Privacy policy

Section 1: Information on the collection of personal data

(1) By the present Privacy Policy, we are informing you of how we collect personal data concerning you when you use our website.  Personal data are all data that relate to you personally, such as your name, address, email addresses, as well as individualized data regarding your user behavior.

(2) The controller pursuant to Article 4 paragraph 7 of the European General Data Protection Regulation (GDPR) is VTG GmbH, Nagelsweg 34, 20097 Hamburg, Tel.: +49 40 2354-0, email: (referred to hereinbelow as “we” or “us”). Our Data Protection Officer can be reached by email at or by sending us a letter to the above address, specifying “der Datenschutzbeauftragte” (Attn: The Data Protection Officer).

(3) When you contact us via email or using a contact form, we will store the data you provide to us (your email address and, as the case may be, your name and your telephone number) to allow us to respond to your query.  The processing of these data is justified since we do so in order to pursue our legitimate interests, these consisting of our interest in responding to queries you address to us, pursuant to Article 6 paragraph 1, first sentence, letter f) of the GDPR.  We will erase the data accruing in this context once it is no longer necessary to store them for this purpose, or we will restrict the processing should statutory retention obligations exist.  While providing these data to us is voluntary, it may be that, if you do not provide them, we will be unable to reply to your query or to process it.

(4) Should we avail ourselves, in order to provide individual functions of our offering, of service providers with whom we have concluded a contract, or should we wish to use your data for advertisement purposes, you will find below detailed information on the respective processes this entails.  In this context, we will also provide you with the criteria determining the duration of the period for which data will be stored.


Section 2: Your rights

(1) You are entitled to the following rights vis-à-vis ourselves regarding the personal data concerning you:

  • Right of access pursuant to Article 15 of the GDPR,
  • Right to rectification or to erasure pursuant to Articles 16 und 17 of the GDPR,
  • Right to restriction of processing pursuant to Article 18 of the GDPR,
  • Right to object to the processing pursuant to Article 21 of the GDPR,
  • Right to data portability pursuant to Article 20 of the GDPR.

(2) Moreover, you are entitled to the right to file a complaint with the competent supervisory authority for data protection matters regarding our processing of the personal data concerning you.


Section 3: Collection of personal data when you visit our website

(1) If you use the website for purposes of obtaining information only, in other words, if you do not register and do not provide us with information in any other way, we will collect only those of the personal data concerning you that your browser transfers to our server.  If you wish to view our website, we will collect the following data, which we need in order to display our website to you and in order to warrant its stability and security (the legal basis therefor is Article 6 paragraph 1, first sentence, letter f) of the GDPR):

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status / HTTP status code
  • The amount of data transmitted in each case
  • Website from which the request originates
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.


Section 4: Further functions and offerings of our website

(1) Besides allowing visitors to use our website for purely informational reasons, we also offer a range of services which you may use if you are interested.  As a rule, you must provide further personal data for this purpose, which we will use in order to provide the respective service; they are governed by the above-referenced principles on the processing of data.  While providing such data is voluntary, it may be that you will not be able to use the services offered if you refrain from providing them to us.

(2) In some instances, we will avail ourselves of external service providers in order to process your data.  We have carefully selected the service providers to whom we have awarded a contract; they are bound to our instructions and are subject to regular controls.

(3) Moreover, we will share the personal data concerning you with third parties only if this is necessary in order to correspond to your query or to provide the offered services.


Section 5: Objection to the processing of your data or revocation of consent

(1) If you have consented to your data being processed, you may revoke this content at any time.  Such revocation of consent will impact the permissibility of processing the personal data concerning you once you have declared it.

(2) As much as we base the processing of the personal data concerning you on an exercise of balancing our reciprocal interests, you may object to the processing of your data at any time.  This is the case in particular where processing your data is not necessary to perform an agreement in place with you, which we will present in each case when we subsequently describe the functions.  Where you exercise such right of objection, we ask that you provide us with the reasons for which we should not continue processing the personal data concerning you.  In the event of your lodging an objection and providing us with the grounds therefor, we will review the factual situation and will either cease processing the personal data concerning you, or will make modifications to the data processing, or will indicate to you the absolutely mandatory grounds meriting protection based on which we will continue processing the personal data concerning you.


Section 6: Newsletter

(1) By your consent, you have the opportunity to sign up for our newsletter, which we use to inform you of our current offerings of interest.  The goods and services advertised will be set out in the declaration of consent.

(2) For you to sign up for our newsletter, we use a process known as the “double opt-in” process.  This means that once you have registered, we will send an email to the email address you have provided to us, asking you to confirm that you wish to receive the newsletter.  Should you fail to confirm your registration within twenty-four (24) hours, your data will be blocked and will automatically be erased once one (1) month has lapsed.  Moreover, we will store the IP addresses you have used and the time at which you registered / sent us a confirmation.  The purpose of this procedure is to give us an evidentiary record of your registration and to allow us to clear up any potential abuse of the personal data concerning you.  The collection of the personal data concerning you for this purpose is justified pursuant to Article 6 paragraph 1, first sentence, letter f) of the GDPR.

(3) The only information you must mandatorily provide to us in order for the newsletter to be sent to you is your email address.  Any provision of further, separately marked data is voluntary; they will be used to address you personally.  Once we receive your confirmation, we will store your email address for purposes of sending the newsletter to you.  The legal basis therefor is Article 6 paragraph 1, first sentence, letter a) of the GDPR.  We will store the data you provide to us in the context of granting your consent and will use them to send our newsletter to you until you revoke your consent as described in the following paragraph below.

(4) You may revoke your consent to receiving the newsletter at any time and may unsubscribe from the newsletter.  To do so, you can click on the link included in every newsletter email or you may declare your revocation by sending a message using the contact details provided in the website information.


Section 7: Events

(1) By your consent to the privacy policy, you allow us to process your personal data for the organization and realization of the mentioned event. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data. This collection of your data for this purpose is justified according to Art. 6 para. 1 p. 1 lit. f DS-GVO.

(2) Mandatory information for sending the registration confirmation is your first and last name, your company and your e-mail address. After your confirmation, we will store your first and last name as well as your e-mail address for the purpose of sending the registration confirmation as well as other important information regarding the respective event. The legal basis is Art. 6 para. 1 p. 1 lit. a DS-GVO. We will store the data you provide as part of your consent and use it to send you further important information about the respective event until you revoke your consent, as described in the following paragraph.

(3) You have the right to revoke your consent at any time in the form of a cancellation of the respective event.


Section 8: Information on data protection in the application procedure

We process applicant data only for the purpose of and within the scope of the application procedure in accordance with the legal requirements. Applicant data is processed to fulfil our (pre)contractual obligations within the scope of the application procedure in accordance with Art. 6 (1) lit. b. GDPR and Art. 6 para. 1 lit. f. GDPR insofar as the data processing becomes necessary for us, e.g. within the scope of legal procedures (in Germany, § 26 BDSG also applies).

The application procedure requires applicants to provide us with their data. The necessary applicant data is otherwise derived from the job descriptions and basically includes personal details, postal and contact addresses as well as the documents belonging to the application, such as application letter, curriculum vitae and further certificates. In addition, applicants may voluntarily provide us with additional information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application procedure in the manner and to the extent described in this information on data protection.

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily disclosed within the scope of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants as part of the application process, their processing is additionally carried out in accordance with Art. 9 (2) a GDPR (e.g. health data if this is necessary for the exercise of the profession).

If provided, applicants can submit their applications to us using an online form on our website. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We cannot therefore accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend rather using the online form or sending it by post.

The data provided by applicants may, in the event of a successful application, be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

The deletion will take place after the expiry of a period of six months, unless the applicant withdraws their application, so that we can answer any follow-up questions about the application and comply with our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements. If the applicant cannot be considered for the current position, but is in principle of interest to the person responsible, the data will be included in an applicant pool for one year. However, the data will only be stored with the explicit and verifiable consent of the applicant.


Section 9: reCAPTCHA

We use the reCAPTCHA service from Google. With reCaptcha, a JavaScript element is embedded in the source code, whereby the software is loaded in the background and your user behavior is analyzed. The data is already used and analyzed before you clicked the "I am not a robot" checkbox. Google calculates a score based on the data, which is used on the one hand to be able to understand whether the visitor is a human or whether the input is abusive through automated, machine processing (e.g. bots). On the other hand, it also serves to prevent fraudulent mass orders, which can lead to risks in the company's infrastructure. ReCAPTCHA also provides protection for our customers from becoming potential victims of cyber crime.

Legal basis
The legal basis for this processing is therefore our legitimate interest according to Art. 6 (1) lit. f GDPR.

Type of data
- Previous web pages (referrer URL) 
- IP address (Google Fonts)
- Operating system 
- cookies 
- Scrolling and mouse clicks on the page 
- Date and language settings 
- screen resolution 
- The IP address transmitted to Google is shortened and not merged with other Google data.

Provider of the ReCAPTCHA service
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Further information on Google's data protection can be found here: 
To have data deleted directly from Google, contact Google support at. 
If you want as little data as possible about you and your behavior to be transmitted to Google, you must log out of Google and delete any Google cookies before you visit our website or use the reCAPTCHA software.

If VTG GmbH transfers data to third countries, suitable guarantees for the transfer of data are agreed with any processors or data controllers in accordance with the requirements of Chapter V of the GDPR, or the adequacy decisions of the EU Commission are used.

Section 10: YouTube

We use the YouTube embedding function to display and play videos from YouTube on our website. We use the extended data protection mode, which, according to the provider, only initiates storage of user information when the video is played. At the moment when the playback of the embedded video is started, YouTube uses cookies to collect information about user behavior.

Section 11: Customer Relationship Management (CRM)
  1. (1) We process the contact data you provide us with for the purpose of conducting business in our CRM in accordance with the legal requirements. The processing is carried out to fulfill our (pre-)contractual obligations within the meaning of Art. 6 para. 1 lit. b. GDPR. The necessary data is limited to data for business contact (e.g. business telephone number, e-mail address or postal address). Your data will be deleted in compliance with the applicable legal regulations.
  2. (2) Our employees are trained in the sensitive handling of your data and instructed in terms of data protection.

  3. (3) We will only pass on your contact details to third parties outside the VTG Group with your consent if this may be necessary to process your request or provide the services offered.

  4. (4) Any service providers required for data processing are carefully selected by us, are committed to our instructions and are regularly reviewed.


As of: February 2024

Data protection officer