Privacy Policy

We thank you very much for your interest in our company! Data protection has a particularly high priority for the management of NEUTRALOG GmbH. Our website is mostly accessible without the sharing of any personal data, only when making use of a specific service the processing of personal data might be required. If the processing of personal data is required without the required legal basis, we generally request consent of the affected party. The processing of personal data, for instance the name, address, e-mail address or phone number of an affected party will always be processed within the general data protection regulations and NEUTRALOG GmbH applicable district-specific data protection regulations. By the means of this data privacy declaration, our company would like to inform the public about the way, extent and purpose of the requested, used and processed Data. Furthermore, by the means of this data privacy declaration, affected parties are to be informed about their rights to which they are entitled to. The NEUTRALOG GmbH, as the responsible party, implemented numerous technological and organizational measures to ensure protection as complete as possible for the via our website requested and processed personal data. Nevertheless, internet-based data transfers generally can contain vulnerabilities, so absolute protection cannot be guaranteed. For this reason, every affected party are free to share personal data using alternate ways, such as by phone. 1. Definition of terms The data protection declaration of the NEUTRALOG GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance. We use the following terms, among others, in this Privacy Policy: a) Personal data Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. b) Affected persons Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing. c) Processing Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. d) Restriction of processing Restriction of processing is the marking of stored personal data with the aim of restricting its future processing. e) Profiling Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. f) Pseudonymization Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. g) Controller or controller responsible for the processing Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. h) Processor Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. i) Receiver Receiver is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. j) Third party Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data. k) Consent Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. 2. Name and address of the controller The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the: NEUTRALOG GmbH Martinistr. 61 28195 Bremen Deutschland Phone: +49 421 4788697-0 E-Mail: datenschutz@neutralog.com 3. Cookies The Internet pages of NEUTRALOG GmbH use cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser. Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters that can be used to assign websites and servers to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID. Through the use of cookies, the NEUTRALOG GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie for a shopping basket in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie. The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable. 4. Collection of general data and information The website of the NEUTRALOG GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website can be recorded, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems. When using these general data and information, the NEUTRALOG GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the NEUTRALOG GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject. a) Use of Google Translate This site uses the Google Translate translation service via an API. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. To use the features of Google Translate, it is necessary to store your IP address. This information is generally transmitted to a Google server in the United States and stored there. The provider of this site has no influence over this data transmission. The use of Google Translate is in the interest of ensuring easy accessibility and accessibility of our online offerings for international visitors. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. For more information on the handling of user data, please refer to Google’s Privacy Policy: https://google.de. 5. Routine deletion and blocking of personal data The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the statutory provisions. 6. Rights of the data subject a) Right of confirmation Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller. b) Right of information Any person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain from the controller free information at any time about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information

• the purposes of the processing
• the categories of personal data being processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
• where possible the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
• the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
• the existence of the right to lodge a complaint with a supervisory authority
• where the personal data are not collected from the data subject: All available information on the origin of the data
• The existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) GDPR and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for the data subject

Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller. c) Right of rectification Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller. d) Right of erasure (right to be forgotten) Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data have been collected or otherwise processed for such purposes for which they are no longer necessary.
• The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.
• The personal data has been processed unlawfully.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the NEUTRALOG GmbH, he or she may, at any time, contact any employee of the controller. An employee of NEUTRALOG GmbH shall promptly ensure that the erasure request is complied with immediately. If the personal data have been made public by the NEUTRALOG GmbH and our company, as the controller, is obliged pursuant to Article 17(1) of the GDPR to erase the personal data, NEUTRALOG GmbH shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other data controllers, insofar as the processing is not necessary. An employee of the NEUTRALOG GmbH will arrange the necessary measures in individual cases. e) Right of restriction of processing Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to require the controller to restrict the processing if one of the following conditions is met:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the NEUTRALOG GmbH, he or she may at any time contact any employee of the controller. The employee of the NEUTRALOG GmbH will arrange the restriction of the processing. f) Right of data portability Any person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of the NEUTRALOG GmbH . g) Right to object Any person affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. 7. Legal basis of processing Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR). 8. Legitimate interests in the processing pursued by the controller or a third party Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders. 9. Duration for which the personal data is stored The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data is routinely deleted, provided that it is no longer required for contract fulfillment or contract initiation. 10. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided. 11. Existence of automated decision-making As a responsible company, we do not use automated decision-making or profiling. This Privacy Policy has been generated by the Privacy Policy Generator of the DGD – Your External DPO that was developed in cooperation with German Lawyers from WILDE BEUGER SOLMECKE, Cologne.

12. Processing of applicant, partner and commercial customer inquiries

We look forward to your interest in our company and offer various ways to contact us on our website (e.g. via email or our online forms). Below we inform you about the scope, purpose and use of the personal data collected during these processes in a B2B context.

1. Purpose and legal basis of applicant data processing

   We process your personal data (e.g. contact and master data, application documents such as CV, certificates, notes from interviews) to conduct the application process and decide on establishing an employment relationship. The primary legal basis is Art. 6 (1) (b) GDPR (initiation of a contractual or employment relationship).

2. Recipients of applicant data

   Within our company, only persons directly involved in the decision regarding your application have access (e.g. management, the responsible department heads or HR managers). Your application data will not be passed on to third parties outside our company.

3. Retention period of applicant data

   If we are unable to offer you a position, if you reject a job offer or withdraw your application, we store your data for a maximum of 6 months after completion of the application process. This retention serves as evidence in the event of a legal dispute under the General Act on Equal Treatment (AGG). After this period, the data and associated emails will be permanently deleted or physical documents destroyed.

4. Inclusion in the applicant pool

   If we cannot offer you a position at present but your profile is of interest for future vacancies, we will explicitly ask for your consent beforehand to include your data in our “applicant pool”. Without this separate, voluntary consent, your data will be deleted after the 6-month period mentioned above.

5. Use of the contact form for subcontractors and partners (B2B)

   If you apply or request cooperation via our contact form as a subcontractor or transport partner, we process the data you enter (e.g. company name, business contact details of contact persons, fleet details, areas of operation). This processing serves the initiation and review of a business cooperation and is based on Art. 6 (1) (b) GDPR (pre-contractual measures). The transmitted data remains in our system until the purpose for storage ceases to apply or statutory retention periods dictate longer storage.

6. Use of the form for commercial price inquiries (requests for quotations)

   Via our form for price inquiries, we collect specific business data (such as transport details, loading points, container types, route requests and contact details of the responsible corporate contact person) to calculate an individual, non-binding logistics offer for your company. The processing of this data serves the execution of pre-contractual measures at your request and is based on Art. 6 (1) (b) GDPR. If business letters or contracts result from these inquiries, the data will be stored for 6 or 10 years in accordance with statutory retention periods under § 257 HGB and § 147 AO. Otherwise, they will be deleted as soon as the purpose for storage ceases to apply.

13. Web hosting and security encryption

Web hosting We host the content of our website with our external service provider, netclusive GmbH, Robert-Bosch-Str. 10, Haus I, 56410 Montabaur. The server log files automatically recorded when using our website (as described under point 4) are processed on the servers of this provider. A contract for data processing (AVV) pursuant to Art. 28 GDPR has been concluded with the provider.

SSL or TLS encryption This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as commercial price inquiries, partner contact forms or applications that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.