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Data protection

Privacy policy of Kombiverkehr Deutsche Gesellschaft für kombinierten Güterverkehr mbH & Co. KG

Last updated: 1 March 2023


At Kombiverkehr GmbH & Co. KG, the protection of your privacy in the context of the processing of personal data is an important concern that is taken into account in business processes. The purpose of this privacy policy is to give you an overview of the cases in which Kombiverkehr collects and processes personal data about you, the cases in which data is passed on to third parties for a specific purpose and how your personal data is used and protected.

1. What is personal or anonymized data?

Personal data are any information that can be used to discover your identity. They include information such as your name, address, postal address, IP address, telephone number and email address. Information that is not directly associated with your real identity (such as, for example, your favourite websites or the number of users of a site) is not considered personal data.

Every time our internet content is accessed, general information is stored automatically (such as the number of users and how long they spend on each page, etc.). These data are not personal, so they are processed in anonymous form. Information of this type is for statistical purposes only and will be used in order to optimise our internet content.

2. Controller for data collection and processing

All the personal data you provide within a commercial transaction with Kombiverkehr or its initiation, as well as via the Kombiverkehr websites www.kombiverkehr.de, www.kombiverkehr.com, mein.kombiverkehr.de, karriere.kombiverkehr.de or medien.kombiverkehr.de, will be collected, processed or stored by or for Kombiverkehr Deutsche Gesellschaft für kombinierten Güterverkehr mbH & Co. KG, Zum Laurenburger Hof 76, 60594 Frankfurt am Main, registered in the Commercial Register of Frankfurt am Main under A 20 477 and represented by the managing directors Heiko Krebs and Armin Riedl. Kombiverkehr GmbH & Co. KG is thus the “controller” within the meaning of the German Federal Data Protection Act (BDSG) and hence legally responsible for the protection of your data.

3. Collection, processing and use of personal data

3.1 for certain purposes
Kombiverkehr GmbH & Co. KG collects, processes, stores and uses personal data when you disclose such data, for example as part of the registration process, when making general contact or in order to perform a commercial transaction. The personal data that you provide will only be processed for correspondence with you and only for the purpose for which you have made the data available to us. This includes, among other things, correspondence in connection with the initiation of a commercial transaction, order processing for a shipment and the execution of payment transactions. In individual processing steps within the scope of commissioned data processing, your data will only be passed on to companies and service providers who support us in the provision of services. Beyond that, the information will of course not be passed on unless legal regulations permit or require us to do so. Insofar as we make use of service providers to carry out and handle data processing within the scope of commissioned data processing, the contractual relationships are regulated in accordance with the provisions of the German Federal Data Protection Act (BDSG).

We commission other companies and individuals to perform tasks for us.

Examples include the craning of loading units at terminals, the traction of freight trains, the provision of agency services, the handling of payments (Kombiverkehr deferral scheme), the sending of letters or emails and also advertising activities. These service providers have access to personal data that they need in order to perform their tasks. However, under a commissioned data processing contract the companies involved must not use personal data for other purposes. In addition, they are obligated to handle the information in accordance with this data privacy policy and the applicable legal and contractual data protection regulations.

3.2 On the Internet
It is generally possible to visit our website without registering. However, while certain personal data are collected automatically, we require you to provide other personal data to enable us to fulfil and implement the specific services, service offers and features that we offer.

3.2.1 Usage data
Our web servers automatically store the following usage data when you visit our website: 

  • The type and version of the browser you are using
  • The operating system you are using
  • The website from which you accessed our website
  • The date and time the page was viewed
  • Your IP address

These data are stored on the web servers of Next Tuesday GmbH, Neue Rothofstraße 13-19, 60313 Frankfurt am Main.

These data will not be merged with data from other sources and will be erased automatically after 14 days. We will not use your IP address to identify you. However, the usage data help us gain information about how our website and the offers on our website are used and gives us the opportunity to improve our offer and eliminate errors.

3.2.2 Personal data
When you register for specific services, service offers and features, we ask you to provide some personal data, such as your name, your postal address and your contact details. In some cases, you can choose whether or not to disclose these personal data.

We will, however, require user data insofar as these are mandatory (e.g. email address, name) so that we can provide the services, service offers and features you request. The data will be stored in the IT systems of Kombiverkehr GmbH & Co. KG as well as on web servers of Next Tuesday GmbH, Neue Rothofstraße 13-19, 60313 Frankfurt am Main, Krankikom GmbH, Calaisplatz 5, 47051 Duisburg, CURSOR Software AG, Friedrich-List-Straße 31, 35398 Gießen, and eRecruiter GmbH, Am Winterhafen 4, 4020 Linz, Austria. The duration of the storage is directly related to the services, service offers and features requested by the user (see also section 3.2.2 a to f).

We will not otherwise pass your data on to third parties

We collect, process and use personal data within the scope of our internet presence for the following purposes:

a. Making contact by email
If you contact us using online forms such as the contact form, the enquiry form or the form for making an appointment on our website, the information you provide in the contact form will be sent to Kombiverkehr KG by email so that your enquiry can be dealt with and any subsequent questions answered. Once the purpose has been fulfilled, we will erase your personal data. If you have given us consent to use your personal data for further purposes, such as direct marketing, we will store your data for such purposes.

The supplementary data privacy policy for myKOMBIVERKEHR can be found at the end of this document.

c. Newsletter
If you subscribe to our newsletter, we will use the email address you provided when registering. We will use your stored email address solely in order to send the newsletter, unless you have consented to use of the data for other purposes. You can unsubscribe from the newsletter at any time by clicking on the corresponding link displayed in each newsletter. You can also request to be unsubscribed in writing by post or email. In these cases, please use only the following contact options: Kombiverkehr Deutsche Gesellschaft für kombinierten Güterverkehr mbH & Co. KG, data protection (erasure), Zum Laurenburger Hof 76, 60594 Frankfurt am Main, email loeschen-datenschutz@kombiverkehr.de

d. Application procedure

If you would like to apply for a position with Kombiverkehr, once you have given your consent we will collect, process and use your personal data solely for the purposes of the application process. We process data that relate to your application. These may include general information about you (such as your name, address and contact details), information about your professional qualifications and schooling, information about your professional training or other information that you provide to us in connection with your application. We may also process job-related information which you have made publicly available, such as a profile on professional social media networks.

Your personal data will be stored both at Kombiverkehr GmbH & Co. KG and at eRecruiter GmbH, Am Winterhafen 4, 4020 Linz, Austria, with which we have a commissioned data processing contract. The data transferred will only be stored until the application process is completed, but for no longer than six months after the end of the application process.

After this date, all data will be erased permanently. We will also use your personal data to ensure a smooth application process in personal contact with you. Depending on your qualifications and suitability, and subject to your consent, we will also be happy to submit job offers for which you have not explicitly applied during the current application process.

e. Participant management with Meetingmasters
Kombiverkehr uses a web tool provided by IT service provider Meetingmasters, Rudi-Schillings-Strasse 17, 54296 Trier, with which we have a commissioned data processing contract, to organize trade fairs and events. Personal data from commercial transactions pursuant to section 7 of the German Unfair Competition Act (UWG) and/or personal data for which consent for direct advertising is granted will be used and processed for the purpose of invitation management. The data will be stored on the web servers of Meetingmasters only for the purpose of participant management for a specific event and will be erased after follow-up of the event.

f. Downloading of photos and videos for cultural, journalistic and educational purposes

We make selected image materials, photographs and videos (known as media data) available for download free of charge to a defined group of authorised persons for cultural, journalistic and educational purposes in accordance with our Terms of Use.

In order to ensure that you are entitled to download media data free of charge and use them in accordance with our Terms of Use, we will ask you for the following personal details before you download our media data in print quality: 
  • First name and surname
  • Authorised group to which you belong
  • Intended use  
  • Email address

We require these personal data and details from you so that we can verify whether you are authorised to conclude a contract for the free use of the media data. We also require these data from you so that we can document and administer the user contract and check compliance with the Terms of Use.

4. Use of “cookies”

To offer comprehensive functions and to make it easier to use our website, we use what are known as “cookies” on our website. Cookies are small files that are stored on your computer with the help of your internet browser. Cookies enable us to analyse your use of our website and to recognise you when you return to our website.

While the use of cookies is standard practice, you can object to their storage on your computer in your internet browser's settings for cookies, and you can prevent or restrict their storage. However, you may then be limited in your use of our website.

5. Use of Google Analytics

Data are collected and stored on this website by Google Analytics, a web analysis service provided by Google Inc. ("Google"), and used to create user profiles by means of pseudonyms. The purpose of these user profiles is to analyse visitor behaviour so that our offering can be improved and attuned to requirements.

Google Analytics uses cookies, which we have described in section 4 above.

The information generated by the cookies about your use of our website will generally be transmitted to Google servers in the USA and stored there. In accordance with statutory data protection provisions, however, your IP address will be abbreviated beforehand by Google within Member States of the European Union and in other signatory states to the Treaty on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there. Google will use this information on behalf of the operator of this website in order to evaluate your use of the website, compile reports on website activity and provide other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser in connection with Google Analytics will not be associated with any other data held by Google. The pseudonymised user profiles will not be associated with personal data relating to the holder of the pseudonym without the express consent, to be issued separately, of the data subject.

You may prevent the installation of cookies by using an appropriate setting in your browser software (see section 4 above). However, please note that if you do this, you may not be able to use the full functionality of this website.

You can also disable Google Analytics on your monitor and your computer, i.e. you can prevent Google from recording the data generated by the cookie in relation to your use of the website (inc. your IP address) and from processing these data by downloading and installing the Google browser add-on available under the following link:


The web analysis function will remain disabled until this Google browser add-on is disabled or deleted. The browser add-on is needed on both the browser and the computer. If you do not wish to have a web analysis function, therefore, you must add the browser add-on to all the browsers and computers in use.

Browser and operating system updates may affect the installation and functionality of the browser add-ons.

Google Analytics has been extended by the code "gat._anonymizeIp();" on this website in order to ensure that IP addresses are always anonymised to prevent direct reference to individuals (IP masking). For details of the purpose and scope of data processing, collection and use on the part of Google Analytics, please refer to Google's privacy policy.

If you have consented to the use of cookies (see section 4 above) or have not installed the Google browser add-on, you declare that you agree to allow us to use Google Analytics to analyse the use of our website in the manner described and to process the data collected about you.

6. Use of Cloudflare

We use the Content Delivery Network (CDN) of Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich, Germany (Cloudflare), in order to enhance the security and speed of delivery of our website. This corresponds to our legitimate interest (point (f) of Art. 6(1) GDPR). A CDN is a network of servers [across the world] that is able to deliver optimised content to website users. Cloudflare may process personal data in server log files for this purpose. Please compare the information provided under “Hosting”.

Cloudflare acts for us as the recipient of your personal data and a commissioned data processor. This corresponds to our legitimate interest within the meaning of point (f) of Art. 6(1) GDPR not to operate a Content Delivery Network ourselves.

You have the right to object to processing. Whether the objection is successful will depend on a balancing of interests.

There is no statutory or contractual requirement for the data indicated in this section to be processed. Without the processing, no guarantee can be given about the functionality of the website.

Cloudflare will store your personal data for as long as they are required for the purposes described.

Further information about your rights to object and right of removal vis-à-vis Cloudflare can be found at: Cloudflare DPA

Cloudflare has implemented compliance measures for international data transmission. These apply for all worldwide activities in which Cloudflare processes personal data of natural persons in the EU. The measures are based on the EU Standard Contractual Clauses (SCCs). Further information can be found at: https://www.cloudflare.com/cloudflare_customer_SCCs.pdf

7. Hyperlinks to third-party websites

Our website has what are known as hyperlinks to websites operated by other providers. If you click on these, you will be redirected from our website directly to the websites of the other providers. You will recognise this, for example, by the change of URL. We cannot assume any responsibility for the confidential handling of your data, as we have no influence on whether these companies comply with data protection regulations. Please check the websites of these companies directly for information on how they handle your personal data.

8. Product information / invitations / market and opinion polls (direct advertising)

If you give your consent, we also use your personal data to contact you by email, telephone, SMS or post for the following purposes:

  • To send offers and information on the range of products and services
  • To send invitations to events and functions
  • To conduct market and opinion surveys in order to optimise our services, service offerings and features

You can give us your consent on online forms for the above use of your name, your email address, telephone number and postal address for sending information and product recommendations by means of an active declaration of intent for each specific purpose.

We will keep a record of your consent(s). Once given, you can withdraw consent at any time with effect for the future. You will not incur any costs other than postage or transmission costs based on existing basic tariffs. To do so, please use only the following contact options: Kombiverkehr Deutsche Gesellschaft für kombinierten Güterverkehr mbH & Co. KG, data privacy (withdrawal), Zum Laurenburger Hof 76, 60594 Frankfurt am Main, email widerruf-datenschutz@kombiverkehr.de

9. Security measures for protecting the data we store

Insofar as we collect personal data, we and/or our service provider(s) with whom we have a commissioned data processing contract will store such data on specially protected servers in Germany or in the European Union. Access to such data is limited to a few authorised persons with special technical, commercial or editorial responsibility for them. In order to prevent the loss or misuse of data, we have put in place comprehensive technical and operational safety precautions which are monitored on a regular basis and duly modified in line with advances in technology. Owing to the structure of the internet, however, we should also point out the possibility that other persons outside our area of responsibility and institutions may fail to observe data protection regulations and the aforementioned safety measures. In particular, third parties may also read data that are divulged without being encrypted, even if they are sent by email. We have no technical control over this. It is your responsibility to protect the data with which you provide us against misuse by means of encryption or in some other way.

10. Passing data on to third parties

We are legally obliged to pass on your personal data to third parties in certain cases. This is the case if, for example, there is a suspicion of criminal activity or a misuse of our website. We will then be obliged to pass on your data to the law enforcement authorities. Insofar as Kombiverkehr uses third-party companies for data processing in order to fulfil its obligations to you (commissioned data processing), such companies will be obliged to handle your data carefully, with due regard for the requirements of data protection laws and in accordance with our instructions, and not to use them for their own purposes or forward them to third parties.

11. Protection of data (organizational and technical measures)

We have taken various organisational and technical measures to protect your data from unauthorised disclosure, unlawful use, modification and destruction. To this end we maintain physical, electronic and procedural security measures. Our servers are protected by firewalls and virus protection, for instance. Backup and recovery concepts as well as role and authorisation concepts are a matter of course for us. To increase the security of your data, we often use encryption methods (such as SSL for transferring data via the internet). Our employees are bound to data secrecy and must observe the regulations of the German Federal Data Protection Act (BDSG) and the German Telemedia Act (TMG) when handling data.

All the companies that receive data from us, whether they process data under our control or we pass data on to them, must also undertake to observe data secrecy and to comply with certain organisational and technical data protection requirements. This is checked by Kombiverkehr KG on commencement of the contract and thereafter on a regular basis in order to ensure that such companies also fulfil their obligations in their ordinary activities and that the protection of your data is always guaranteed.

12. Right of access, withdrawal of consent, blocking and erasure

You can obtain information free of charge at any time regarding the personal data we hold about you, including their origin, recipient and purpose of data processing. You can have the personal data we hold about you blocked, rectified or erased, and you can refuse to consent to the anonymised or pseudonymised collection and storage of data for the purpose of optimising our website. You can also at any time withdraw the consent you have given us to collect and use data without stating your reasons.

If you would like to make use of your right of access, withdrawal of consent, blocking and erasure, please contact Kombiverkehr using only the following channels of communication:

Kombiverkehr Deutsche Gesellschaft für kombinierten Güterverkehr mbH & Co. KG, data protection (access) or (withdrawal of consent) or (blocking) or (erasure), Zum Laurenburger Hof 76, 60594 Frankfurt am Main. For communication by email, please use the following contact details, depending on the matter:


email auskunft-datenschutz@kombiverkehr.de or

email widerruf-datenschutz@kombiverkehr.de or

email sperrung-datenschutz@kombiverkehr.de or

email loeschen-datenschutz@kombiverkehr.de

13. Right to lodge a complaint with a supervisory authority

If you as the data subject believe that the processing of your personal data by Kombiverkehr GmbH & Co. KG violates the provisions of the German Federal Data Protection Act (BDSG), you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, your workplace or the place of presumed infringement, without prejudice to any other administrative or judicial remedy.

14. Changes to the Kombiverkehr privacy policy

The legal frameworks in which we act as service providers are subject to changes and amendments. From time to time, these changes and amendments require the data privacy policy to be updated. Kombiverkehr therefore reserves the right to amend this data privacy policy at any time.

Frankfurt am Main, March 2023

If you have any questions about our privacy policy, please contact us:

Kombiverkehr GmbH & Co. KG
Christian Franz, Head of Finance & Administration
+49 69/7 95 05-112

Data Protection Officer, Kombiverkehr GmbH & Co. KG
Ulrich Emmert, ESB Rechtsanwälte
Stuttgart Office
+49 711 / 469058-0

Supplementary data privacy statement for mein.kombiverkehr.de

1. To use the “myKOMBIVERKEHR” portal, during the registration process the user must consent both to the processing of their personal data to the necessary extent as well as to the Terms of Use:

a) The following personal data will be collected for each user or, if the user is already known, transferred from the CRM system of Kombiverkehr GmbH & Co. KG to the portal with the consent of the user:

Forename, surname, title, employer, position in the company, contact details (telephone, mobile, email address), user language, permissions in the portal, receipt of notifications

The UIRR number of the company will also be shown in the user profile.

The user can consent to receiving information on a voluntary basis, e.g. on the following topics:

Offers relating to products and services, events and trade fairs, opinion surveys

b) While the portal is being used, session cookies will be set so that the user is identified on a subsequent visit.

c) The booking of transports and other entries in the portal will be recorded with reference to the respective user.

d) No personal data will be processed where service addresses for user groups are shared.

2. All personal data used and stored within the myKOMBIVERKEHR portal will be collected, processed and used by Kombiverkehr and commissioned service providers in accordance with statutory data protection requirements where this is necessary for use of the portal, performance of the contractual relationship and pursuit of the legitimate proprietary interests of Kombiverkehr within the scope of GDPR and BDSG provisions.

The following specifically applies:

a) The data can be viewed by the respective administrator of the myKOMBIVERKEHR portal solution in the user’s company (hereinafter Supervisor) and by the administrators of the portal at Kombiverkehr, Next Tuesday, CURSOR Software AG. Supervisors only have access to the user management system with 2-factor authentication.

b) Passwords can be set by the user and not seen by anyone else. Passwords can be changed by Kombiverkehr administrators at the user's request or in the event of a suspected security breach.

c) Ordinary users do not have any access to the user management system, only to the transport or communication history with assigned users. Users must consent to the data privacy statement when registering. Permissions for online services will only be allocated by the Supervisor and with additional verification.

d) Users can delete their own user account at any time. They are obliged to do so if they withdraw with effect for the future the consent to the processing of their personal data that was required when registering the user account.

e) Usage statistics will only be recorded and analysed to the extent allowed by law in pursuit of legitimate interests pursuant to point (f) of Art. 6(1) GDPR.

f) The data will be erased when the statutory or contractual retention periods and the statutory or contractual limitation periods have expired.

The Terms of Use of the myKOMBIVERKEHR portal, which can be found on the registration page under mein.kombiverkehr.de, also apply.