1 Introduction
In the following, we provide information about the collection of personal datawhen using
our website https://vivasio.com
our profiles in social media.
Personal data is any data that can be related to a specific natural person, such astheir name or IP address.

1.1 Contact details
The controller within the meaning of Art. 4 para. 7 EU General Data ProtectionRegulation (GDPR) is Vivasio GmbH, Am Hamburger Bahnhof 3, 10557 Berlin, Germany, email: info@vivasio.com. We are legally represented by Fabian Berkemeier.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin,
www.heydata.eu 

E-Mail: datenschutz@heydata.eu

1.2 Scope of data processing, processing purposesand legal bases
We detail the scope of data processing, processing purposes and legal basesbelow. In principle, the following come into consideration as the legal basis fordata processing:
Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operationsfor which we obtain consent.
Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing ofpersonal data is necessary for the performance of a contract, e.g. if a sitevisitor purchases a product from us or we perform a service for him. Thislegal basis also applies to processing that is necessary for pre-contractualmeasures, such as in the case of inquiries about our products or services.
Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processingpersonal data, as may be the case, for example, in tax law.
Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely onlegitimate interests to process personal data, e.g. for cookies that arenecessary for the technical operation of our website.

1.3 Data processing outside the EEA
Insofar as we transfer data to service providers or other third parties outside theEEA, the security of the data during the transfer is guaranteed by adequacydecisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canadaand Israel) (Art. 45 para. 3 GDPR).
In the case of data transfer to service providers in the USA, the legal basis for thedata transfer is an adequacy decision of the EU Commission if the service providerhas also certified itself under the EU US Data Privacy Framework.
In other cases (e.g. if no adequacy decision exists), the legal basis for the datatransfer are usually, i.e. unless we indicate otherwise, standard contractual clauses.These are a set of rules adopted by the EU Commission and are part of thecontract with the respective third party. According to Art. 46 para. 2 lit. b GDPR,they ensure the security of the data transfer. Many of the providers have givencontractual guarantees that go beyond the standard contractual clauses toprotect the data. These include, for example, guarantees regarding the encryptionof data or regarding an obligation on the part of the third party to notify datasubjects if law enforcement agencies wish to access the respective data.

1.4 Storage duration
Unless expressly stated in this privacy policy, the data stored by us will be deletedas soon as they are no longer required for their intended purpose and no legalobligations to retain data conflict with the deletion. If the data are not deletedbecause they are required for other and legally permissible purposes, theirprocessing is restricted, i.e. the data are blocked and not processed for otherpurposes. This applies, for example, to data that must be retained for commercialor tax law reasons.

1.5 Rights of data subjects
Data subjects have the following rights against us with regard to their personaldata:
Right of access,
Right to correction or deletion,
Right to limit processing,
Right to object to the processing,
Right to data transferability,
Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisoryauthority about the processing of their personal data. Contact details of the dataprotection supervisory authorities are available at
https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html

1.6 Obligation to provide data
Within the scope of the business or other relationship, customers, prospectivecustomers or third parties need to provide us with personal data that is necessaryfor the establishment, execution and termination of a business or otherrelationship or that we are legally obliged to collect. Without this data, we willgenerally have to refuse to conclude the contract or to provide a service or will nolonger be able to perform an existing contract or other relationship.
Mandatory data are marked as such.

1.7 No automatic decision making in individual cases
As a matter of principle, we do not use a fully automated decision-making processin accordance with article 22 GDPR to establish and implement the business orother relationship. Should we use these procedures in individual cases, we willinform of this separately if this is required by law.

 

1.8 Making contact
When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g.names and e-mail addresses) will be stored by us in order to answer questions. Thelegal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR)to answer inquiries directed to us. We delete the data accruing in this context afterthe storage is no longer necessary or restrict the processing if there are legalretention obligations.

2. Data processing on our website
2.1 Notice for website visitors from Germany
Our website stores information in the terminal equipment of website visitors (e.g.cookies) or accesses information that is already stored in the terminal equipment(e.g. IP addresses). What information this is in detail can be found in the followingsections.
This storage and access is based on the following provisions:
Insofar as this storage or access is absolutely necessary for us to provide theservice of our website expressly requested by website visitors (e.g., to carryout a chatbot used by the website visitor or to ensure the IT security of ourwebsite), it is carried out on the basis of Section 25 para. 2 no. 2 of theGerman Telecommunications Digital Services Data Protection Act(Telekommunikation-Digitale-Dienste-Datenschutzgesetz, "TDDDG").
Otherwise, this storage or access takes place on the basis of the websitevisitor's consent (Section 25 para. 1 TDDDG).
The subsequent data processing is carried out in accordance with the followingsections and on the basis of the provisions of the GDPR.

2.2 Informative use of our website
During the informative use of the website, i.e. when site visitors do not separatelytransmit information to us, we collect the personal data that the browser transmitsto our server in order to ensure the stability and security of our website. This is ourlegitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
These data are:
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
Amount of data transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.
This data is also stored in log files. They are deleted when their storage is no longernecessary, at the latest after 14 days.

2.3 Web hosting and provision of the website
Our website is hosted by Wix. The provider is Wix.com Ltd., 40 Namal Tel-Aviv St.,Tel Aviv, Israel. In doing so, the provider processes the personal data transmittedvia the website, e.g. content, usage, meta/communication data or contact data, inthe EU. Further information can be found in the provider's privacy policy athttps://www.wix.com/about/privacy.
It is our legitimate interest to provide a website, so the legal basis of the describeddata processing is Art. 6 para. 1 s. 1 lit. f GDPR.

2.4 Contact form
When contacting us via the contact form on our website, we store the datarequested there and the content of the message. The legal basis for theprocessing is our legitimate interest in answering inquiries directed to us. The legalbasis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We delete the dataaccruing in this context after the storage is no longer necessary or restrict theprocessing if there are legal retention obligations.

2.5 Vacant positions
We publish vacant positions on our website, on pages linked to the website or onthird-party websites.
The processing of the data provided as part of the application is carried out for thepurpose of implementing the application process. Insofar as this is necessary forour decision to establish an employment relationship, the legal basis is Art. 88para. 1 GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act(Bundesdatenschutzgesetz). We have marked the data required to carry out theapplication process accordingly or refer to them. If applicants do not provide thisdata, we cannot process the application.Further data is voluntary and not requiredfor an application. If applicants provide further information, the basis is theirconsent (Art. 6 para. 1 s. 1 lit. a GDPR).
We ask applicants to refrain from providing information on political opinions,religious beliefs and similarly sensitive data in their CV and cover letter. They arenot required for an application. If applicants nevertheless provide suchinformation, we cannot prevent their processing as part of the processing of theresume or cover letter. Their processing is then also based on the consent of theapplicants (Art. 9 para. 2 lit. a GDPR).
Finally, we process the applicants' data for further application procedures if theyhave given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1lit. a GDPR.
We pass on the applicants' data to the responsible employees in the HRdepartment, to our data processors in the area of recruiting and to the employeesotherwise involved in the application process.
If we enter into an employment relationship with the applicant following theapplication process, we delete the data only after the employment relationshiphas ended. Otherwise, we delete the data no later than six months after rejectingan applicant.
If applicants have given us their consent to use their data for further applicationprocedures as well, we will not delete their data until one year after receiving theapplication.

2.6 Technically necessary cookies
Our website sets cookies. Cookies are small text files that are stored in the webbrowser on the end device of a site visitor. Cookies help to make the offer moreuser-friendly, effective and secure. Insofar as these cookies are necessary for theoperation of our website or its functions (hereinafter "Technically NecessaryCookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. fGDPR. We have a legitimate interest in providing customers and other site visitorswith a functional website. Specifically, we set technically necessary cookies for thefollowing purpose or purposes:
• to enable the playback of media content

2.7 Third parties
2.7.1 Usercentrics
We use Usercentrics to manage consents. The provider is Usercentrics GmbH,Sendlinger Straße 7, 80331 Munich. The provider processes meta/communicationdata (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is
Art. 6 para. 1 s. 1 lit. f GDPR
. We have alegitimate interest in managing the consent of website visitors to cookies in asimple manner.
The data will be deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is available in theprovider's privacy policy at https://usercentrics.com/privacy-policy/.

2.7.2 Google Analytics
We use Google Analytics for analytics. The provider is Google LLC, 1600Amphitheatre Parkway Mountain View, CA 94043, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times),meta/communication data (e.g. device information, IP addresses)
in the USA in theUSA.
The legal basis for the processing is
Art. 6 para. 1 s. 1 lit. a GDPR
The processing isbased on consent. Data subjects may revoke their consent at any time bycontacting us, for example, using the contact details provided in our privacy policy.The revocation does not affect the lawfulness of the processing until therevocation.
The transfer of personal data to a country outside the EEA takes place on the legalbasis adequacy decision. The security of the data transferred to the third country(i.e. a country outside the EEA) is guaranteed because the EU Commission hasdecided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPRthat the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longerapplies and there is no obligation to retain it. Further information is available in theprovider's privacy policy at https://business.safety.google/privacy/.

2.7.3 Google Tag Manager
We use Google Tag Manager for advertising, for analytics. The provider is GoogleIreland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The providerprocesses
usage data (e.g. web pages visited, interest in content, access times)
inthe USA in the USA.
The legal basis for the processing is
Art. 6 para. 1 s. 1 lit. a GDPR.
The processing isbased on consent. Data subjects may revoke their consent at any time bycontacting us, for example, using the contact details provided in our privacy policy.The revocation does not affect the lawfulness of the processing until therevocation.
The transfer of personal data to a country outside the EEA takes place on the legalbasis adequacy decision. The security of the data transferred to the third country(i.e. a country outside the EEA) is guaranteed because the EU Commission hasdecided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPRthat the third country ensures an adequate level of protection.
We delete the data when the purpose for which it was collected no longer applies.Further information is available in the provider's privacy policy athttps://business.safety.google/privacy/.

2.7.4 heyData
We have integrated a data protection seal on our website. The provider is heyDataGmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processesmeta/communication data (e.g. IP addresses) in the EU. The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimateinterest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuringthat only customers with existing contracts use its seals, which is why a mereimage copy of the certificate is not a viable alternative as confirmation.
As the data is masked after collection, there is no possibility to identify websitevisitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy

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3. Data Processing in Connection with Our Consulting Engagements
We process the personal data of our clients, partners, prospective clients, andservice providers to perform our consulting services related to the market launchof innovative pharmaceuticals, to respond to inquiries, and to manage projects.
We always process personal data for specifi c purposes and to the extent necessaryfor our consulting activities. This includes:
Master and contact data: e.g., fi rst and last name, business email address,phone number, company name, position/role within the company, businessaddress.
Project-related data: Depending on the specifi c consulting engagement,we process project-related information.
The processing of your data for the performance of our consulting mandates andfor the initiation of contracts is based on
Art. 6(1)(b) GDPR (performance of acontract and pre-contractual measures). 

For our office and email communications as well as project management, we usethe Microsoft 365 service as a data processor in accordance with Article 28 of theGDPR. The data is stored and processed on servers located within the EuropeanUnion (EU).

The data will be deleted once the purpose for which it was collected no longerapplies and there is no confl icting retention obligation.

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4. Data processing on social mediaplatforms
We are represented in social media networks in order to present our organizationand our services there. The operators of these networks regularly process theirusers' data for advertising purposes. Among other things, they create user profilesfrom their online behavior, which are used, for example, to show advertising on thepages of the networks and elsewhere on the Internet that corresponds to theinterests of the users. To this end, the operators of the networks store informationon user behavior in cookies on the users' computers. Furthermore, it cannot beruled out that the operators merge this information with other data. Users canobtain further information and instructions on how to object to processing by thesite operators in the data protection declarations of the respective operators listedbelow. It is also possible that the operators or their servers are located in non-EUcountries, so that they process data there. This may result in risks for users, e.g.because it is more difficult to enforce their rights or because government agenciesaccess the data.
If users of the networks contact us via our profiles, we process the data provided tous in order to respond to the inquiries. This is our legitimate interest, so that thelegal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

4.1 LinkedIn
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland UnlimitedCompany, Wilton Place, Dublin 2, Ireland. The privacy policy is available here:https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to dataprocessing is via the settings for advertisements:https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy
We reserve the right to change this privacy policy with effect for the future. Acurrent version is always available here.

6. Questions and comments
If you have any questions or comments regarding this privacy policy, please feelfree to contact us using the contact information provided above.