- According to Article 26(2) sentence 2 of the General Data Protection Regulation (GDPR) –

In the framework of joint data protection responsibility, we – the corporate group of ALVARA | Digital Solutions, have agreed which company within the corporate group fulfills which obligations according to GDPR. This particularly affects the exercising of data subjects' rights and the fulfillment of information obligations according to Articles 13 and 14 GDPR.

This agreement is necessary because, within the context of application processes and in designing marketing measures and exercising business relationships, personal data is processed in different process steps and systems.

We present to you here the essential information of the agreement made.

Who shares the joint responsibility?

What are the reasons for joint processing?

Joint marketing strategy

To fully promote the group's product portfolio and present comprehensive solutions to customers, we work closely in the design and execution of marketing measures and product configuration.

Centralized application process

Except for Safelogy SAS, we use a centralized application process. This way, we achieve a comprehensive and uniform appearance and also achieve both central and standardized processes.

In both of the aforementioned cases, this also involves the processing of your personal data. We have jointly determined the purposes and means of processing these data in the individual process steps and are therefore jointly responsible for the protection of your personal data within the process steps described below (Art. 26 GDPR).

1. Master data management
    

   Process step	Responsibility
   Data collection and forwarding to ALVARA Holding	The company in direct first contact with the data subject
   Incorporation of data into central master data system	ALVARA Holding GmbH
   Use of data	Entire corporate group

    

2. Marketing measures
    

   Process step	Responsibility
   Receipt of the expression of interest in marketing measures & transfer to ALVARA Holding	The company in direct first contact with the data subject
   Recording and managing consents for marketing measures	ALVARA Holding GmbH
   Execution of marketing measures	ALVARA Holding GmbH

    

3. Fulfillment of contractual or pre-contractual business relationships
   (Correspondence, project execution, etc.)
    

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

    

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

    

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

    

5. Centralized application process
    

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

Who informs me as the data subject?

Within the joint responsibility, the company of the corporate group that is in first contact with you always fulfills the information obligations according to Art. 13 and 14 GDPR.

Who complies with my data subject rights?

Within the scope of joint responsibility and the respective responsibilities, the companies promptly inform each other about the rights you have asserted. They provide each other with all necessary information for responding to requests for information.

To exercise your data protection rights, you have ALVARA Holding GmbH as the central administration office available as a direct contact. However, you are free to assert your rights against any company of the corporate group.

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