Privacy Policy
In this Privacy Policy (“Policy”) the 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 General Data Protection Regulation (“GDPR”).
1. Controller
The controller responsible for this data processing is the IGEL Technology GmbH, Hermann-Ritter-Str. 110, 28197 Bremen, Germany. You can find further information .
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 to protect 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 them on our web server for statistical purposes in order to improve the quality of our website. This data includes:
- the page, from which the data is requested,
- the name of the data file,
- the date and time of the query,
- the amount of data transferred,
- the access status (file transmitted, file not found),
- 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 listed usage data is stored anonymously.
The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest to use this information to enable our website to be called, to control and administer our systems, and to improve the design of our website. This data is not passed on to any third party.
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 organization data, this includes your professional phone number and e-mail address, company affiliation, job title and professional or company address.
The legal basis for processing depends on whether your use of the form is during a contractual relationship with IGEL or is leading up to such a relationship, in which case the legal basis is Art. 6 (1) (b) GDPR. In any other case the legal basis for processing will be Art. 6 (1) (f) GDPR. We have a legitimate interest to process and respond to your request, just as you have an interest that your request will be responded to. 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.
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, those transfers are secured by the EU standard contractual clauses (SCC) with Act-On and its certification under the EU-US Data Privacy Framework (DPF).
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-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 the EU standard contractual clauses (SCC) with Microsoft and its certification under the EU-US Data Privacy Framework (DPF).
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,
- 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 legitimate basis for this processing is Art. 6 para. 1 lit. a GDPR, meaning your consent. You can withdraw your consent at any time by contacting us (legal@igel.com) or Text Inc.
The Live-Chat functionality is provided by our supplier Text, Inc. (with its principal office at 101 Arch Street, 8th Floor, Boston, MA 02110, USA). Text, Inc. is a US Company. If, in the course of processing, your data is transferred to Text in the USA, those transfers are secured by Text’s certification under the EU-US Data Privacy Framework (DPF).
2.1.5. Newsletter
We provide the opportunity to subscribe to our newsletter in a number of ways. This is first separately 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.
For the newsletter subscription we collect:
- Your email address,
- Your consent to receiving our newsletter in conjunction with your IP-address and the time of your consent.
The legal basis for this processing is Art. 6 (1) (a) GDPR. You can withdraw your consent at any time, following which we will stop the corresponding processing. This does not impact the lawfulness of prior processing. You may also unsubscribe from the newsletter at any time, via the link to unsubscribe from the newsletter, which you will find in every newsletter email.
For the purpose of managing and sending out the newsletter, your data will be processed by Act-On Software, Inc. (please see 2.1.3 for more details).
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 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 on the basis of Art. 6 (1) (a) GDPR, your consent. Google analytics is only enabled when you agree to 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 the EU standard contractual clauses (SCC) with Google and its certification under the EU-US Data Privacy Framework (DPF).
2.1.6.3. Embedded YouTube Videos
We have also decided to only embed YouTube Videos using the NoCookie function on our site. As a result, the only information generally transferred to YouTube and its affiliates will be your consent or non-consent to marketing cookies. If you consent to marketing cookies, additional cookies may be used.
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 the registration,
- You may include personal information, such as your real name, in your username.
- Company 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 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 serve the 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 to protect 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 Art. 6(1) (a) GDPR, i.e. your consent. You can delete your messages and any personal information contained in them at any time.
We utilize the timestamps of the messages as an indicator for the engagement of the IGEL Community. The legal basis for this processing is Art. 6 (1) (f) GDPR. We have a legitimate interest to evaluate 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. If data is transferred to Pynthonanywhere in the UK, the data transfer is protected by the EU-UK Adequacy Decision issued by the EU Commission.
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:
- Your name,
- Your email address,
- Your username,
- As they are provided in your Slack account.
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 to evaluate 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 our DPA and the EU Standard Contractual Clauses with Subcurrent as well as its certification under the EU-US Data Privacy Framework.
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.
- You may comment as a guest user.
- 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 chose to register an account with HYVOR (2.), the following personal data will be processed:
- Your IP address,
- Your name,
- Your user name,
- Your Hyvor Talk activity on our website.
The 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 (legal@igel.com) 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 License Portal (activation.igel.com) for the activation of purchased IGEL product licenses by the customer. When you register for the License 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 company 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) (b) GDPR, as the processing is necessary to perform our End User License Agreement (EULA) with you (or the company on whose behalf you are activating the licenses).
In addition, the License Portal protocols the following actions you as user perform:
- 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 the customer). The processing 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, the legal basis is legitimate interest in accordance with Art. 6 (1) (f) GDPR. The customer has a legitimate interest in being able to track the allocation of assets (which also includes activated IGEL licenses) in an auditable manner.
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 company you are registering for,
- 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 responding to your support ticket and for the performance of support services by IGEL. The processing is based on Art. 6 (1) (b) GDPR, as the processing is necessary to perform our maintenance and support agreement with you.
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 secured by the EU standard contractual clauses (SCC) with ServiceNow and its certification under the EU-US Data Privacy Framework (DPF).
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 for users. The processing is based on Art. 6 (1) (b) GDPR, as the processing is necessary to perform our contractual obligations from our EULA and Cloud Services Terms of Use with you.
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 secured by the EU standard contractual clauses (SCC) with AWS and its certification under the EU-US Data Privacy Framework (DPF).
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,
- recommendation 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.
Legal basis for the data processing is IGEL’s legitimate interest in accordance with Art. 6 (1) (f) General Data Protection Regulation (GDPR). It is IGEL’s legitimate interest to pursue the above detailed purposes to improve its products and services, and to provide its customers with more secure, up-to-date, and optimized software as well as optimal customer support.
Data collected by the Insight Service:
- Company 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 (Insight Service Data Collector),
- Client version (Insight Service Data Collector)
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 IGEL device will only be stored pseudonymously. The data will be deleted after five years.
You can object to the processing by disabling the Insight Service functionality in your UMS settings. By objecting you will not receive further recommendation based on your setup and you can not be provided with access to software and hardware insights based on your data.
2.8. Online Application
When you apply for a job at IGEL, we process your personal data 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 pages based on Art. 6 (1)(f) GDPR 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.
It is in IGEL’s legitimate interest to present IGEL to partners and customers as a modern market participant with corresponding social media presences and thus to receive business-generating publicity.
The data you enter on our Facebook page, such as comments, videos or images, will not be used or processed by us at any time for any other purpose.
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 the 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 you, whether you are 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 company (including the company address),
- Your role in your company,
- Potentially any information you chose to include in the communication.
The purpose of data processing is the initiation and execution of the respective customer, partner or supplier contract. If a specific contractual relationship has already been indicated, the legal basis is Art. 6 (1) (b) GDPR. If no contractual relationship has yet been indicated and you have given us your consent to process your personal data for communication with you, the legal basis is Art. 6 (1) (a) GDPR. You can withdraw this consent at any time (e.g. by sending an email to legal@igel.com).
IGEL uses IT systems and applications of service providers for the performance of business communications and may transfer data to these service providers in the process, according to applicable laws.
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 obligated to do so based on statutory requirements or an administrative or judicial order or based another applicable legal basis.
Third parties which may receive your data are:
- Governmental authorities in the scope of their duties.
- Courts 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 ff. GDPR, for example the EU Commissions Standard Contractual Clauses (SCCs) or the EU-US Data Privacy Framework (DPF). 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.
4. Storage and deletion of data
Generally, we store your data only as long as necessary to achieve the intended purpose. After the intended purpose has been achieved, we will delete your personal data.
However, we might be required to store your data longer to comply with statutory obligations or if required by administrative or judicial order or to exercise or defend ourselves against legal claims. Additional information 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 or not 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 without undue delay the rectification of inaccurate personal data concerning you and, if necessary, the right to have incomplete personal data completed.
You also have the right to request an erasure of the personal data concerning you 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 those copies of your data as well. Please note that the right for 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 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 the 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 personal data, unless there are demonstrably compelling legitimate grounds for processing, which override the interests, rights and freedoms of the person concerned, or 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 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 and its address is:
The state representative for data protection and information freedom of the free and hanseatic city 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 per any applicable laws, please contact us at legal@igel.com 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
office@datenschutz-nord.de, +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 Filial, Sweden; IGEL Technology SRL, Romania; IGEL Technology Ltd., Great Britain):
FIRST PRIVACY GmbH,
Konsul-Smidt-Straße 88, 28217 Bremen, Germany
office@first-privacy.com, +49 421 69 66 32 80
- North America and South America (IGEL Technology Corporation):
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/.
