As of: 1st March 2020. Version 1.2

1. The Responsible Authority/ The Contact

The responsible authority for the processing of data in accordance with the legal regulations of the GDPR/ DSGVO is:

Tracks GmbH
The Drivery, Mariendorfer Damm 1
12099 Berlin

The company is registered by the District Court Charlottenburg (HRB 193697 B) and represented by its Managing Director - Jakob Muus.
For questions or comments on data protection matters, please contact us via e-mail at: contact-(at)

2. General Information

The protection of personal data of our customers, employees and business partners is an important concern for us. When processing your data, we observe the specifications of the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG). This Privacy Policy particularly describes the way our company processes personal and/or telematic data, as well as the rights of the data subjects (or the persons concerned), including the way they can contact us.

We process personal and/or telematic data of the users of our website only to the extent, which is necessary for the provision of functionality of our website and for providing of our services. The processing of any data by us takes place only with the prior consent of the affected user (the data subject). In the case when the prior consent could not be obtained beforehand for legal reasons, the data processing is permitted to the extent and in accordance with the legal regulations.

3. Legal Basis for the Processing of Personal Data

We process any kind of data in accordance with the legal regulations of the Art.6 of the General Data Protection Regulation (GDPR). This means that:

a) the personal data is processed by Tracks GmbH with the appropriate consent of data subjects to the processing of their data. Art. 6 paragraph 1 (a) of the GDPR is the legal basis for it.

b) if personal data are processed for the performance of a contract, to which the data subject is a party, the legal basis shall be Art. 6 paragraph 1 (b) of the GDPR.

c) the same applies to the processing operations that are necessary for the implementation of pre-contractual measures.

d) in accordance with Art. 6 paragraph 1 (c) of the GDPR, Tracks GmbH processes personal and/or telematic data in fulfillment of the company’s legal obligations (providing of its services).

e) if vital interests of the person concerned or another natural person requires the processing of their data, the legal basis shall be Art. 6 paragraph 1 (d) of the GDPR.

f) if processing of data is necessary for the protection of legitimate interests of our company or a third party, and does not overshadow the interests, fundamental rights and freedoms of the person concerned. Art. 6 paragraph 1 (f) of the GDPR is the legal basis for it.

4. Deployment of the Website and the Use of Log Files

When you visit our website, our system automatically collects data and information from the your device. The following data are collected:

- the type of your web browser and its version,
- the operating system of your device,
- the domain of your internet provider,
- the date and time of access,
- your IP address

These data are collected for statistical purposes - for the improvement of the performance of our Website and the enhancement of your experience from using it.

5. Registration and Contact Forms

As a user of our website you can register on our website or contact us, which implies providing us with some of your personal data. You enter these personal data in the relevant entry forms through which these personal data are transmitted to us and stored. A transfer of your personal data to third parties does not take place in this case.

The following personal data are collected through the registration and contact forms:
- your first and last name, and/or
- the name and address of the company you represent,
- your or your company’s e-mail address,
- if you use our contact form: your message

An alternative to our contact form is the provided e-mail address. If you decide to contact us by this option, the personal data transmitted by e-mail will be stored.

Legal Basis

As part of the registration, we will get your consent for the processing of your personal data in accordance with Art. 6 paragraph 1 (a) of the GDPR. Art. 6 paragraph 1 (f) regulates the storage of your e-mail address. Whereas Art. 6 paragraph 1 (b) of the GDPR is applied when in the process of registration personal information is shared as a part of the fulfillment of a contract/ agreement with us.

Purpose of Data Processing

The information collected and used in the process of registration on our website is used by us to provide you with our services and to secure the technology we develop.

The personal data collected through our contact form is used for communicative purposes only - to receive your feedback or inquiry, and to respond to them by providing you with the information about our services or related matters.

Duration of Storage

Your personal and/or telematic data are stored on Tracks GmbH data server at AWS data center (Frankfurt) for the time required for the implementation of the company’s services and will be deleted as soon as it is no longer necessary for the fulfillment of the company’s purpose. For example, in the case when your registration on our website was canceled.

Personal messages received by Tracks GmbH through our Contact Form or via e-mail will be deleted as soon as the respective conversation with the client is over or the matter in question is clarified. Any additional personal data collected during such communication process will be deleted after a period of seven days.

Managing your personal data

You have the right to change your personal data (the name or e-mail address) or to revoke your consent for our processing of your personal data at any time by sending us a corresponding request at contact (at)

6. Use of Cookies

Please also note the Cookie Policy, which specifically explains how we use cookies on our website and the associated web applications. It explains what cookies are, why they are used and how you use them.

Description and scope

A cookie is a small data element (text file) that a website asks a browser to save to your device when a user visits it so that the website remembers your actions and settings (such as login, language, font) Size and other display settings) over a period of time, so you don’t have to re-enter them every time you return to the website or scroll from page to page. We set these cookies and call them first-party cookies. We also use third-party cookies for our advertising and marketing efforts - cookies from a domain other than the domain of the website you are visiting.

Legal basis for data processing

We process personal data using technically necessary cookies in accordance with Art. 6 Para. 1 lit. f GDPR. For the processing of personal data using cookies for analysis purposes, we obtain the user's consent in accordance with Art. 6 para. 1 lit. a GDPR.

Purpose of data processing

The use of technically necessary cookies helps us to simplify the use of our website for the users. Some functions of the website cannot be offered without the use of these cookies. User data collected through technically necessary cookies are not used to create user profiles. Analysis cookies help us to improve the quality of our website and its content. We learn how our website is used and can constantly optimize our offer.

Manage cookies

When you visit our website, you will be informed of our cookie policy via a pop-up window and can give us your consent to the use of cookies. You can accept our cookies or prevent them from being stored on your devices by changing the corresponding settings in your browser. However, if you disable cookies (or disable them by default), your experience with our website may be affected and some features of this website may not work as intended. Notwithstanding the foregoing, you cannot restrict or refuse cookies that are strictly necessary for the provision of the website to you.

7. Links to Social Media

We use links to social media on our website. These links in the form of icons can be found on the bottom navigation bar of our website. If you click on any of these social media icons, you will be redirected to the respective page and will need to log in or register on this page. At the moment you switch to any of the third party websites, a cookie of this third party will be stored on your device. If you do not click the link to the denoted social media pages, no third-party cookies will be used. If you choose to switch to a third-party website from our homepage, processing of your data and your rights in this regard are regulated by cookie- and privacy policies of the respective third party.

8. SSL encryption/ TLS encryption

For security reasons, to protect the transmission of confidential content, we use the SSL /TLS encryption on our website. The encryption can be detected by changing the address line of your browser from 'http: //' to https: // ' - in this case a lock symbol appears. When the SSL or TLS encryptions are enabled, your data can not be accessed by a third party.

9. Transmission of telematic data and personal data from/ to a Third-Party

With your respective consent and for the implementation of our services we can access and process your telematic data from such third-party websites and platforms as Volvo Connect, RIO, or MAN. We do not have access to, or control over the cookie and privacy policies applied to these third party platforms.

In accordance with the legal regulations of the GDPR Tracks GmbH does not transfer your personal or telematic data to any third party.

10. Your Rights

Allowing Tracks GmbH access your personal or telematic data you have the following rights according to the GDPR:

Right to Information:
You have the right to be provided with the information about the processing of your data.

Right to Rectification:
You have the right to demand from us rectification, completion of incomplete or correction of incorrect personal data.

Right to Complain:
In case of unlawful use of your personal information you can enforce your right to appeal to a regulatory authority on this matter (for example to the European Data Protection Supervisor).

Right to Data Portability:
Insofar as the processing of your personal data takes place on the basis of consent and/or a contract and by means of an automated procedure pursuant to Art. 6 paragraph 1 (b) of the GDPR, you have the right to receive your personal data in a structured, common and machine-readable format, and to transmit it or to have it transmitted from us to another provider.

Right to Restriction of Processing:
Under the conditions of Art. 18 of the GDPR, during the period of verification of the accuracy of your personal data, as a data subject, you have the right to restrict the amount of your personal information subject to verification.

Right to Erasure:
Under the conditions of Art. 17 of the GDPR, you may request the deletion of your personal data and revoke your consent for their processing.

Right to Withdrawal of Consent:
You have the right to revoke your consent to the processing of your data at any time and free of charge. To revoke your consent an informal e-mail with a corresponding request to us is sufficient.

Right to Object:
Under the conditions of Articles 21 and 6 (paragraph 1 e, f) of the GDPR you have the right to object the processing of your personal data at any time, for reasons that arise from your particular situation. In this case, the responsible party will no longer process your personal data, unless it can prove the legitimate reason for processing, which overrides your interests, rights and freedoms, or which is necessary due to establishment, defense or legal claims.

11. Privacy Policy for Applicants

Job applications can be sent to us via e-mail to career(at) or by post. Please note that sending you application by e-mail involves risks with regard to data security. Below you will find information on how we process your personal data in connection with your application

Responsible for processing data:
Responsible for the processing of your data is c/o Tracks GmbH, The Drivery, Mariendorfer Damm 1, 12099 Berlin, Represented by CEO Jakob Muus

The data we process and the purpose:
We process your personal data you send us in connection with your application to check your qualifications for the specific position (or other open positions in our company, if applicable) and perform the application process.

Legal Basis:
The legal basis for processing your personal data in connection with the application process is section 26 Federal Data Protection Act in the version valid from 25.05.2018. According to this, the processing of your personal data is permitted if it is necessary in connection with the decision on the establishment of an employment relationship. After conclusion of the application procedure, data processing on the basis of Art. 6 GDPR may be necessary. In particular, data processing may be performed in accordance with Art. 6 para. 1 lit. f) GDPR in order to protect our legitimate interest. The legitimate interest includes e.g. in the assertion or defence of legal claims.

Storage Duration:
In case of a rejection, we will keep your application documents for six months and after this period your application documents will be completely destroyed in accordance with data protection regulations. With your consent to a further storage and use of your application, we can affiliate you into our pool of applicants. In this case we destroy your data after max. 1 ½ years. In case of a commitment for the position, we will transfer your application documents into the personnel system.

Transfer of your data:
Your personal data will only be transfered to persons who need them for a proper application procedure. The recipient of your personal data are basically the internal department, the personnel department and, if applicable, the management. The transfer of your data to third parties does not occur. Your data is protected from unauthorized access or data loss by suitable technical and organizational measures.

Your Right:
As a person concerned within the meaning of the GDPR, you are entitled to rights. You can receive information from us about the processed personal data within the scope of the right to information. Furthermore, you have the right to have your personal data corrected, deleted or restricted, provided that the requirements of Art. 18 GDPR are fulfilled. You have a right to object to the processing, a right to data transfer and to complain to the responsible supervisory authority.

In case you have further questions, you are welcome to contact Rene Meyer (internal contact person on the subject of data protection