally analyse your user behaviour comprehensively when you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). Visiting our social media presences triggers numerous processing operations relevant to data protection. In detail:
If you are logged into your social media account and visit our social media presence, the operator of the social media portal can attribute this visit to your user account. Under certain circumstances, however, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In that case this data is collected, for example, via cookies stored on your device or by recording your IP address.
With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you inside and outside the respective social media presence. If you have an account with the respective social network, the interest-based advertising can be displayed on all devices on which you are logged in or have been logged in.
Please also note that we cannot trace all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and privacy policies of the respective social media portals.
Legal basis
Our social media presences are intended to ensure the most comprehensive presence on the internet possible. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which must be stated by the operators of the social networks (e.g. consent within the meaning of Art. 6 (1) (a) GDPR).
Controller and exercise of rights
If you visit one of our social media presences (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during that visit. In principle, you can exercise your rights (information, rectification, erasure, restriction of processing, data portability and complaint) both against us and against the operator of the respective social media portal (e.g. against Facebook).
Please note that despite the joint responsibility with the social media portal operators, we do not have full influence over the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.
Storage period
The data we collect directly via the social media presence is deleted from our systems as soon as you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory provisions — in particular retention periods — remain unaffected.
We have no influence over the storage period of your data that is stored by the operators of the social networks for their own purposes. For details, please enquire directly with the operators of the social networks (e.g. in their privacy policy, see below).
Your rights
You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data. You also have a right to object, a right to data portability and a right to lodge a complaint with the competent supervisory authority. You can also request the rectification, blocking, erasure and, under certain circumstances, the restriction of the processing of your personal data.
We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
The transfer of data to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.
For details of how they handle your personal data, please refer to Instagram’s privacy policy: https://privacycenter.instagram.com/policy/.
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information from the provider at the following link: https://www.dataprivacyframework.gov/participant/4452
We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.
If you would like to deactivate LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
The transfer of data to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.
For details of how they handle your personal data, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information from the provider at the following link: https://www.dataprivacyframework.gov/participant/5448
This notice is based on the privacy notice template by e-recht24.de (version of 31 October 2024).