Data protection responsibilities

Within the framework of joint responsibility under data protection law, we - the ALVARA | Digital Solutions group of companies - have agreed which company in the group of companies fulfils which obligations in accordance with the GDPR. This concerns in particular the exercise of the rights of the data subjects and the fulfilment of the information obligations pursuant to Art. 13 and 14 GDPR.

This agreement is necessary because personal data is processed in different process stages and systems when designing marketing measures and handling business relationships.

The essential information in the agreement reached is presented here.

What is the reason for joint processing?

In order to promote the group of companies’ product portfolio holistically and to be able to present customers with total solutions, we - the companies of the ALVARA | Digital Solutions group of companies, consisting of

work closely together in the design and execution of marketing activities and product configuration. This also applies to the processing of your personal data. We have jointly determined the purposes and means of processing this data in the individual process stages and are therefore jointly responsible for the protection of your personal data within the process stages described below (Art. 26 GDPR).

The parent company ALVARA Holding GmbH assumes the task of the central administrative unit of the individual subsidiaries of the group of companies.

The subsidiaries offer various products and services from which you can put together an individual overall solution.

For which process stages is there joint responsibility?

Within the group of companies, marketing measures are implemented centrally by the parent company ALVARA Holding GmbH. The purpose and means of the marketing measures are determined by all companies in the group. For example, the group offers a group newsletter and communication tools that provide information about the products, services and current topics of the subsidiaries. Furthermore, corporate events are organised that address the customers, interested parties and business partners of all subsidiaries. In addition, press releases and professional articles are jointly designed within the group of companies, with the additional inclusion of reference partners from the individual companies.

Customers can take advantage of products and services from various companies in the group as a complete solution. In this case, the customer enters into a separate contract with each company whose products and services they wish to use. In order to be able to optimally configure the desired overall solution, the design and implementation of the overall solution is carried out jointly by the participating companies.

Who is responsible for processing within the group of companies and when?

Within the framework of joint responsibility, your personal data is processed within the procedures in the respective process steps by different companies of the group of companies and within different systems of these companies. The responsibilities are shown below.

1. Master data management
   

   Process step	Responsibility
   Collection and transfer of data to ALVARA Holding	The company in direct initial contact with the data subject
   Inclusion of the data in central master data system	ALVARA Holding GmbH
   Use of data	Entire group of companies

2. Marketing measures
   

   Process step	Responsibility
   Receipt of the expression of interest in the marketing measures & transfer to ALVARA Holding	The company in direct initial contact with the data subject
   Collection and management of consents for marketing measures	ALVARA Holding GmbH
   Implementation of the marketing measures	ALVARA Holding GmbH

3. Fulfilment of contractual or pre-contractual business relations (project handling etc.)
   

   Process step	Responsibility
   Conducting the pre-contractual talks	The respective companies involved in the pre-contractual discussions
   Implementation of the contractual obligations	The companies contractually involved in each case

4. Implementation of the web presence (www.digital.alvara.eu)
   

   Process step	Responsibility
   Implementation and adaptation of the web presence	ALVARA Holding GmbH
   Analysis of usage statistics	Entire group of companies

5. Central application procedure
   

   Process step	Responsibility
   Acceptance, recording and forwarding of applications and correspondence with persons concerned (applicants)	ALVARA Holding GmbH
   Procedure Further steps in the application process (selection, evaluation, etc.)	ALVARA Holding GmbH & the company concerned by the job advertisement in each case

Who informs me as a data subject?

Within the joint responsibility, the company of the group of companies that has the first contact with you always fulfils the information obligations pursuant to Art. 13 and 14 GDPR.

Who is responsible for the exercise of my data subject rights?

Within the scope of joint responsibility and respective competences, the companies shall inform each other without delay of the rights asserted by you. They shall provide each other with all information necessary to respond to requests for information.

For the assertion of your data protection rights, the ALVARA Holding GmbH is available to you as a direct contact as the central administrator. However, you are free to assert your rights against any company in the group.

Information about your asserted data protection rights is always provided by ALVARA Holding GmbH.