Data protection

‍1.1 Contact details

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The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Purpose Green Real Estate GmbH, Kurfürstendamm 38-39, 10719 Berlin, Germany, e-mail: contact@purpose-green.com. We are legally represented by Lennart Christel, Lucas Christel and Okitonga Memba.

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Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal bases

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The scope of data processing, processing purposes and legal bases are explained in detail below. The following legal bases for data processing can generally be considered:

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• Art. 6 para. 1 sentence 1 lit. a GDPR serves as the legal basis for processing operations for which we obtain consent.
• Art. 6 para. 1 sentence 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of inquiries about our products or services.
• Art. 6 para. 1 sentence 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.
• Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests to process personal data, e.g. for cookies that are required for the technical operation of our website.

1.3 Data processing outside the EEA

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Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 para. 3 GDPR guarantee the security of the data during transfer, insofar as these exist, as is the case, for example, for the UK, Canada and Israel.

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In the case of data transfer to service providers in the USA, the legal basis for data transfer is an adequacy decision by the EU Commission if the service provider is also certified under the EU-US Data Privacy Framework.

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In other cases (e.g. if there is no adequacy decision), the legal basis for data transfer is usually standard contractual clauses, i.e. unless we indicate otherwise. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they guarantee the security of data transfer. Many of the providers have issued contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding the obligation of the third party to inform the data subject if law enforcement agencies wish to access data.

1.4 Storage period

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Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5 Rights of the data subjects

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Data subjects have the following rights vis-à-vis us with regard to their personal data:

• Right to information,
• Right to rectification or erasure,
• Right to restriction of processing,
• Right to object to the processing,
• Right to data portability,
• Right to withdraw consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities can be found at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

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In the context of a business relationship or other relationship, customers, interested parties or third parties must only provide us with the personal data that is necessary for the establishment, execution and termination of the business relationship or for the other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

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Mandatory information is marked as such.

1.7 No automated decision-making in individual cases

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In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. If we use these procedures in individual cases, we will provide separate information about this if this is required by law.

1.8 Making contact

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When you contact us, e.g. by email or telephone, the data you provide us with (e.g. names and email addresses) will be stored by us in order to answer your questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in answering inquiries addressed to us. We delete the data collected in this context after storage is no longer necessary or restrict processing if there are statutory retention obligations.

1.9 Competitions

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We occasionally offer competitions via our website or in other ways. We process the data requested to determine and notify the winners. We then delete the data. We may also offer competitions only for existing customers. In this case, we only process the name to determine the winners and the contact details to notify the winners. It is in our legitimate interest to offer competitions to attract customers or to interact with our existing customers. The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.

1.10. Customer surveys

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From time to time, we conduct customer surveys to get to know our customers and their wishes better. We collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data once the results of the surveys have been evaluated.

2nd Newsletter

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We reserve the right to inform customers who have already used our services or purchased goods about our offers from time to time by email or other means if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in direct advertising (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time at no additional cost, for example via the link at the end of each email or by sending an email to our email address stated above.

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Based on the consent of the recipients (Art. 6 para. 1 sentence 1 lit. a GDPR), we also measure the opening and click rate of our newsletters in order to understand which content is relevant for our recipients.

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We send newsletters using the HubSpot tool from the provider HubSpot, Inc, 25 1st Street Cambridge, MA 0214, USA The provider processes content, usage, meta/communication data and contact data in the EU. Further information can be found in the provider's privacy policy at https://legal.hubspot.com/de/privacy-policy

3. data processing on our website

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3.1 Note for website visitors from Germany

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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). Please refer to the following sections to find out what information this is in detail.

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This storage and access takes place on the basis of the following provisions:

• Insofar as this storage or access is absolutely necessary for us to provide the service expressly requested by website visitors on our website (e.g. to implement a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 (2) No. 2 of the Telecommunications Digital Services Data Protection Act (TDDDG).
• Otherwise, this storage or access is based on the consent of the website visitor (Section 25 (1) TDDDG).

Downstream data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2 Informational use of the website

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When using the website for informational purposes, i.e. when visitors to the site do not send us information separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

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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 longer required, at the latest after 14 days.

3.3 Web hosting and provision of the website

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Our website is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sàrl, Avenue John F. Kennedy 38, 1855 Luxembourg, Luxembourg. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/de/privacy/?nc1=f_pr.

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It is our legitimate interest to provide a website, so that the legal basis for the data processing described is Art. 6 para. 1 sentence 1 lit. f GDPR.

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We use the Vercel content delivery network for our website. The provider is Vercel Inc, 340 S Lemon Ave Unit 4133 Walnut, CA, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication or contact data in the USA. Further information can be found in the provider's privacy policy at https://vercel.com/legal/privacy-policy.

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We have a legitimate interest in using sufficient storage and delivery capacities in order to ensure optimal data throughput even during large load peaks. The legal basis for the data processing described is therefore Art. 6 para. 1 sentence 1 lit. f GDPR.

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The legal basis for the transfer to a country outside the EEA is an 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 has decided that the third country offers an adequate level of protection as part of an adequacy decision in accordance with Art. 45 (3) GDPR.

3.4 Contact form

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When you contact us via the contact form on our website, we store the data requested there and the content of the message.

The legal basis for the processing is our legitimate interest in responding to inquiries addressed to us. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR.

We delete the data arising in this context after storage is no longer required, or restrict processing if there are statutory retention obligations.

3.5 Job advertisements

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We publish jobs that are vacant in our company on our website, on pages linked to the website or on third-party websites.

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The data provided as part of the application is processed in order to carry out the application procedure. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 BDSG. We have marked the data required to carry out the application process accordingly or refer to it. If applicants do not provide this data, we will not be able to process the application.

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Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

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We ask applicants to refrain from providing information on political opinions, religious beliefs and similar sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the CV or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

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Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.

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We pass on applicants' data to the responsible employees in the HR department, to our processors in the area of recruiting and to the other employees involved in the application process.

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If we enter into an employment relationship with the applicant following the application process, we will only delete the data after the employment relationship has ended. Otherwise, we will delete the data no later than six months after rejecting an applicant.

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If applicants have given us their consent to use their data for further application procedures, we will only delete their data one year after receipt of the application.

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3.6 Booking appointments

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Site visitors can book appointments with us on our website. For this purpose, we process meta or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly way to make appointments. The legal basis for data processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR. If we use a tool from a third-party provider for the agreement, the information can be found under "Third-party providers".

3.7 Customer account

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Visitors to the website can open a customer account on our website. We process the data requested in this context on the basis of the site visitor's consent. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. a GDPR.

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Consent can be withdrawn at any time, e.g. via the contact details provided in our privacy policy. Revocation does not affect the lawfulness of the processing up to the time of revocation. If consent is withdrawn, we will delete the data unless we are obliged or entitled to retain it.

3.8 Offer of goods

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We offer goods via our website. We process the following data as part of the order process:

• Name
• E-mail
• The company
• Address / Billing address

The data is processed for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 sentence 1 lit. b GDPR).

3.9 Technically necessary cookies

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Our website uses cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the website more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "technically necessary cookies"), the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.


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Specifically, we set technically necessary cookies that adopt language settings.

4. data processing on social media platforms

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We are represented on social media networks in order to present our organization and our services. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to display advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the network operators store information on user behavior in cookies on the user's computer. It is also possible that the operators may combine this information with other data. Users can find further information and information on how users can object to processing by the site operators in the privacy policies of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, meaning that they process data there. This may result in risks for users, e.g. because the enforcement of their rights is made more difficult or government agencies gain access to the data.

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When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

4.1 Instagram

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We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.2 LinkedIn

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

5. data processing in connection with deliveries and services of Purpose Green and with suppliers / service partners / service providers

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5.1 Categories of data

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With regard to the type of personal data concerned. data, we essentially distinguish between (i) master data, (ii) contract performance data, (iii) third-party data and - if relevant at all - (iv) special categories of personal data within the meaning of Art. 9 GDPR.

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a. Master data

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Master data is data about your company and/or your person that you provide in the context of contract initiation and/or contract conclusion. These result from the respective contract forms used by us and contain in particular details such as company name, surname, first name, address, date of birth, e-mail address, telephone number, fax and, for billing purposes, bank and account details. In addition, you can voluntarily provide us with further data with your application, e.g. a cell phone number, your preferred correspondence language or other interests and preferences. We refer to this data provided by you collectively as "master data".

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b. Contract performance data

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Contract performance data is data that arises in the course of contract performance or fulfillment and is processed by us for contract performance, billing, administration, further development or marketing of our offers, services and deliveries. Some of this data has no direct reference to a natural person, but as a rule such a personal reference can be established so that this data can be related to a person. Depending on the deliveries and services ordered or provided, the following data, for example, may be included in the contract performance data: (i) data required for the preparation of offers (including financing), (ii) data required for the ordering / utilization of deliveries and services (names of employees), (iii) payment and billing data or (iv) data / information in connection with the processing of customer inquiries or complaints.

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c. Third-party data

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Personal data is generally collected directly from you. However, it may also happen that we do not collect personal data directly from you, but that we receive it from third-party companies and/or contractual partners, e.g. as part of separate contractual relationships (so-called third-party data). Such third-party data relating to your company/person may, for example, be address data, billing data from third parties (e.g. from our service partners) or similar.

5.2 Deliveries and services of Purpose Green

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We process personal data in accordance with the relevant data protection regulations, in particular the GDPR and the BDSG. We process the data collected about you and/or your company - subject to the applicability of data protection regulations - in connection with the provision of our services as follows:

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a. Purposes and legal bases

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We collect and process personal data for the following purposes and legal bases:

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i. Deliveries and services

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Master data, contract performance data and third-party data - which may include data of our customers and service partners, including data of their employees and/or staff - are processed by us for the purpose of contract initiation, contract conclusion and the provision of our deliveries and services, insofar as processing is necessary for this purpose. This includes, in particular, data processing for the purpose of providing services, including the billing of these services.

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The legal basis for the aforementioned data processing between the parties involved is Art. 6 para. 1 lit. b GDPR. Under data protection law, this takes place within the framework of so-called controller-to-controller relationships; we will be happy to provide further information on this upon request.

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ii. Invoicing of deliveries and services

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For the purpose of invoicing our deliveries and services, we use the master data provided by customers, the contract implementation data required for invoicing (e.g. services used, etc.) and, in individual cases, third-party data (e.g. if customers purchase operating resources via third-party service partners of Purpose Green Real Estate). The legal basis for such processing is Art. 6 para. 1 lit. b GDPR (fulfillment of contract / implementation of pre-contractual measures) and Art. 6 para. 1 lit. f GDPR (legitimate interests).

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iii. Enforcement of claims / fulfillment of legal obligations

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We reserve the right to use personal data for the extrajudicial and judicial enforcement of claims. The legal basis for such processing of data is Art. 6 para. 1 lit. b GDPR (fulfillment of contract / implementation of pre-contractual measures) or Art. 6 para. 1 lit. f GDPR (legitimate interests). Data may also be processed and/or transmitted for the purpose of fulfilling statutory or legal obligations (e.g. information from authorities, etc.); the legal basis for this is Art. 6 para. 1 lit. c GDPR.

• Electrical customer accounts / accounts

We offer our customers the option of setting up an electronic customer account for the use of certain services and/or performances. We collect and store the following personal data ("mandatory data") as part of the registration and setup of this customer account:

• Business e-mail address of the user,
• Password,
• First name, surname, title (of the person stored in the customer account)
• Company (where relevant),
• Address, country, state and city of the company.

At the time of registration, (i) the user's IP address and (ii) the date and time of registration are also stored.

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In addition, voluntary information can be provided. This information may include, for example, telephone number, fax number, mobile phone number or information about the company such as the number of employees, industry. Mandatory fields are marked with an asterisk in the input mask if they are required for the purpose of registration. Registration cannot take place if the mandatory fields are not filled in completely and truthfully. Registration is only complete when you confirm the link contained in an e-mail sent by us after completing the mandatory fields. This information may be used on an anonymous basis for the purpose of improving our services, among other things.

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b. Research / (product) development, product improvement, product safety, product quality

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To the extent permitted by applicable law, Purpose reserves the right to process personal data of its customers, which are collected and processed in the context of the provision of services and/or services by Purpose and/or by Purpose partners, in de-personalized form for the purposes of research, product development and product improvement, product and IT security and to ensure product and service quality. "De-personalized" means that data can no longer be traced back directly to customers, suppliers/subcontractors or employees of the customer. For this purpose, Purpose may therefore process personal data in order to generate "de-personalized" data sets, which are then used to improve Purpose's products and services.

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The legal basis for such processing is Art. 6 para. 4 GDPR (change of purpose) and Art. 6 para. 1 lit. f GDPR (legitimate interests). Purpose's legitimate interests lie in using "de-personalized" data to meet the high expectations of its customers in the provision of high-quality services and services, to improve products and services, to ensure product and IT security and to meet the demand for newly developed, innovative solutions and/or services.

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To protect the interests of the customer, including their employees, additional precautions and data security measures are taken and implemented as required - in addition to depersonalization - e.g. strict data access restrictions, restrictions on data use, security measures, retention periods and data minimization principles, such as the exclusive collection of relevant data.

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c. Any recipients

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As part of the provision of our services and the associated processing of personal data, our employees have access to data in accordance with the "need-to-know" principle. Data, our employees have access to data according to the so-called "need-to-know principle" in order to fulfill the purposes mentioned in section 5.2.a.. This means that the group of authorized persons is limited to those employees who are required to fulfill the respective processing purpose.

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In order to fulfill the purposes mentioned in section 5.2.a., data may also be processed by (technical) service providers, service providers, subcontractors, vicarious agents and/or service partners who work for Purpose to fulfill the aforementioned purposes. The companies belonging to Purpose (Purpose Green transformation GmbH; Manage to Green GmbH; Purpose Green Real Estate GmbH) are used in particular in the context of contract execution.

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Data is also processed and transmitted in the context of payment transactions (e.g. to banks, payment service providers).

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Data may also be transferred to courts, lawyers, debt collection agencies and/or public authorities for the purpose of enforcing claims and/or fulfilling legal obligations (e.g. reporting obligations, follow-up performance obligations in the event of product warnings, etc.).

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d. Data processing outside the EEA

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Data processing outside the European Union (EU) and/or the European Economic Area (EEA) does not take place as a matter of principle. Insofar as data processing should take place outside the EEA, this is carried out for the purpose of executing the contract in accordance with Art. 49 GDPR, in particular Art. 49 para. 1 lit. b and/or lit. c GDPR.

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e. Data erasure, storage duration, revocation and objection options

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If personal data is processed in connection with the fulfillment of a contract or for the implementation of pre-contractual measures (Art. 6 para. 1 lit. b GDPR), the data will be stored for the duration of the respective order or contractual relationship and deleted or blocked after expiry of the respective contract term or notice period. Instead of deletion, the data may be stored with restriction of processing if this is provided for by the European or national legislator in EU regulations, laws or other provisions to which our company is subject, in particular e.g.

• to fulfill statutory retention obligations (e.g. the German Fiscal Code (AO) or the German Commercial Code (HGB), currently between 6 and 10 years), and/or
• if there are legitimate interests in storage (e.g. during the course of limitation periods for the purpose of a possible legal defense (§§ 195 ff. BGB, currently between 3 and 30 years).

The legal basis for this is Art. 6 para. 1 lit. c or lit. f GDPR. The data will be deleted at the latest when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion of a contract or for other purposes (e.g. legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR).

Insofar as Art. 49 GDPR does not intervene and Purpose is responsible for data processing on site under data protection law, Purpose will take further necessary measures to ensure an adequate level of data protection. We will be happy to provide further information on this upon request.

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f. Obligation to provide personal data (so-called mandatory information)

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Data that is required for the initiation, conclusion or performance of a business relationship, including the fulfillment of associated contractual obligations and/or which we are legally obliged to collect, is mandatory information. Mandatory information is marked with an asterisk in our forms. If this data is not provided, we may not be able to provide a contract and/or service or only to a limited extent; we reserve the right to refuse to conclude a contract if mandatory data is not provided.

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g. Automated decision-making / profiling pursuant to Art. 22 (1) and (4) GDPR

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We do not use fully automated decision-making within the meaning of Art. 22 GDPR to establish and conduct the business relationship. Profiling based on the data collected and processed by us does not take place.

5.3 Suppliers / service partners / service providers

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We process personal data of suppliers and/or service providers (hereinafter uniformly referred to as "suppliers") who are natural persons and whose services we request and/or use on a contractual basis exclusively for the purpose of fulfilling or implementing the contract. This may involve master data, contract performance data and third-party data. The legal basis for such data processing is Art. 6 para. 1 lit. b GDPR (fulfillment of contract / implementation of pre-contractual measures).

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Furthermore, we reserve the right to process pers. data of our suppliers for the purpose of enforcing claims within the scope of legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. This includes, in particular, the transmission of data to credit rating service providers, authorities and/or courts. Data may also be processed and/or transmitted for the purpose of fulfilling statutory or legal obligations (e.g. information from authorities, etc.); the legal basis for this is Art. 6 para. 1 lit. c GDPR.

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Please note that data protection law may not apply to suppliers that are legal entities (see definition of personal data in Art. 4 para. 1 GDPR).

6. changes to this privacy policy

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We reserve the right to amend this privacy policy with effect for the future. A current version is always available here.

7. questions and comments

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If you have any questions or comments regarding this privacy policy, please do not hesitate to contact us using the contact details above.