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Privacy Policy

§1 Information about the collection of personal data 


1.1 In the following, the owner and operator, Lemin GmbH (here “Lemin”, “we”, “us”, “our”) of the website (“Website“) provides you with information about our collection and use of your personal data, that is collected when using our website and our software (Lemin, „Software“) with the purpose of  analyzing of individual and collective working culture. Personal data is any data that is personally identifiable to you, e.g. name, address, e-mail addresses and user behavior.  


1.2 According to Art. 13 General Data Protection Regulation of the EU, (“GDPR”), we inform you about the legal basis of our data processing procedure. If the respective legal basis is not explicitly stated in this policy, the following applies: The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR, the legal basis for the processing of data in order to fulfill our services and carry out contractual measures and respond to inquiries is Art. 6 (1) (b) GDPR, the legal basis for the processing of data to fulfill our legal obligations is Art. 6 (1) (c) GDPR and the legal basis for the processing of data to protect our legitimate interests is Art. 6 (1) (f) GDPR. In the event that vital interests of the concerned subject or another natural person make processing data necessary, we will act according to Art. 6 (1) (d) GDPR. 



1.3 The responsible party for this Website is Lemin GmbH, Im Mediapark 5, 50670 Cologne,, +49172892542 (as stated in our imprint). Please send any inquiries to our data protection officer to or via our postal address with the subject line “Matter of privacy policy”. 


1.4 When contacting us via e-mail or contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be collected by us, in order to answer your questions. The data collected in this context will either be deleted after the storage is no longer necessary or processing will be restricted, if we are legally obligated to retain them.  


1.5 If we use contracted service providers for individual functions of our services or we would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. In doing so, we will also state the specified criteria for storage periods.   


§2 Your rights  


2.1 If you: 


  • want to view, confirm, correct, rectify, update, extend, anonymize, block, restrict or delete your personal data; 

  • want to object to our use of your personal data or want to restrict our usage; 

  • have questions regarding your personal data; 

  • want us to pass on your data to another person or company,  


please contact us through our, in §1 provided, contact details.  


2.2 Regarding your personal data we will grant you all the rights to which you are entitled to under applicable law. If you have any complaints about the handling of your personal data, you can contact a data protection supervisory authority (Art 13. (2) (d) GDPR. Alternatively, you can contact us through our, in §1 provided, contact details.  


§3 Objection or revocation of consent 

  • If you have given consent to the processing of your personal data, you may revoke that consent at any time by informing us accordingly using the contact details provided in §1. A revocation will cover the processing of your personal data starting at the time of revocation.  

  • You may object to the processing of your personal data, insofar as we base the processing of your personal data on a comparison of interests (Art. 6 para.1 p.1 (f) GDPR). This is the case if the processing of your personal data is not particularly necessary for the fulfillment of a contract with you, as shown in the following description of the functionalities. In that case, when exercising an objection, we will require an explanation of you, as to why we should not process your personal data as we did. In the event of an objection, we will review the matter and either discontinue, adjust the data processing procedure or demonstrate our compelling and legitimate reasons on the basis of which we will continue the processing of your data to you.  


§4 Collection, Processing and Utilization of your personal data 


4.1 In the event of a mere informational use of our website, i.e. if you do not register or otherwise transmit information to us, we will only collect the personal data that your browser transmits to us. In this case we collect the following data, which is technologically necessary for us to display our website to you and to ensure stability and security (Art 6 para. 1 p. 1 (f) GDPR, whereby our legitimate interest lies in the technological opportunity of website operation):  

  • IP-address; 

  • Date and time of request; 

  • Time zone difference to Greenwich Mean Time (GMT); 

  • Content of request (specific page); 

  • Access status/ HTTP status code; 

  • Volume of transferred data; 

  • Website from which the request originates; 

  • Browser; 

  • Operating system and its interface; 

  • Language and Version of browser-software. 

This data will be saved for a limited time period of 7 days. 


4.2 Lemin is a software that aims to identify fields of action for a further development of teams and to promote behavioral change within the workforce. Lemin focusses on communication, collaboration and leadership behavior of employees.  


Participating in Lemin’s service is on a completely voluntary basis. At the beginning of usage, your employer shares certain information with Lemin, such as the users’ names, e-mail addresses and position details from their internal HR database. When using our software, Lemin collects the data you provide as part of the personality and team analysis, including personal strengths, personality traits and a work situation survey. The provided data will then be combined to create your individual cultural profile and, if applicable, your team and your employer.  

The data will be transferred, usually in a compressed form, to your employer. All processing operations are carried out on the basis of your consent provided when using the software (Art. 6 para. 1 p. 1 (a) GDPR). If you choose to participate in Lemin’s service, Lemin will process your data and survey responses for the following purposes: 

  • Generating of reports and analyses on, among other things, fields of action and corporate culture, based on aggregated responses; 

  • Communicating feedback, assigning nudges and content to users; 

  • Monitoring of interactions with Lemin’s software; 

  • Creating dashboard tools for managers and recruiters to access the collected data, which is based on aggregated responses; 

  • Evaluation of behavioral change through Lemin’s service. 


You may revoke your consent at a later point in time. Your employer will not be able to associate a particular response on Lemin’s surveys and analyses with the employee who submitted it, unless you are specifically told otherwise prior to submitting your response.  


4.3 In detail, we will store your data as follows: 

For users of the software: We will retain your data for a limited time period of 5 years or up to 6 months after the end of our collaboration (whichever comes first). After this period, your data will be anonymized and deleted; 

For marketing contacts: We will retain your data for as long as necessary to provide you with news or e-mails for promotional purposes or to maintain other communication (in the following referred to as “purpose”), as long as you have given consent to (where necessary) and not objected to the particular purpose and as long as we have a continuous legitimate interest in the particular purpose.  


a) A legitimate interest exists in the context of the operation of the website, in particular: 

  • for answering questions; 

  • for the realization of direct marketing measures; 

  • for the provision of services and/or information intended for you; 

  • for the operation and management of our website; 

  • for the technical support for users; 

  • for preventing and detecting fraud and crime; and/or 

  • for ensuring network and data security, to the extent that these interests are consistent with the applicable law and with the rights and freedom of the user 


b) if you have given consent to the utilization for the specifically stated and lawful purpose; or 

c) we are obligated to do so for legal reasons.  


4.4 If you choose not to provide the personal data we request, we may not be able to provide the information and/or services you request or perform certain tasks for which the personal data is needed. However, your visit to the website will otherwise remain unaffected.  


§5 Deletion of retained data 


Your retained personal data (including the data collected in accordance with §4.2 and §4.3) will be deleted, provided that the deletion does not conflict with any statutory retention obligations or the personal data is no longer required for its intended purpose according to Art. 17 GDPR, in particular after revocation of any consent (as shown in §3 of this declaration). If there is a legally permissible purpose fpr the continued retention of personal data, its processing will be restricted according to Art. 18 GDPR by blocking this data and no longer processing it. This particularly applies to data that must be retained for legal reasons.  


§6 Use of Google Analytics 


6.1 This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users interact with the site. According to Google, the information generated by the cookie about your interaction with this website is usually transmitted to a Google server in the U.S. and retained there. However, in the event that IP anonymization is activated on this website, your Ip address will be abbreviated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in rare cases will the full IP address be transmitted to a Google server in the U.S and is abbreviated there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your interaction with the website, compiling reports on website activity and providing other services related to website activity and internet usage to the website operator.  


6.2 According to Google, the IP address transmitted by your browser as part of the Google Analytics service is not combined with other Google data.  


6.3 You may prevent the use of cookies by selecting appropriate settings on your browser, but please note that if you do, you may not be able to use the full range of functions of this website. You can also prevent the collection of data generated by the cookie and related to your interaction with the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: Browser-Plug-in 


6.4 This website uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are processed in an abbreviated form, which means that personal references can be ruled out. As long as the collected data about you has a personal reference, this is immediately excluded, and personal data is deleted right away. 


6.5 We use Google Analytics to analyze and regularly improve the interaction with our website. The statistics obtained allow us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the U.S., Google has signed up to the EU-US Privacy Shield. The legal basis for the use of Google Analytics is Art. 6 para. 1 p.1 (f) GDPR, whereby our legitimate interest is the provision of an interactive und user-friendly web service and its ongoing optimization.  


6.6 You can request information from the third-party provider by postal mail: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland. Here you can find the user conditions, the data protection overview, as well as the privacy policy.  


§7 Subcontractors 


7.1 Appointed subcontractors for ensuring the functionality of the Lemin software   


MongoDB Inc., 1633 Broadway, 38th Floor New York, NY 10019 

  • Data center in Frankfurt 

Google Cloud Platform, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 Ltd., PO box 40190 San Francisco, CA United States 


a) Other subcontractors commissioned for their offered functionalities used by Lemin 


Google LLC, 1600 Amphiteatre Parkway, Mountain View, CA 94043, USA  

Hubspot, Inc., 25 First Street, Cambridge, MA 02141 USA 

Twilio Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105 USA 

  • Sendgrid (Email-Automation) 

Vimeo, Inc., 555 West 18th Street, New York, New York 10011USA 

Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA, Functional Software Inc., 132 Hawthorne Street, San Francisco, CA 94107 USA



§8 Data security 


Our website is hosted on servers operating within the European Economic Area (“EEA”). We take reasonable precautions to protect your personal data from unauthorized access. Data is stored in a sealed, certified data center on secure computers. The data is encrypted in the best way possible and stored. We regularly review our security policies and procedures to ensure the security of our systems. However, when transmitting data over the internet, we cannot give a one-hundred-percent guarantee of the security of the data transmitted to our website.  


§9 Confidentiality 


The data you provide us with will be treated confidentially by us. As a matter of principle, personal data will not be sold, distributed or made available to third parties in return for payment in any other way, but will be passed on to third parties exclusively for the purposes stated in this privacy policy. The confidentiality and security of your data will be maintained in accordance with our privacy policy and applicable law and regulations.  


§10 Subject to change  


10.1 We always keep this privacy policy up to date. Therefore, we reserve the right to adapt this privacy policy in the event of legal and/or technological requirements, for reasons of clarifying explanations or changes to the software or our service, as well as data processing. However, the changes only apply with regard to data processing explanations. If parts of the privacy policy contain provisions of the contractual relationship with the users or require the consent of the users, the respective change will only be made with the prior consent of the users.  


10.2 We therefore ask you to pay attention to the respective current version of this privacy policy and to regularly inform yourself about the contents of the privacy policy.  


10.3 You can make a printout of the privacy policy or save it at any time.  

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