Privacy Policy

In this Privacy Policy (“Policy”) IGEL Technology GmbH (“we” or “IGEL”) would like to inform you about the processing of your personal data when visiting our website and using other selected IGEL services in accordance with Art. 13 of the General Data Protection Regulation (“GDPR”).

1. Controller

The controller responsible for this data processing is IGEL Technology GmbH, Maria-Cunitz-Str. 7, 28199 Bremen, Germany. You can find further information in our imprint.

2. Data Processing Activities

2.1. Our website

We have designed our website (igel.com) so that it may generally be used with very little data processing. This basic processing is described in Section 2.1.1 and 2.1.2 of this policy.

2.1.1. Access to the website

When you access our website, we store the IP address transmitted by your web browser for a period of seven (7) days, strictly for the purpose of identifying, restricting and eliminating attacks on our website. After seven (7) days, we delete or anonymize your IP address. The legal basis for the processing of this personal data is Art. 6 (1) (f) GDPR. We have a legitimate interest in protecting the integrity of our website, its content and the security of its users.

2.1.2. Using the website

When you are using our website, we collect data on your use of the website and temporarily store such data on our web server for statistical purposes in order to improve the quality of our website. This data includes:

• information on the page or file you interact with, including:
• the page or file name,
• when you interacted with the page or file,
• how much data was transferred,
• whether you were able to access the file,
• a description of the type of browser used,
• the IP-address of the requesting computer shortened to such an extent that no reidentification of any personal data is possible.

The above-listed usage data is stored anonymously.

The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in using this information to enable our website to be accessed, to control and administer our systems, and to improve the design of our website. This data is not passed on to any third parties.

2.1.3. Contact Forms

While using our website, you might share your data with us, particularly in the context of contact forms. We use that data to process your request, route your request internally, and respond to your request.

In these forms you might enter data such as:

• Personal contact and identification data, this includes your name, phone number and email address, and
• Professional contact and data, this includes your professional phone number and e-mail address, organization affiliation, job title and professional address.

The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in processing and responding to your request, which mirrors your interest in having your request responded. Your data will be deleted as soon as it is no longer necessary for the initial purpose and will not be transmitted to third parties, other than those necessary for the processing of your request.

All forms on our website are provided by and managed with Act-On (Act-On Software, Inc with its principal place of business at 121SW Morrison Street, Suite 1600, Portland, Oregon 97204 U.S.A.). When you click the “Contact” or “Get Free Licenses” or a similar button, the form and its contents are processed by Act-on Software, Inc. Act-On Software, Inc. is a US Company. If in the course of processing, your data is transferred to Act-On in the USA, the security and confidentiality of your personal data during those transfers is secured by a sufficient and appropriate data transfer mechanism.

Most of our forms are forwarded to our Microsoft Dynamics Environment for internal processing. As part of this forwarding, your data is also processed by Microsoft Ireland Operations Ltd. as our Cloud-services provider. Microsoft Ireland generally processes your data in European data centers. If, in the course of processing, your data is transferred to Microsoft Corporation or its affiliates in the USA, those transfers are secured by  sufficient and appropriate data transfer mechanisms.

2.1.4. Live-Chat Tool

You might also share your personal data with us when participating in our Live-Chat. To enter the Live-Chat you will provide us with:

• Your name and,
• Your email address.

While using the Live-Chat you may choose to share additional personal data with us. This will be limited to what you decide to enter into the chat window.

The legal basis for this processing is your consent according to Art. 6 (1) (a) GDPR.  You can withdraw your consent at any time by contacting us ([email protected]).

The Live-Chat functionality is provided by our supplier ServiceNow (ServiceNow Nederland B.V., Hoekenrode 31102 BR Amsterdam, Netherlands). If, in the course of processing, your data is transferred to ServiceNow, Inc. in the USA, those transfers are secured by a sufficient and appropriate transfer mechanism.

2.1.5. Newsletter

We provide the opportunity to subscribe to our newsletter through many channels. Subscription to our newsletter is in principle an interaction separate from other interactions on the website, but you may also subscribe to our newsletter when applying for a test-license or when contacting us via our contact form.

We collect the following data when you subscribe to our newsletter:

• Your email address,
• Your consent to receive our newsletter in conjunction with your IP-address and the time of your consent.

The legal basis for this processing is your consent according to Art. 6 (1) (a) GDPR. You can withdraw your consent at any time by contacting us at [email protected], following your withdrawal of consent we will stop the corresponding processing. This has no impact on the lawfulness of prior processing. You may also unsubscribe from the newsletter at any time, via the unsubscribe link which you will find in every newsletter email.

Your data will be processed by Act-On Software, Inc. (please see 2.1.3 for more details) for the purpose of managing and sending out the newsletter.

2.1.6. Cookies and social media plugins

2.1.6.1. Cookies

We use cookies on our website. Cookies are small pieces of data that are stored and read in your end-device. Cookies may contain data that enables the recognition of the device being used. However, in some cases cookies only contain information on certain settings which are not personal data.

We use session cookies, temporal, and permanent cookies on our website. In the case that personal data is processed, the processing is based on your consent in accordance with Art. 6 (1) (a) GDPR.

Please be aware that you can set up your browser to inform you when cookies are being stored or used on the website you are visiting. Thus, any use of cookies is transparent to you.

You can see a detailed list of the cookies used on our website and manage your consent in our separate cookie notice.

2.1.6.2. Google Analytics

We use Google Analytics (GA4) to create pseudonymous user profiles for improving and designing our website on demand. Google Analytics uses “cookies”, and other tracking tools which can be read by us. In this way, we are able to recognize and count returning visitors. This data processing is carried out based on your consent  according to Art. 6 (1) (a) GDPR. Google analytics is only enabled when you consent to the use of statistic cookies. The information generated by the cookies about your use of the website will be transmitted to and stored by Google on their servers. If you are located in the EU those servers will also be located in the EU. GA4 processes EU IP-addresses for the geo-localization required for this routing but does not store IP addresses beyond that. While Google also aims to process analytics data on regional servers, the possibility of transfers to the USA can not be excluded. If in the course of processing, your data is transferred to Google in the USA, those transfers are secured by a sufficient and appropriate transfer mechanism.

2.1.6.3. Embedded YouTube Videos

We have also decided to only embed YouTube Videos using the NoCookie function on our site. With the NoCookie function, pages with embedded videos transfer only your decision whether you consent or not to marketing cookies to YouTube and its affiliates. If you consent to marketing cookies, additional cookies may be used and transferred.

2.2. IGEL Community

We also operate the IGEL community platform (igelcommunity.com), which you can join to collaborate and interact with other users of IGEL and get community-based support on IGEL solutions. When registering with the IGEL community you share certain personal information with us:

• Your email address is required for registration,
• You may include personal information, such as your real name in your username, but this is not required.
• Organization Affiliation
• Country

Our operation of the IGEL Community is assisted by Slack Technologies, LLC with its principal office at 500 Howard Street, San Francisco, CA-94105, USA and the processing of your registration to the IGEL Community is supported by Google Ireland Ltd. and MailJet GmbH.

After registration, when using the IGEL community, as we do for our main website, we process your IP-address to provide our website to you and for the purpose of identifying, restricting and eliminating attacks on our website. This processing is based on Art. 6 (1)(f) GDPR. We have a legitimate interest in protecting the integrity of our website, its content and the security of its users.

When interacting with the IGEL community you may share further personal information in the messages you send. Our processing of such information is based on your consent according to Art. 6(1) (a) GDPR. You can delete your messages and any personal information contained in them at any time.

We use the timestamps of the messages as an indication of engagement within the IGEL Community. The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in evaluating the interactions on the IGEL community to improve the quality of those interactions and the IGEL community as a platform. For this purpose, your personal data is processed by Pythonanywhere LLP. Pythonanywhere is located in the UK. When data is transferred to Pythonanywhere in the UK, the data transferred is protected by sufficient and appropriate transfer mechanisms.

The IGEL community also offers a polling system based on Polly by Subcurrent, Inc. with its principal office at 300 Lenora Street PMB 6148, Seattle, WA 98121, USA.

Subcurrent will receive and process the following personal data as provided in your Slack account:

• Your name,
• Your email address,
• Your username.

The polling system is used to gather your feedback on the IGEL Community and to better understand its requirements. The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in evaluating the requirements of the IGEL community to improve the quality of the IGEL community as a platform.

Subcurrent, Inc. is a US Company. If data is transferred to Subcurrent in the USA, the data transfer is protected by sufficient and appropriate transfer mechanisms.

2.3. IGEL Knowledge Base

We operate the IGEL Knowledge Base (kb.igel.com) as a repository of technical documentation for IGEL products.

While using the IGEL Knowledge Base, you have the option to rate or comment on articles. This functionality is provided by HyvorTalk and processing is supported by HYVOR with its principal place of business at 11 RUE CARNOT 94270 LE KREMLIN-BICETRE France.

If you decide to rate or comment on articles, you have two options:

1. You may comment as a guest user.
2. You may register an account with HYVOR and use that account to rate or comment.

We process your personal data depending on the authentication method chosen by you.

If you chose to comment as a guest user (1.), the following personal data will be processed:

• Your IP-Adress,
• Your chosen name,
• Optionally, your email address.

If you choose to register an account with HYVOR (2.), the following personal data will be processed:

• Your IP address,
• Your name,
• Your username,
• Your Hyvor Talk activity on our website.

This processing is based on your consent in accordance with Art. 6 (1) (a) GDPR. You can withdraw your consent at any time by contacting us ([email protected]) or by deleting your comments in the knowledgebase.

Since the Knowledge Base is an IGEL website, 2.1.1 and 2.1.2 apply accordingly.

2.4. IGEL Licensing Portal

We provide the IGEL Licensing Portal (activation.igel.com) for the activation of purchased IGEL product licenses by the customer. When you register for the Licensing Portal, the following personal data will be processed:

• Your first and last name,
• Your email address,
• Your phone number,
• Your preferred language,
• the name and address of the organization you are registering for,
• activated product packs/licenses for your account (including date of activation).

This data is processed for the purpose of activating the purchased licenses for IGEL products. The processing is based on Art. 6 (1) (f) GDPR We have a legitimate interest in processing data that is necessary to perform our End User License Agreement (EULA) with the organization on whose behalf you are activating the licenses.

In addition, the Licensing Portal keeps logs of the following actions you perform as a user:

• Activation of new/additional product packs/licenses (including user, date and time),
• (Re-)Assignment of product packs/licenses to another entity managed in the account (including user, date and time).

This data is logged in order to provide a transparent audit trail for possible tax or financial audits (of IGEL or IGEL customer’s). The processing for IGEL is based on Art. 6 (1) (c) GDPR in conjunction with the applicable audit obligations from national statutory regulations (for example, in Germany Section 256 Commercial Code (Handelsgesetzbuch) and/or Section 147 Tax Code (Abgabenordnung). Where the obligation does not arise directly from a law, but from self-imposed compliance obligations, or from obligations of a customer, the legal basis is legitimate interest in accordance with Art. 6 (1) (f) GDPR. IGEL has a legitimate interest to allow its customers to track the allocation of assets (which also includes activated IGEL licenses) in an auditable manner to comply with their audit obligations.

Since the License Portal is an IGEL website, 2.1.1 and 2.1.2 apply accordingly.

2.5. IGEL Customer Portal

We provide the IGEL Customer Portal (support.igel.com) as the central point of contact for our customer support. When you register on our Customer Portal and submit a support request, the following personal data will be processed:

• Your email address,
• Your username,
• the name of the organization you are registering for,
• the time and date of your support request and further answers to the support ticket,
• potentially any information you include into the support request.

The data is processed for the purpose of addressing your support ticket and for the performance of support services by IGEL. The processing is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in processing data that is necessary to fulfil our maintenance and support agreement with the organization procuring our support services, i.e. your employer or client.

We use ServiceNow (ServiceNow Nederland B.V., Hoekenrode 31102 BR Amsterdam, Netherlands) as a service provider to operate our Customer Support Portal. If in the course of processing, your data is transferred to ServiceNow in the USA, those transfers are protected by sufficient and appropriate transfer mechanisms.

Since the Customer Portal is an IGEL website, 2.1.1 and 2.1.2 apply accordingly.

2.6. IGEL App Portal

When using the IGEL App Portal (app.igel.com), your email address will be processed to enable access to the App Portal via Single-Sign-On.

The data is processed to enable access to and use of the App Portal. The processing is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in processing data necessary to fulfil our contractual obligations from our EULA and Cloud Services Terms of Use with the organization procuring our products and services, i.e. your employer or client.

We use AWS Cognito (Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855 Luxembourg) as a service provider to enable Single-Sign-On for the App Portal. If in the course of processing, your data is transferred to AWS in the USA, those transfers are protected by sufficient and appropriate data transfer mechanisms.

We use Cloudflare (Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, United States) as a service provider to enable content delivery for the App Portal. If data is transferred to Cloudflare in the USA, the data transfer is protected by appropriate and sufficient data transfer mechanisms.

Since the App Portal is an IGEL website, 2.1.1 and 2.1.2 apply accordingly.

2.7. IGEL Insight Service

We need specific analytical and usage data from all users to continuously,

• improve our products and services and the user experience,
• inform you about available software and security updates,
• provide recommendations for system optimization (software and hardware),
• identify potential performance issues regarding apps in your setup,
• improve customer support and consulting,
• provide you with direct access to software and hardware insights, e.g. reports, based on your data.

The Legal basis for this data processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in pursuing the above detailed purposes to improve our products and services and to provide our customers with more secure, up-to-date, and optimized software as well as optimal customer support.

Data collected by the Insight Service:

• Organization Identifier,
• UMS Identifier,
• Pseudonymized Device Identifier,
• Name of Application,
• Version of Application,
• Manufacturer of Device,
• Model of Device,
• CPU of Device,
• RAM of Device,
• Mainboard of Device,
• GPU of Device,
• Storage Hardware of Device,
• Network / Wi-Fi Hardware information of Device,
• Peripheral Hardware information of Device,
• Timestamp,
• Client type,
• Client version

We do not share your data with third parties outside the IGEL group. Your data is stored on servers in the EU.

The identity of the individual end user’s IGEL device will only be stored pseudonymously. The data will be deleted after five years.

You can object to the processing of your personal data by disabling the Insight Service functionality in your UMS settings. Please note, however, that if you object, you will not receive further recommendations based on your setup and you will not be provided with access to software and hardware insights based on your data.

2.8. Online Job Application

When you apply for a job at IGEL, we process your personal data in order to process your application. This processing is governed by a separate privacy policy which you can find at https://www.igel.com/ats-privacy-policy/

2.9. Social Media Pages

We operate official social media on Facebook, X (formerly known as Twitter), LinkedIn, and YouTube under the URLs https://www.facebook.com/igel.technology, https://twitter.com/IGEL_Technology/, https://www.linkedin.com/company/igel-technology, https://www.youtube.com/user/IGELTechnologyTV.

You may choose to, but are not required to, interact with our social media channels, e.g. through comments, videos, images, or likes. You may also choose to share additional personal data withing those interactions with us.

We process this data in the operation of our social media channels to generate business publicity, to interact with you and to enable you to interact with us. The legal basis for this processing is your consent according to Art. 6 (1) (a) GDPR. You can withdraw this consent at any time (e.g. by deleting or removing your interaction on the platform, or by sending an email to [email protected]). Please be aware that we are not able to edit or delete your interactions on these social media platforms.   Facebook, X.com, YouTube, and LinkedIn use web tracking methods on those sites. Please be aware that they may use your profile data to evaluate your habits, personal relationships, preferences, etc. We have no influence on the processing of your data by these platforms.

If you want to follow IGEL News without using the platforms mentioned above, you may subscribe to our RSS-feed available at https://www.igel.com/feed/.

2.10. Contact for Business Communications

We may process your personal data when we initiate and execute a contractual relationship with your organization, whether your organization is a (potential) customer, partner or supplier of IGEL. In this context, the following data is regularly processed by email and/or in our internal IT systems (for example in our CRM or ERP systems):

• Your name,
• Your email address,
• Your phone number,
• Your organization (including the organization’s address),
• Your role in your organization,
• Potentially any information you chose to include in the communication.

The purpose of data processing is establishing and executing the respective customer, partner or supplier contract with your organization. The legal basis is Art. 6 (1) (f) GDPR. It is IGEL’s legitimate interest to process your personal data to initiate and execute a contract with the aforementioned organization.

IGEL uses IT systems and applications of service providers for the performance of business communications and may transfer data to these service providers only according to applicable laws.

2.11. Live Events

We organize live events from time to time, which you may attend. In the preparation and execution of those events we may process your personal data to allow you to register for and participate in such events, as well as to enable us and our sponsors or partners to contact you. Personal data processed for these purposes includes:

• Contact data, this includes your name, phone number and professional email address, and
• Data on your organization, this includes your organization affiliation, your job title and organization address.

The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest in processing registrations for our events to enable their execution and to provide an enjoyable and productive experience for all attendees.

• Optionally, if you provide such data to us, we may process your dietary preferences to provide appropriate catering and food options.

The legal basis for this processing is your consent according to Art. 6 (1) (a) GDPR. You can withdraw this consent at any time (e.g. by sending an email to [email protected]).

We use Cvent (Cvent Deutschland GmbH, c/o TMF Steuerberatung GmbH WPG, Maximilianstr. 54, 80538 München, Germany) as a service provider for our event registrations. If, in the course of processing, your data is transferred to Cvent, Inc. in the USA, those transfers are protected by sufficient and appropriate data transfer mechanisms.

We may also share your personal data with: (a) sponsors of our events,  if you have consented during your registration for your information to be shared with them to contact you for promotional or marketing purposes, and (b) other attendees of our events, if you have consented to be searchable in the event app for professional networking.  The legal basis for this processing is your consent according to Art. 6 (1) (a) GDPR. You can withdraw this consent at any time by sending an email to [email protected].

3. Additional Recipients and Data Transfers

3.1. Additional Recipients

Generally, your data will only be shared with the recipients listed above for the respective data processing activity. However, IGEL may transfer your data to third parties if we are required to do so based on statutory requirements or on administrative or judicial orders or based on another applicable legal bases.

Third parties which may receive your data are:

• Governmental authorities in the scope of their duties.
• Courts of law in the course of legal proceedings or orders.
• Other third parties, as far as you request/instruct us to transfer data to that third party or give your consent to the transfer or another legal basis applies for the transfer.

3.2. Data Transfers to Third Countries

We generally aim at processing your personal data within the European Union / European Economic Area. Only in limited circumstances, your data will be transferred to third countries. In such cases your data will be protected by appropriate safeguards in accordance with Art. 44 GDPR, for example the EU Commission’s Standard Contractual Clauses (SCCs) or other appropriate data transfer mechanisms. Please refer to the description of the respective data processing activity above for further information on potential third country transfers. Additional information may be provided upon request.

3.3. Do not Sell

This section is only applicable where required by US State Law (e.g.  for Residents of California). We don’t sell your personal data to third parties. For clarity, we have not sold your personal data to any third parties in the last twelve (12) months. We also do not share your data with third parties without your consent. If you have consented to it, we may share, not sell, your data with selected partners for marketing purposes. In the last twelve (12) months we have shared the following categories of data with the recipients listed below

Data categories	Recipients	Restriction
Name, contact information, and professional identification information	Third parties that sponsor our live events and attendees of our live events	Only applies if you have consented to your information being shared
IP-Addresses, your activity on our website	Cookie providers and marketing partners; See our cookie notice for more information.	Only applies if you have consented to marketing cookies.

You may opt out to having your data shared with third parties by following the process outlined in Section 5.7 of this policy.

4. Storage and deletion of data

In general, we store your data only as long as necessary to achieve the intended purpose. After the intended purpose has been achieved, we delete your personal data.

However, we might be required to store your data for a longer period to comply with statutory obligations or if required by administrative or judicial orders or to exercise or defend ourselves against legal claims. Additional information regarding storage and deletion of your data may be provided upon request.

5. Your rights

Under the GDPR you have certain rights relating to the processing of your personal data.

5.1. Right of access (Art. 15 GDPR)

You have the right to obtain confirmation as to whether personal data concerning you is being processed by IGEL, and, where that is the case, you have the right to be informed about the scope of personal data processed by us.

5.2. Right to rectification and erasure (Art. 16 and 17 GDPR):

You have the right to obtain the rectification of inaccurate personal data concerning you and, if necessary, the right to have incomplete personal data completed without undue delay.

You also have the right to request the erasure of the personal data concerning you that IGEL processes without undue delay, if one of the reasons listed in Art. 17 GDPR applies, e.g. if the data is no longer necessary for the intended purpose. If your data was transferred to third parties in the course of processing, we will initiate the necessary steps to delete transferred copies of your data as well. Please note that the right to erasure may be partly deferred if we are required to process your data longer than initially necessary as laid out in Section 4 of this policy.

5.3. Right to restriction of processing (Art. 18 GDPR):

If one of the conditions set forth in Art. 18 GDPR applies, you shall have the right to restrict the processing of your data to simple storage, e.g. if you object to the processing, for the duration of a possible evaluation of your objection.

5.4. Right to data portability (Art. 20 GDPR):

In certain situations, listed in Art. 20 GDPR, you have the right to receive the personal data concerning you that we process in a structured, common and machine-readable format or demand a transmission of the data to another third party.

5.5. Right to object (Art. 21 GDPR):

If the data is processed pursuant to Art. 6 para. 1 lit. f) GDPR (data processing for the purposes of our legitimate interests), you have the right to object to the processing at any time for reasons arising out of your particular situation. We will then no longer process your personal data, unless there are demonstrably compelling legitimate grounds for processing, which override your interests, rights and freedoms, or when the processing serves the purpose of asserting, exercising or defending legal claims.

5.6. Right to lodge a complaint with a supervisory authority

Pursuant to Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of the data concerning you infringes data protection regulations. The right to lodge a complaint may be invoked in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement.

The supervisory authority responsible for IGEL is:

The state representative for data protection and information freedom of the free and hanseatic city of Bremen
Arndtstraße 1, 27570 Bremerhaven, Deutschland

5.7. How to exercise your rights

If you want to exercise any of the rights described above or according to any applicable laws, please contact us at [email protected] or contact the IGEL Data Protection Officer using any of the methods listed below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You have a right not to receive discriminatory treatment from us for exercising your rights as a user.

5.8. Our data protection officer

Please contact our data protection officer if you have any further questions, suggestions or wishes regarding data protection:

• For Germany (IGEL Technology GmbH):

datenschutz nord GmbH,
Konsul-Smidt-Straße 88, 28217 Bremen, Germany
[email protected], +49 421 69 66 320

• For other European IGEL entities (IGEL Technology (Austria) GmbH; IGEL Technology BVBA, Belgium; IGEL Technology B.V., The Netherlands; IGEL Technology SRL, Romania; IGEL Technology Ltd., Great Britain; IGEL Technology SAS, France; IGEL Technology ApS, Denmark; IGEL Technology AB, Sweden):

FIRST PRIVACY GmbH,
Konsul-Smidt-Straße 88, 28217 Bremen, Germany
[email protected], +49 421 69 66 32 80

• North America and South America (IGEL Technology Corporation)
• and Australia (IGEL Technology PTY LTD):

[email protected]

6. Updates to this Privacy Policy

As data processing at IGEL may change, this policy is subject to constant updating and modification. You can find the latest version of this Policy at: https://www.igel.com/privacy-policy/.