Privacy Notice
The following privacy notice provides an overview regarding the collection and processing of user data. The full information can be found in the Privacy Statement.
What data do we collect from our users?
Access data: When visiting and using our web pages
- Information about the browser type and version used
- The user's operating system
- The user's IP address
- The date and time of access
- Web pages from which the user's system has reached our website
- Internal web pages called up by the user's system via our website
Form data: Based on registration
- Name
- E-mail address
- Address, bank- and accounting details (only for paying user via Chargebee)
- password, which we only store as 'salted hash'
Analysis data: In addition, we collect additional data
We use internet analysis services (Google Analytics) and Inbound-Marketing and Sales Software (HubSpot and Clearbit) to assess the usage of our web page and to optimize our service offering and marketing campaigns. With Google Analytics, the user's IP address is processed and transferred in an anonymized form. We also offer the user to follow-us on different social media platforms via a follow-me-button (Twitter, Facebook and LinkedIn).
What data do we collect from our users?
The access and analysis data are automatically logged during access to our web pages. The form data are collected from what you enter.
What do we use the data from our users for?
We use the access and analysis data in providing our products and services and in optimizing and protecting our web pages. With the consent of our users, we use the form data to respond to contact inquiries, messages and product inquiries (e.g. registration for our product).
Further uses of user data
We also use the data from our users for direct marketing (newsletter or emails on product updates), if the users register for our SaaS-Tool on our web pages. For this, we work in collaboration with Third-Party providers, "MailChimp" and "Hubspot", which process the user data on our behalf. Unsubscribing from our newsletter is possible at any time. We use further tools and services from third-party providers to operate the web page and provide our service. The full list of service providers is contained in the Privacy Statement.
What rights do our users have?
- Information:
Users have the standardized right to information about the personal data being stored about them.
- Erasure:
Users have the right to erasure of their data if these are no longer permitted to be stored.
- Rectification:
Users have a right to rectification of their personal data if we have stored these about users incorrectly.
- Objection:
Users have the right to object and can contact us in this regard (privacy@cawemo.com).
Privacy Statement
Camunda Services GmbH (hereinafter also referred to as "Camunda") is a German provider of services and software in the field of workflow automation. Camunda operates the website cawemo.com that offers a SaaS tool enabling teams to design, discuss and share workflows.
Via this privacy statement, we wish to explain for users which data are required when using the Cawemo web page (“web page”) and Cawemo SaaS app (“Cawemo”), and how we will proceed to use those data if the user browses the webpage.
We take the protection of the personal data of our users very seriously, and we comply with the applicable provisions under data protection law, especially the new General Data Protection Regulation (GDPR) applicable across the EU. We collect, process and use the personal data of our users only if this is essential to respond to their inquiries or to deliver our product and services and insofar as the law permits data processing. This privacy statement is applicable to all services offered in connection with the web pages. If you have any questions or comments about this Privacy Statement, please contact us via privacy@cawemo.com.
I. Name and address of the controller and of its data protection officer
Controller within the meaning of the GDPR, of other data protection laws applicable in the Member States of the European Union and of other provisions having the character of data protection legislation is:
Camunda Services GmbH
Zossener Strasse 55-58
10961 Berlin
Germany
Tel.: +49 30 664 04 09 - 00
E-mail: privacy@cawemo.com
website: https://camunda.com
The Data Protection Officer for Camunda is:
Julian Höppner
JBB Data Consult GmbH
Friedrichstrasse 95
10117 Berlin
Germany
Tel.: +49 30 20962282
E-mail: hoeppner@jbbdataconsult.de
website: www.jbbdataconsult.de
II. Data processing on our web page
1. Web pages and log files
Personal data: Every time our website is visited, our system automatically records data and information from the computer system of the computer making contact.
The following data may be collected for this (access data):
- Information about the browser type and version used
- The user's operating system
- The user's IP address
- The date and time of access
- Web pages and URLs from which the user's system has reached our website
- Internal web pages called up by the user's system via our website
The data are similarly stored in the log files of our system. This data is not correlated with other personal data of the user.
Purpose and legal basis: The temporary storage of the IP address by the system is necessary in order to make it possible to deliver the web pages to the user's computer. For this, the user's IP address needs to remain stored for the duration of the session. Storage takes place in log files, in order to guarantee the functionality of the web pages. In addition, the data help us to optimize the web pages and to ensure the security of our IT systems. We sometimes need to log data more extensively in order to measure the use of Cawemo in terms of use intensity, as this is the basis for our free/ pay for extensive use freemium use and payment model and in order to fix any incidents that may be in the way of providing the best possible service. These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR.
Duration of storage and data erasure: The data are erased as soon as they are no longer necessary for the achievement of the purpose for which they were collected. In the situation of recording data for provision of the web pages, this is the case if the respective session has ended. In the situation of storing the data in log files, this is the case after 6 months at the latest.
Opportunity to object and for removal: The recording of data for provision of the web pages and storage of the data in log files is fundamentally necessary for the operation of the website. There is consequently no opportunity for the user to object.
2. Cawemo cookies (first-party cookies)
Personal data: The Camunda web pages use cookies. Cookies are data stored by the web browser on the user's computer system. The cookies can be transferred to the computer when visiting the website, thus enabling assignment to the user. Camunda uses only technically required cookies.
The following data are stored and transmitted in the technical cookies:
- User and session credentials
Purpose and legal basis: We use an authentication and session cookie to automatically identify the user's browser or his device when he logs in as a registered user. It also serves as an identifier that saves the user from having to log in repeatedly, provided he does not actively log out. At the same time, the cookie serves as a session cookie.
We require cookies for the following applications:
- Security (user is authenticated and content is only delivered to the intended user)
- Optimizing the user experience (user session is saved)
The user data collected via technically necessary cookies are not used to create user profiles. These purposes also constitute our legitimate interest in processing personal data pursuant to Art. 6 (1) (f) GDPR. The services on our website cannot be offered without the use of the session and authentication cookies.
Duration of storage, data erasure, opportunity to object and for removal: Cookies are stored on the user's computer and are sent by that computer to our web page. For that reason, the user also has full control over the use of cookies. The cookie expires when the user logs out or after eight days of inactivity at Cawemo. The user can, of course, also delete the cookie manually at any time. By changing the settings in their web browser, the user can disable or restrict the transmission of cookies. However, if cookies for our web pages are disabled, the user cannot log in to our product.
3. Website analysis services (third-party cookies)
On the web pages Camunda is using Third-Party cookies from Google Analytics, HubSpot, and Clearbit. “Cookies” are text files that are stored on the user’s computer and enable analysis of the use of the web pages by the user.
Used Cookies: The Cookies we use may be either "persistent" cookies or "transient” cookies: a persistent cookie will be automatically deleted after a specified period of time, which may vary depending on the cookie. The user can delete the cookie in the security settings of his browser at any time however. A transient cookie will expire once the user is closing his browser. These include in particular session cookies which are used when the user visits the web page. These store a so-called session ID, with which various requests from the user'´s browser can be assigned to a common session. This will allow the user´s computer to be recognized when he returns to our web page. The types of cookies we are using on our web pages are listed under the respective section of the Third-Party provider.
Opt-Out: The user can prevent the third-party cookies mentioned in the respective section from being stored in the future by placing an opt-out request. The user must click on the “Opt-out from all tracking” button at the following link: https://camunda.com/opt-out/. His opt-out request will set an opt-out cookie in his browser. This serves solely to assign his opt-out request and prevents Camunda from storing cookies on the user's computer in the future. In addition, the user can always configure his browser setting according to his wishes and decline acceptance of either third-party cookies or all cookies. This way he also has the option to delete previously stored cookies. The user should be aware that in these cases he may not be able to use all features of this web page.
a. Google Analytics
The web pages use Google Analytics, a web analysis service of Google Inc. (“Google”).
Personal data: Information generated by the cookie regarding use of these web pages is generally transferred to a Google server in the USA and stored there. As IP anonymization is enabled on our web pages, the user’s IP address is, however, previously abbreviated by Google within the Member States of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional instances is the full IP address transmitted to a Google server in the USA and abbreviated there. Google Analytics processes the data on behalf of Camunda. Google Analytics is certified under the US Privacy Shield. A data
Purpose and legal basis: Google will use this information on behalf of Camunda to evaluate use of the web page by the user, to put together reports on web page activities and to provide additional services connected with use of the web pages and use of the internet for the web page operator. The IP address transmitted as part of Google Analytics by the user’s browser is not put together with other Google data. Google Analytics is used to increase the effectiveness of our web pages and requires the passing-on of data about users to us. Generally, the user’s consent is not obtained for this. However, use of these services is justified via Art. 6 (1) (f) GDPR, because Camunda simplifies and accelerates the handling of the visits by its users to the web pages through the use of Google Analytics.
Duration of storage, data erasure, opportunity to object and for removal: The user is able to prevent storage of cookies via a corresponding setting on their browser software; however, we advise that in that case the user may not be able to use all functions of these web pages to the full extent. In addition, the user can prevent the recording of the data generated by the cookie and relating to their use of the web pages (including their IP address) being sent to Google and the processing of this data by Google by downloading and installing the browser plug-in available from the following link: http://tools.google.com/dlpage/gaoptout.
Overview on the specific cookies from Google Analytics used by Camunda
| Cookie name | Service | Duration | Type | Description |
|---|---|---|---|---|
| _gat | Google Analytics | 1 minute | Persistent | This cookie is used to throttle request rate. |
| _ga | Google Analytics | 2 years | Persistent | This cookie is used to distinguish users. |
| _gid | Google Analytics | 1 day | Persistent | This cookie is used to distinguish users. |
| _gaexp | Google Analytics | Depends on the length of the experiment but typically 90 days. | Persistent | Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in. |
The storage of cookies and the exchange of data with Google Analytics can also be prevented by enrolling in the opt-out option provided above.
b. HubSpot
For our marketing activities (plan, execute and measure integrated marketing campaigns) we are using HubSpot. HubSpot is one of the leading marketing automation platforms worldwide and allows us to analyze the behavior of our prospects and customers and automate and streamline a multitude of marketing operations.
Personal data: Information generated by the cookie regarding use of these web pages may be transmitted to a HubSpot server outside the EU and stored there. Personal data will only be collected and enriched if the user completes a form on this web page. In this case, in addition to the data the user enters himself, his IP address will also be saved. HubSpot processes the data on behalf of Camunda. HubSpot is certified under the US Privacy Shield. A data processing agreement with HubSpot is in place that conforms to the requirements of the GDPR.
Purpose and legal basis: The cookies used by HubSpot enable us to determine the success or failure of a marketing campaign. Before implementing the cookies on our web page, we have balanced our interest of using HubSpot against the interest of our B2B-users not being exposed to cookies. As the implementation of a tracking code on web properties is one of the most basic and commonest practice with all marketing automation software, we assume that the average B2B-user is aware of the usage of such a marketing tool. We focus on product remarketing and only in rare occasions - and limited to data we collect either directly from users or indirectly via data enrichment platforms-, are we carrying out dynamic messaging. Furthermore, HubSpot offers plenty of options to enable opt-out, which we have included in every email that Camunda sends to the user. No sensitive data (only B2B-user personal data) nor data of minors (they are not the target of our webpages/ products) will be processed. The legal basis for processing the data via the use of cookies is hence the legitimate interest pursuant to Art. 6 (1) (f) GDPR.
Duration of storage, data erasure, opportunity to object and for removal: The user is able to prevent storage of cookies via a corresponding setting on their browser software. Further information on data collection, evaluation and processing of the user’s data by HubSpot and on their rights in relation to this can be obtained from HubSpot´s cookies policy, which is available from https://legal.hubspot.com/cookie-policy.
Overview on the specific cookies from HubSpot used by Camunda
| Cookie name | Service | Duration | Type | Description |
|---|---|---|---|---|
| _hssc | Hubspot | 30 minutes | Persistent | This cookie is used to keep track of sessions, number of page views and timestamp. |
| _hssrc | Hubspot | Session duration | Transient | This cookie is set whenever a new session is started. This serves to determine if the user has started a new session. |
| _hstc | Hubspot | 2 years | Persistent | This is the main HubSpot cookie. It contains information about the user (identified by a unique identifier). It stores domains, timestamps and numbers of sessions. |
| hubspotutk | Hubspot | 10 years | Persistent | This cookie contains a user unique identifier, its value gets checked on form submission to avoid duplication of contacts. |
The storage of cookies and the exchange of data with Hubspot can also be prevented by enrolling in the opt-out option provided above.
c. Clearbit
For our marketing activities we also use Clearbit, a data provider, in conjunction with HubSpot to enrich our opt-in database and customize our marketing campaigns via APIs.
Personal data: Information the B2B user is providing via a form will be sentd via HubSpot to Clearbit through an API call, thus helping us to enrich the user´s data with business information. Clearbit processes the data on behalf of Camunda. Clearbit is certified under the US Privacy Shield. A data processing agreement with Clearbit is in place that conforms to the requirements of the GDPR.
Purpose and legal basis: The APIs used by Clearbit enable us to “enrich” or supplement information based on the user’s unique business email, which the user has entered in one of our online forms. Via the prospector functionality we can build a list of specific and relevant contact persons (within the companies that we have targeted for marketing campaigns), which we intend to contact later on via direct marketing mails. Before implementing the cookies on our web page, we have balanced our interest of using Clearbit against the interest of our B2B-users not being exposed to cookies. As Clearbit is a data enrichment and prospecting platform used widely by thousands of companies online, we assume that the average B2B-user is aware of the usage of such a marketing tool. We provide the option to enable opt-out, which we have included in every email that Camunda sends to the user. No sensitive data (only B2B-user personal data) nor data of minors (they are not the target of our webpages/ products) will be processed. The legal basis for processing the data via the use of APIs is hence the legitimate interest pursuant to Art. 6 (1) (f) GDPR.
Duration of storage, data erasure, opportunity to object and for removal: Further information on data collection, evaluation and processing of the user’s data by Clearbit and on their rights in relation to this can be obtained from Clearbit´s privacy statement, which is available to download from: https://clearbit.com/privacy
4. Links to social media platforms
In our website-footer we offer links to the social media platforms Twitter, Facebook,and LinkedIn where you can follow Camunda. We have not implemented Like-, Share- or other social-media-Buttons (Plug-Ins).
If the user uses a follow-me button, indicated using the respective social-media logo, a direct connection with the social-media servers is established by their browser. Information is then transferred to the social-media platform indicating that the page was visited.
Twitter: is a micro-blogging service from the American company Twitter, Inc. (795 Folsom St., Suite 600, San Francisco, CA 94107).Further information on data collection, evaluation and processing of the user’s data by Twitter and on their rights in relation to this can be obtained by the user from Twitter’s privacy statement, downloadable from http://twitter.com/privacy.
LinkedIn: is a business and employment-oriented service (LinkedIn Headquarters 2029 Stierlin Ct. Ste. 200 Mountain View, CA 94043). Further information on data collection, evaluation and processing of the user’s data by LinkedIn and on their rights in relation to this can be obtained by the user from LinkedIn’s privacy statement, downloadable from https://www.linkedin.com/legal/privacy-policy
Facebook: is an American online social media and social networking company based in California (1 Hacker Way, 94025 Menlo Park). Further information on data collection, evaluation and processing of the user’s data by Facebook and on their rights in relation to this can be obtained by the user from Facebook’s privacy statement, downloadable from https://www.facebook.com/legal/FB_Work_Privacy
5. Registering for Cawemo
If the data subject uses the opportunity on the web page to register for Cawemo by entering personal data, the data in the respective input mask are transferred to Camunda.
Personal data: The following data are collected as part of the registration process:
- First name and surname
- E-mail address
- Password
If the user is registering for the commercial version of our Cawemo product (paid seat) he also enters the following data:
- Bank and accounting details
The data in the respective input mask are stored in Cawemo’s internal database. We also transfer the data to MailChimp (https://mailchimp.com) for marketing purposes (newsletter). This company processes the data on behalf of Cawemo. MailChimp is certified under the US Privacy Shield. A commissioned data processing agreement conforming to the requirements of the GDPR exists with MailChimp. The handling of paid seats operates exclusively via our third-party provider Chargebee and Stripe. Those companies process the data on behalf of Camunda. Both are certified under the US Privacy Shield. Agreements for data processing to order with Chargebee and Stripe are in place that conforms to the requirements of the GDPR.
| Third-party Provider | Service | Data processing agreement | Where is user data stored |
|---|---|---|---|
| Chargebee (https://www.chargebee.com/privacy) | Payment system | Data processing agreement in place | Data stored in the US; Standard contractual clauses. Chargebee is also certified under the US-Privacy Shield |
| Stripe (https://stripe.com/us/privacy) | Payment system | Data processing agreement in place | Data stored in the US; Stripe is certified under the US-Privacy Shield |
(The list of Third-party providers may be reduced or extended in the future. We try to update our Privacy Policy correspondingly and timely)
In order to operate and maintain Cawemo and to ensure the continued and best possible operation of Cawemo for the user, to detect and fix any incidents that may be in the way of providing the best possible service, to enable users to communicate with each other and with us, we share the user data with other third-party providers. All third-party providers are either certified under the US Privacy Shield or so-called standard contractual clauses have been signed. Agreements for data processing are in place that conforms to the requirements of the GDPR:
| Third-party Provider | Service | Data processing agreement | Where is user data stored |
|---|---|---|---|
| Pusher (https://pusher.com/legal/privacy) | Communication distributer between users | Data processing agreement in place | Data stored in Irland |
| SparkPost (https://www.sparkpost.com/policies/privacy) | Email-Gateway | Data processing agreement in place | Data stored in the US; SparkPost is certified under the US-Privacy Shield |
| Waffle (https://www.ca.com/us/legal/privacy.html) | Tracking of workflows and issues | Data processing agreement in place | Data stored in the US; Standard contractual clauses. Waffle is also certified under the US-Privacy Shield |
| GitHub (https://help.github.com/articles/github-privacy-statement) | version control system | Data processing agreement in place | Data stored in the US; GitHub is certified under the US-Privacy Shield |
| Zendesk (https://www.zendesk.de/company/customers-partners/privacy-policy) | Ticket system for handling support requests | Data processing agreement in place | Data stored in the US; Standard contractual clauses. Zendesk is also certified under the US-Privacy Shield |
| Sentry (https://sentry.io/privacy) | logfile capturing and analyzing service | Data processing agreement in place | Data stored in the US; Sentry is certified under the US-Privacy Shield |
| Mailchimp | Mail-Kampagnen | Data processing agreement in place | Data stored in the US; MailChimp is certified under the US-Privacy Shield |
| Clearbit | Marketing tool to enrich our B2B data | Data processing agreement in place | Data stored in the US; Clearbit is certified under the US-Privacy Shield |
| HubSpot | Mail-Kampagnen | Data processing agreement in place | Data stored in Germany/US. Standard contractual clauses and Zertifizierung nach dem US-Privacy Shield |
(The list of Third-party providers may be reduced or extended in the future. We try to update our Privacy Policy correspondingly and timely)
Purpose and legal basis: Registering for Cawemo serve to initiate and, under some circumstances, to fulfill a service. When the user contacts us, we keep a record of his communication with us to help solve the respective issue. For example, we use the user´s email address to send him his registration confirmation (via a double opt-in method) as well as to later contact him about matters concerning his user account and/or with regard to contractual matters; any optional data the user may have uploaded will only be used for allowing the user to use his user account as desired. The legal basis for processing the data is, therefore, Art. 6 (1) (b) GDPR. The forwarding of the data to external third parties is similarly justified pursuant to Art. 28 GDPR and Art. 6 (1) (f) GDPR.
Duration of storage, data erasure, opportunity to object and for removal:The data are erased as soon as they are no longer necessary for achievement of the purpose for which they were collected. If the user deletes his account (paying or non-paying users), all respective data get automatically deleted, too. The user can, of course, also send an e-mail at any time for rectification or erasure of their data to privacy@cawemo.com. Further information on data collection, evaluation and processing of the user's data by our third-party providers can be obtained by the user from the third-party´s privacy statement´s, which are available to download under the above-mentioned links.
6. Registering for Cawemo via Third-Party Log-Ins
The web page allows the users to register via a Third-Party account. Currently we are offering this service for Linked-In and Google. This service may be reduced or extended in the future.
This allows for usage of certain data stored by Google, LinkedIn or Facebook in relation to the user´s account there to register the Cawemo user account and, subsequently, log into the Cawemo account. We may then ask the user to complete the necessary account information as applicable and described above.
In addition to certain basic profile information (e.g. user name) we also receive the email address the user is using for his Google or LinkedIn account as we need this address to initiate and, subsequently, administrate the Cawemo user account.
7. Newsletter
We also offer the user the opportunity to keep up to date about Cawemo and upcoming developments in the process modeling field via our newsletters.
Personal data: If the user subscribes to our Cawemo´s newsletter, we require only the user's e-mail address, which we will store for as long as the user wishes to obtain the newsletter. The data in the respective input mask are stored in Cawemo’s internal database and transmitted to MailChimp (https://mailchimp.com) and HubSpot (https://www.hubspot.de/). These company process the data on behalf of Camunda. MailChimp and Hubspot are certified under the US Privacy Shield. A data processing agreement with MailChimp and HubSpot is in place that conforms to the requirements of the GDPR.
Purpose and legal basis: Collecting the user's e-mail address is used for sending the newsletter. In addition, we use the data to further optimize our newsletter for our users, by operating newsletter tracking via MailChimp/Hubspot (specifically "open rate" and "click rate" tracking). The user´s consent to receiving the newsletter is obtained via a double-opt-in process. The legal basis for processing the data after the user registers for the newsletter is hence Art. 6 (1) (a) GDPR. Newsletter tracking is similarly justified pursuant to Art. 6 (1) (f) GDPR.
The data we collect when registering for the newsletter is further used to inform the user via email about product updates and upcoming events. This is our legitimate interest, which we can only pursue by sending emails and running product specific marketing-campaigns. We assume that the user has a continuing interest in Cawemo-specific products and services (6 (1) (f) GDPR).
Duration of storage, data erasure, opportunity to object and for removal: The data are used solely for dispatch of the newsletter and for other marketing-campaigns, where we inform the user about product-updates and upcoming events. The data subject can cancel the newsletter subscription and the receipt of further email-communication at any time. Similarly, consent to storage of personal data can be withdrawn at any time. There is a corresponding link for this purpose in every newsletter. And the user can, of course, send an e-mail at any time for rectification or erasure of their data to privacy@cawemo.com. Further information on data collection, evaluation and processing of the user's data by MailChimp and HubSpot and on their rights in relation to this can be obtained from MailChimp's or HubSpot's privacy statement, which is available to download from https://mailchimp.com/legal/privacy or https://legal.hubspot.com/privacy-policy.
III. Rights of users (data subjects)
If the user's personal data are processed, this person is a data subject in the sense of the GDPR. The data subject/user is entitled to the following rights vis-à-vis Camunda:
1. Right of access
The user can demand confirmation from Camunda regarding whether personal data concerning them are being processed by us.
Where such processing takes place, the user can demand details from Camunda concerning the following information:
- the purposes for which the personal data are being processed;
- the categories of personal data being processed;
- the recipients or the categories of recipients to whom the personal data concerning the user were disclosed or are being disclosed;
- the planned duration of storage of the personal data concerning the user or, if concrete details of this are not possible, criteria for determining the storage period;
- the existence of a right to rectification or erasure of the personal data concerning the user, of a right to restriction of processing by the controller or of a right of objection to this processing;
- the existence of a right of complaint to a supervisory authority;
- all available information about the origins of the data, if the personal data were not collected at Camunda;
- confirmation that no automated decision-making, including profiling pursuant to Art. 22 (1) and (4) GDPR takes place at Camunda;
- confirmation that there is no statutory or contractually-specified obligation for Camunda to provide personal data; provision may, however, be necessary for the conclusion of contract (where this is not provided, under certain circumstances no conclusion of contract is possible);
- the user also has the right to request information about whether the personal data concerning them are being sent to a third country or to an international organization. In connection with this, the user may request to be informed regarding the appropriate safeguards pursuant to Art. 46 GDPR in connection with transfer.
2. Right to rectification
The user has a right to rectification and/or completion by Camunda where the processed personal data concerning them are incorrect or incomplete. Camunda will make the rectification without undue delay.
3. Right to restriction of processing
Under the following conditions, the user can request restriction of processing of the personal data concerning them:
- if the user contests the accuracy of the personal data concerning them, for a period that enables Camunda to verify the accuracy of the personal data;
- if the processing is unlawful and the user opposes the erasure of the personal data and instead requests the restriction of use of the personal data;
- if Camunda no longer needs the personal data for the purposes of the processing, but the user requires this for the establishment, exercise or defense of legal claims; or
- if the user has lodged an objection to the processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds for Camunda override those of the user.
If the processing of the personal data concerning the user was restricted, this data will, with the exception of storage, only be processed with their 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 Union or of a Member State.
Where the restriction of processing was established in accordance with the above provisions, the user will be informed by Camunda before the restriction is lifted.
4. Right to erasure
a) Duty of erasureThe user may demand that Camunda erase the personal data concerning them without undue delay, and Camunda will have the obligation to erase these data without undue delay where one of the following grounds applies:
- the personal data concerning the user are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- the user withdraws their consent on which the processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and where there is no other legal ground for the processing.
- the user objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the user objects to the processing pursuant to Art. 21 (2) GDPR.
- the personal data concerning the user have been unlawfully processed.
- the personal data concerning the user have to be erased for compliance with a legal obligation in Union or Member State law to which Camunda is subject.
- the personal data concerning the user were collected in relation to the offer of information society services pursuant to Art. 8 (1) GDPR
Where Camunda has made the personal data concerning the user public and where Camunda is obliged pursuant to Art. 17 (1) GDPR to erase the data, Camunda, taking account of the available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the user has requested from Camunda the erasure of all links to those personal data or of copies or replications of those personal data.
c) ExceptionsThe right to erasure does not exist to the extent that processing is necessary
- for exercising the right to freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which Camunda is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in Camunda;
- for reasons of public interest in the area of public health in accordance with Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defense of legal claims.
5. Right to be informed
Where the user has asserted the right to rectification, erasure or restriction of processing by Camunda, Camunda will be obliged to notify all recipients to whom the personal data concerning the user were disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or is associated with disproportionate expense.
The user has the right Camunda to be informed by Camunda about these recipients.
6. Right to data portability
The user has the right to receive the personal data concerning them, which they have provided to Camunda, in a structured, commonly used and machine-readable format. The user further has the right to transfer those data to another controller without hindrance from Camunda, to whom the personal data have been provided, where
- the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and
- the processing is carried out by automated means.
In exercising this right, the user further has the right to have the personal data concerning them transferred directly by Camunda to another controller, where technically feasible. This will not adversely affect the freedoms and rights of other persons.
The right to data portability does not apply for the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Camunda.
7. Right to object
The user has the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6 (1) (e) or (f) GDPR.
Camunda will cease to process the personal data concerning the user, unless the user can demonstrate compelling legal grounds for the processing which override the interests, rights and freedoms of Camunda, or where processing serves the establishment, exercise or defense of legal claims.
Where personal data concerning the user are processed for direct marketing purposes, the user has the right to object at any time to processing of personal data concerning them for the purposes of such marketing.
Where the user objects to processing for direct marketing purposes, the personal data concerning them will cease to be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the user may exercise their right to object by automated means using technical specifications.
8. Right to revocation of the declaration of consent under the privacy law
The user has the right to withdraw their declaration of consent under the privacy law at any time. The revoking of consent does not affect the lawfulness of the processing that has taken place by reason of the consent up to the time of withdrawal.
9. Automated individual decision-making including profiling
Not applicable; no automated decision-making or other profiling measures take place at Camunda.
10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, the user has the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their workplace or the place of the alleged infringement, if the user considers that the processing of the personal data concerning them infringes the GDPR.
The supervisory authority with which the complaint has been lodged will inform the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
IV: Change log
October 2018: This privacy statement has been updated to describe the usage of Cookies and to reflect the implementation of our new marketing tools HubSpot and Clearbit.
previous versions- May 2018: This privacy statement has been completely revised to conform to the requirements set out in the GDPR and was first published in this form on the 16th of May 2018
- October 2017
- March 2017