Privacy

We are delighted that you are interested in our company. Data protection and privacy is a matter of particular importance to the management of Whiskey Tango Foxtrot GmbH. You can use the Whiskey Tango Foxtrot GmbH website without providing any personal data. However, if a data subject wishes to use specific services offered by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Whiskey Tango Foxtrot GmbH. By means of this privacy policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this privacy policy informs data subjects about their rights.

As the data controller, Whiskey Tango Foxtrot GmbH has implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to provide us with personal data by alternative means, for example by telephone.

1. Definitions
   The privacy policy of Whiskey Tango Foxtrot GmbH is based on the terms used by the European legislator in the General Data Protection Regulation (GDPR). Our privacy policy is intended to 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 terms used in advance. We use the following terms in this privacy policy, among others:

   a) personal data
   Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
   

   b) data subject
   A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
   

   c) processing
   Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, retrieval, 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 limiting their processing in the future.
   

   e) profiling
   Profiling means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
   

   f) pseudonymisation
   Pseudonymisation 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 organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
   

   g) controller or controller responsible for processing
   The controller or controller responsible for 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 law or the law of Member States, the controller or the specific criteria for his or her nomination may be provided for by Union law or the law of Member States.
   

   h) processor
   A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
   

   i) recipient
   Recipient means a natural or legal person, public authority, agency or other body which receives personal data, whether or not a third party. However, public authorities which may receive personal data in the course of their specific activities as provided for by Union law or Member State law shall not be considered recipients.
   

   j) third party
   A third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or the processor, are authorised to process personal data.
   

   k) consent
   Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by such clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
   

2. Contact details 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 with data protection character is:
   Whiskey Tango Foxtrot GmbH
   Schäferkampsallee 16
   20357 Hamburg
   Germany
   Email: privacy@wtfoxtrot.de
   Website: www.wtfoxtrot.de

3. Contact details of the data protection officer
   The data protection officer of the controller is:
   Whiskey Tango Foxtrot GmbH
   Schäferkampsallee 16
   20357 Hamburg
   Germany
   Email: privacy@wtfoxtrot.de
   Website: www.wtfoxtrot.de
   
   Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

4. Collection of general data and information
   The website of Whiskey Tango Foxtrot GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites that are accessed via an accessing system on our website, (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 that serve to protect against attacks on our information technology systems.
   
   When using this general data and information, Whiskey Tango Foxtrot GmbH does not draw any conclusions about the data subject. This information is required in order to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Whiskey Tango Foxtrot GmbH on the one hand statistically and on the other hand with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

5. Contact option via the website
   Due to legal requirements, the website of Whiskey Tango Foxtrot GmbH contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller will be stored for the purpose of processing or contacting the data subject. This personal data will not be passed on to third parties.

6. Routine deletion and blocking of personal data
   The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or if this is provided for by the European directive and regulation issuer or another legislator in laws or regulations to which the controller is subject.
   If the purpose of storage no longer applies or if a storage period prescribed by the European Directive and Regulation or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

7. Rights of the data subject
   

   a) Right to confirmation
   Every data subject has the right granted by European directives and regulations to obtain confirmation from the controller as to whether personal data concerning them are being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.
   
   

   b) Right to information
   Every person affected by the processing of personal data has the right granted by European directives and regulations to obtain, at any time and free of charge, information from the controller about the personal data stored about them and a copy of this information. Furthermore, European directives and regulations grant the data subject the right to obtain the following information:

   • the purposes of the processing
   • the categories of personal data that are 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 organisations
   • where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria for determining this period
   • the existence of a right to rectify or erase personal data concerning them or to restrict processing by the controller or a right to object to such processing
   • the existence of a right to lodge a complaint with a supervisory authority
   • if 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, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
   
   Furthermore, the data subject has the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.
   
   If a data subject wishes to exercise this right to information, they may contact an employee of the controller at any time.

   c) Right to rectification
   Every person affected by the processing of personal data has the right granted by European directives and regulations to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of the processing. If a data subject wishes to exercise this right of rectification, they may contact an employee of the data controller at any time.

   d) Right to erasure (right to be forgotten)
   Every person affected by the processing of personal data has the right granted by European directives and regulations to request that the controller delete personal data concerning them without delay if one of the following reasons applies and provided that the processing is not necessary:
   • The personal data has been collected or otherwise processed for purposes for which it is no longer necessary. • The data subject withdraws consent on which the processing is based in accordance with Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR, and there is no other legal basis for the processing. • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR. • The personal data has been processed unlawfully. • The personal data must be erased to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject. The personal data has been collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.
   
   If one of the above reasons applies and a data subject wishes to have personal data stored by Whiskey Tango Foxtrot GmbH deleted, they can contact an employee of the controller at any time. The employee of Whiskey Tango Foxtrot GmbH will ensure that the request for deletion is complied with immediately. If the personal data has been made public by Whiskey Tango Foxtrot GmbH and our company is obliged to delete the personal data in accordance with Art. 17 (1) GDPR, Whiskey Tango Foxtrot GmbH shall take appropriate measures, including technical measures, taking into account the available technology and 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 copies or replications of this personal data, unless the processing is necessary. The employee of Whiskey Tango Foxtrot GmbH will take the necessary steps in each individual case.

   e) Right to restriction of processing
   Every person affected by the processing of personal data has the right granted by European directives and regulations to request that the controller restrict 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, 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 the data subject needs it for the establishment, exercising or defence of legal claims. • The data subject has objected to the processing pursuant to Art. 21(1) of the GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.
   
   If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Whiskey Tango Foxtrot GmbH, they may contact an employee of the controller responsible for processing at any time. The employee of Whiskey Tango Foxtrot GmbH will arrange for the processing to be restricted.

   f) Right to data portability
   Every person affected by the processing of personal data has the right granted by European directives and regulations to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR or on a contract pursuant to Art. 6(1)(b) 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, when 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.
   
   To exercise the right to data portability, the data subject may contact an employee of Whiskey Tango Foxtrot GmbH at any time.

   g) Right to object
   Every person affected by the processing of personal data has the right, granted by European directives and regulations, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them on the basis of Art. 6 para. 1 letters e or f GDPR. This also applies to profiling based on these provisions. Whiskey Tango Foxtrot GmbH will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. If Whiskey Tango Foxtrot GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing purposes. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Whiskey Tango Foxtrot GmbH processing their data for direct marketing purposes, Whiskey Tango Foxtrot GmbH will no longer process the personal data for these purposes.
   
   In addition, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them by Whiskey Tango Foxtrot GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR, unless such processing is necessary for the performance of a task carried out in the public interest. To exercise the right to object, the data subject may contact any employee of Whiskey Tango Foxtrot GmbH or another employee directly. The data subject is also free to exercise their right to object in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

   h) Automated individual decision-making, including profiling Every data subject whose personal data is processed has the right granted by European directives and regulations not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent. If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is made with the express consent of the data subject, Whiskey Tango Foxtrot GmbH shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
   
   If the data subject wishes to exercise their rights in relation to automated decisions, they may contact an employee of the controller responsible for processing at any time.

   i) Right to withdraw consent under data protection law
   Every person affected by the processing of personal data has the right granted by European directives and regulations to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

8. Data protection for applications and in the application process
   The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, unless other legitimate interests of the controller prevent deletion. Other legitimate interests in this sense include, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

9. Data protection notice for the use of Vercel
   Responsible provider:
   Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA
   Purpose of processing:
   We use Vercel as a hosting and deployment platform for our web applications. Technical access data (e.g. IP address, time stamp, requested resources) is processed in order to provide the website and ensure system security.
   Legal basis
   The processing is based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in the secure and efficient provision of our online services.
   Data storage
   Data is stored and processed within the European Union; the ‘EU Data Residency’ option is activated. This applies in particular to static content and server-side functions (serverless functions).
   Data transfer to third countries
   The transfer of personal data to the USA cannot be completely ruled out. Vercel undertakes to comply with the GDPR and offers contractual guarantees (e.g. standard contractual clauses) and technical measures to ensure an adequate level of data protection.
   Note
   Vercel acts as a processor within the meaning of Art. 28 GDPR. A corresponding data processing agreement (DPA) must be concluded.

10. References to external platforms and services
    As part of our online presence, we link to external platforms and services such as LinkedIn, XING, Kununu, Instagram, YouTube Shorts and TikTok. Please note that when you visit these platforms, personal data may be processed by the respective providers. We have no influence on this data processing.
    The use of these platforms is the sole responsibility of the user. We would like to point out that the providers may create usage profiles, especially if you are logged in there. Further information on data processing by the respective providers can be found in the privacy policies of the platforms.

    a) Data protection provisions for the use of LinkedIn
    We have placed a link to LinkedIn on this website. If you use this link, here is the information on data processing:
    Responsible provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland
    Purpose of processing: Presentation of our company, communication with users, reach analysis
    Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest), if applicable Art. 6 para. 1 lit. a GDPR (consent)
    Data transfer: Possible to the USA, based on the EU-U.S. Data Privacy Framework (Microsoft is certified)
    
    Further information: LinkedIn Privacy Policy
    
    Note: LinkedIn also processes data for its own purposes. We have no influence on this processing.

    b) Privacy policy on the use and application of Xing
    We have placed a link to Xing on this website. If you use it, here is the information on data processing:
    Responsible provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
    Purpose of processing: Company presentation, professional networking, communication
    Legal basis: Art. 6 para. 1 lit. f GDPR
    Data processing: Within the EEA, no transfer to third countries
    
    Further information: XING Privacy Policy
    
    Note: Xing also processes data for its own purposes. We have no influence on this processing.

    c) Privacy policy on the use and application of Kununu
    We have placed a link to Kununu on this website. If you use it, here is the information on data processing:
    Responsible provider: Kununu GmbH, part of New Work SE, Vienna, Austria
    Purpose of processing: Employer reviews, feedback culture, transparency
    Legal basis: Art. 6 para. 1 lit. f GDPR
    Special features: Anonymity of reviews, no publication of personal data permitted
    
    Further information: Kununu Data Protection
    
    Note: Kununu also processes data for its own purposes. We have no influence on this processing.

    d) Privacy policy on the use and application of Instagram
    We have placed a link to Instagram on this website. If you use this link, here is the information on data processing:
    Responsible provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
    Purpose of processing: Marketing, interaction with users, reach analysis
    Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 26 GDPR (joint responsibility)
    Data transfer: Possible to the USA, Meta is DPF-certified
    
    Further information: Instagram privacy policy
    
    Note: Instagram also processes data for its own purposes. We have no influence over this processing.

    e) Privacy policy on the use of YouTube Shorts
    We have placed a link to YouTube Shorts on this website. If you use it, here is the information on data processing:
    Responsible provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
    Purpose of processing: Video distribution, user interaction, advertising
    Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR
    Data transfer: Possible to the USA, Google is DPF certified
    
    Further information: YouTube Privacy
    
    Note: YouTube also processes data for its own purposes. We have no influence on this processing.

    f) Privacy policy on the use and application of TikTok
    We have placed a link to TikTok on this website. If you use it, here is the information on data processing:
    Responsible provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland
    Purpose of processing: Video distribution, user interaction, analysis
    Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 26 GDPR (joint responsibility)
    Data transfer: Partially to third countries, TikTok Ireland is responsible for the EEA
    
    Further information: TikTok Privacy Policy
    
    Note: TikTok also processes data for its own purposes. We have no influence over this processing.

11. Legal basis for processing
    Art. 6 I lit. a GDPR serves as the legal basis for our company 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, with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and their name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third party. In this case, the processing would 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 above 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 override these interests. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, 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 of the GDPR).

12. Legitimate interests in processing pursued by the controller or a third party
    If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the performance of our business activities for the benefit of all our employees and our shareholders.

13. Duration for which the personal data will be stored
    The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data will be routinely deleted, provided that it is no longer necessary for the fulfilment of the contract or for the initiation of a contract.

14. 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 inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we will then have to process. 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 providing personal data, 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 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 consequences the non-provision of personal data would have.

15. Existence of automated decision-making
    As a responsible company, we refrain from automated decision-making or profiling.