1) Information on the collection of personal data and contact details of the responsible person
1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our website. In this context, personal data is all data with which you can be personally identified.
1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (DSGVO) is LiveBridge GmbH i.G., Dr.-Hofmeister-Strasse 13a, 85764 Oberschleißheim, Germany, Tel.: 08952300686, e-mail: email@example.com. The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or enquiries to the controller). You can recognise an encrypted connection by the string “https://” and the lock symbol in your browser line.
2) Data collection when visiting our website
When you use our website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect the data that your browser transmits to our server (so-called “server log files”). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:
– Our visited website
– Date and time at the time of access
– Amount of data sent in bytes
– Source/reference from which you reached the page
– Browser used
– Operating system used
– IP address used (if applicable: in anonymised form)
The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of unlawful use.
In order to make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your terminal device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your end device and enable us or our partner companies (third-party cookies) to recognise your browser on your next visit (persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data and IP address values to an individual extent. Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie.
If personal data is also processed by individual cookies implemented by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b DSGVO either for the execution of the contract or in accordance with Art. 6 para. 1 lit. f DSGVO to protect our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.
We may work with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). If we cooperate with aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the paragraphs below.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and can decide individually about their acceptance or can exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:
Internet Explorer: http://windows.microsoft.com/de-DE/windows-vista/Block-or-allow-cookies
Please note that if you do not accept cookies, the functionality of our website may be limited.
4) Contacting us
When contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected when using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. The legal basis for processing this data is our legitimate interest in responding to your request in accordance with Art. 6 Para. 1 lit. f DSGVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DSGVO. Your data will be deleted after your request has been processed. This is the case when the circumstances indicate that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.
5) Online appointment
This website uses the “Calendly” software of the provider Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA to provide an online appointment booking function.
For the purpose of making an appointment, first name, surname and email address (and telephone number if a telephone appointment is requested) are collected in accordance with Art. 6 Para. 1 lit. b DSGVO and transmitted to Calendly in accordance with Art. 6 Para. 1 lit. f DSGVO on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the purpose of organising the appointment. After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by Calendly. We have concluded an order processing agreement with Calendly (“Data Processing Addendum”, available at https://calendly.com/pages/dpa), in which we oblige Calendly to protect the data of our customers in accordance with the legal requirements. Calendly generally transfers collected information outside the European Economic Area and relies on so-called standard data protection clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.
Details of Calendly’s data protection policy can be found here: https://calendly.com/de/pages/privacy.
6) Registration with the portal or forum
You can register on our website by providing personal data. Which personal data is processed for the registration can be seen from the input mask used for the registration. We use the so-called double-opt-in procedure for registration, i.e. your registration is only completed once you have confirmed your registration by clicking on the link contained in a confirmation e-mail sent to you for this purpose. If your confirmation is not received within 24 hours, your registration will be automatically deleted from our database. The provision of the above-mentioned data is mandatory. You can provide all other information voluntarily by using our portal.
If you use our portal, we store your data required for the fulfilment of the contract, including any information on the method of payment, until you finally delete your access. Furthermore, we store the voluntary data you provide for the duration of your use of the portal, unless you delete it beforehand. You can manage and change all details in the protected customer area. The legal basis is Art. 6 para. 1 lit. f DSGVO.
In addition, we store all content published by you (such as public posts, pinboard entries, guestbook entries, etc.) in order to operate the website. We have a legitimate interest in providing the website with the full user-generated content. The legal basis for this is Art. 6 para. 1 lit. f DSGVO. If you delete your account, your public statements, especially in the forum, remain visible to all readers, but your account can no longer be accessed. All other data will be deleted in this case.
7) Use of customer data for direct advertising
Registration for our e-mail newsletter
If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.
By activating the confirmation link, you give us your consent for the use of your personal data in accordance with Art. 6 Para. 1 lit. a DSGVO. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the purpose of addressing you in an advertising manner by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data or we reserve the right to use your data in a manner that goes beyond this, which is permitted by law and about which we inform you in this declaration.
8) Use of social media: social plugins
8.1 Facebook plugins with Shariff solution
Our website uses so-called social plugins (“plugins”) of the social network Facebook, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
In order to increase the protection of your data when visiting our website, these buttons are not fully integrated into the page as plugins, but only using an HTML link. This type of integration ensures that when you call up a page of our website that contains such buttons, no connection is yet established with Facebook’s servers. When you click on the button, a new browser window opens and calls up the Facebook page where you can interact with the plugins there (if necessary after entering your login data).
8.2 LinkedIn plugin as Shariff solution
Our website uses so-called social plugins (“plugins”) of the online service LinkedIn, which is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”).
In order to increase the protection of your data when visiting our website, these buttons are not fully integrated into the page as plugins, but only using an HTML link. This type of integration ensures that when you call up a page of our website that contains such buttons, no connection is yet established with the servers of LinkedIn. When you click on the button, a new browser window opens and calls up the LinkedIn page on which you can interact with the plugins there (possibly after entering your login data).
8.3 Xing plugins
9) Use of social media: videos
Use of Youtube videos
This website uses the Youtube embedding function to display and play videos from the provider “Youtube”, which belongs to Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
Independently of a playback of the embedded videos, a connection to the Google network is established each time this website is called up, which may trigger further data processing operations without our influence.
As far as legally required, we have obtained your consent for the processing of your data as described above in accordance with Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future. To exercise your revocation, deactivate this service in the “Cookie Consent Tool” provided on the website.
10) Online marketing
10.1 Facebook Pixel for the creation of Custom Audiences with extended data matching (with Cookie-Consent-Tool)
Within our online offer, the so-called “Facebook Pixel” of the social network Facebook is used in the mode of extended data matching, which is operated by Facebook Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland (“Facebook”).
On the basis of the user’s express consent, when a user clicks on an advertisement played on Facebook and placed by us, an addition is added to the URL of our linked page by Facebook Pixel. After forwarding, this URL parameter is then inscribed in the user’s browser via a cookie, which our linked page sets itself. In addition, this cookie collects specific customer data, such as the email address, which we collect on our website linked to the Facebook ad during transactions such as purchase transactions, account logins or registrations (extended data matching). The cookie is then read by Facebook Pixel and enables the data, including the specific customer data, to be forwarded to Facebook.
With the help of the Facebook Pixel with extended data matching, it is possible for Facebook, on the one hand, to precisely determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel with advanced data matching to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel with advanced data matching, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. This allows us to further evaluate the effectiveness of the Facebook ads for statistical and market research purposes by tracking whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”). Compared to the standard variant of Facebook Pixel, the extended data matching function helps us to better measure the effectiveness of our advertising campaigns by capturing more attributed conversions.
All transmitted data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook data usage policy (https://www.facebook.com/about/privacy/). The data may enable Facebook and its partners to serve ads on and off Facebook.
These processing operations will only be carried out if explicit consent is given in accordance with Art. 6 (1) lit. a DSGVO.
Consent to the use of the Facebook Pixel may only be given by users who are older than 13 years of age. If you are younger, we ask you to ask your legal guardians for permission.
The information generated by Facebook is usually transmitted to a Facebook server and stored there; this may also involve transmission to the servers of Facebook Inc. in the USA. You can revoke your consent at any time with effect for the future. To exercise your revocation, remove the checkmark next to the setting for the “Facebook Pixel” in the “Cookie Consent Tool” integrated on the website.
10.2 Google AdSense
This website uses Google AdSense, a web advertising service Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google AdSense uses so-called cookies, which are text files placed on your computer, to help the website analyse how users use the site. In addition, Google AdSense also uses so-called “web beacons” (small invisible graphics) to collect information, through the use of which simple actions such as visitor traffic on the website can be recorded, collected and evaluated. The information generated by the cookie and/or web beacon (including your IP address) about your use of this website is usually transmitted to a Google server and stored there. This may also involve transmission to the servers of Google LLC. in the USA.
Google uses the information thus obtained to carry out an evaluation of your usage behaviour with regard to the AdSense ads. The IP address transmitted by your browser as part of Google AdSense will not be merged with other Google data. The information collected by Google may be transferred to third parties if this is required by law and/or if third parties process this data on behalf of Google.
The processing of data described above is carried out in accordance with Art. 6 Para. 1 lit. f DSGVO for the purpose of targeted advertising to the user by advertising third parties, whose advertisements are displayed on this website on the basis of the evaluated user behaviour. This processing also serves our financial interest in exploiting the economic potential of our website by displaying personalised third-party advertising content in return for payment.
You can permanently deactivate cookies for advertising preferences by setting your browser software accordingly or you can download and install the browser plug-in available under the following link:
As far as legally required, we have obtained your consent pursuant to Art. 6 (1) lit. a DSGVO for the processing of your data as described above. You can revoke your consent at any time with effect for the future. In order to exercise your revocation, please follow the option described above for making an objection.
10.3 LinkedIn Marketing Solutions
We use “LinkedIn Marketing Solutions” on our website, a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (hereinafter “LinkedIn”). This enables us to point visitors to our website to our own content based on their usage behaviour on the LinkedIn social network, which is likely to be of interest to the user in question. This content is displayed on the basis of a cookie-based analysis of previous user behaviour, but no personal data is stored. For this interest-based content determination, cookies, i.e. small text files, are stored on your computer or mobile device in order to collect pseudonymised data about your surfing behaviour and thus adapt the content individually to the stored information.
Insofar as the collected and evaluated information has a personal reference, the processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in displaying personalised page content and in market research.
The information can be assigned to the person of the user with the help of further information that LinkedIn has stored about the user, e.g. due to the ownership of an account on the social network “LinkedIn”. LinkedIn uses an algorithm to analyse the surfing behaviour and can then display targeted product recommendations as personalised advertising banners on the user’s LinkedIn account. LinkedIn may also combine the information collected via the cookies with further information that LinkedIn has collected via other websites and / or in connection with the use of the social network “LinkedIn”, and thus create pseudonymised usage profiles. In no case, however, can the collected information be used to personally identify visitors to this website.
You can prevent the collection of the aforementioned information by LinkedIn by setting an opt-out cookie on one of the websites linked below:
As far as legally required, we have obtained your consent for the processing of your data as described above in accordance with Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future by deactivating this service in the “Cookie Consent Tool” integrated on this website.
Further information on the data protection provisions of LinkedIn can be found on the following website: https://www.linkedin.com/legal/privacy-policy.
11) Retargeting/ Remarketing/ Referral advertising
Google Ads Remarketing
Our website uses the Google Ads Remarketing function to advertise this website in Google search results and on third-party websites. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). For this purpose, Google sets a cookie in the browser of your terminal device, which automatically enables interest-based advertising by means of a pseudonymous cookie ID and on the basis of the pages you visit. The processing is based on our legitimate interest in the optimal marketing of our website in accordance with Art. 6 para. 1 lit. f DSGVO.
Further data processing will only take place if you have consented to Google linking your internet and app browsing history to your Google account and using information from your Google account to personalise the ads you see on the web. In this case, if you are logged into Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, your personal data will be temporarily linked by Google with Google Analytics data in order to form target groups. In the context of the use of Google Ads Remarketing, personal data may also be transmitted to the servers of Google LLC. in the USA.
You can permanently deactivate the setting of cookies for advertising preferences by downloading and installing the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/.
Alternatively, you can obtain information from the Digital Advertising Alliance at the Internet address www.aboutads.info about the setting of cookies and make settings in this regard. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. If you do not accept cookies, the functionality of our website may be limited. Further information and the data protection provisions regarding advertising and Google can be viewed here:
As far as legally required, we have obtained your consent for the processing of your data as described above in accordance with Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future. In order to exercise your revocation, please follow the option described above for making an objection.
12) Tools and miscellaneous
12.1 – Borlabs
This website uses the cookie consent tool Borlabs of the provider Mr Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg (“Borlabs”), which sets two technically necessary cookies (“borlabsCookie” and “borlabsCookieUnblockContent”) to store your cookie preference. The aforementioned processing is carried out pursuant to Art. 6 (1) lit. f DSGVO on the basis of our legitimate interest in providing cookie preference management for website visitors.
The “borlabs cookie” does not process any personal data. The “borlabsCookie” cookie stores your chosen preference, which you selected when you entered the website. The “borlabsCookieUnblockContent” cookie stores which (external) media/content you always want to have automatically unblocked. If you want to revoke these settings, simply delete the cookies in your browser. When you re-enter/reload the website, you will be asked again for your cookie preference.
12.2 – BigBlueButton
We use the open source service “BigBlueButton” provided by BigBlueButton Inc. (hereinafter “BigBlueButton “) to conduct online meetings, video conferences and/or webinars.
In the case of the use of BigBlueButton, different data are processed. The scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. In the course of using BigBlueButton, data of the communication participants will be processed and stored on servers of BigBlueButton. This data may include, in particular, your login data (name, email address, phone (optional) and password) and meeting data (topic, participant IP address, device information, description (optional)). In addition, visual and auditory contributions of the participants as well as voice inputs in chats may be processed.
When processing personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) lit. b DSGVO serves as the legal basis. If you have given us your consent for the processing of your data, the processing is based on Art. 6 (1) a DSGVO. Consent given can be revoked at any time with effect for the future.
Furthermore, the legal basis for data processing when conducting online meetings, videoconferences or webinars is our legitimate interest pursuant to Art. 6 para. 1 lit. f DSGVO in the effective conduct of the online meeting, webinar or videoconference.
13) Rights of the data subject
13.1 The applicable data protection law grants you comprehensive data subject rights (rights of access and intervention) vis-à-vis the controller with regard to the processing of your personal data, which we inform you about below:
– Right of access pursuant to Art. 15 DSGVO: In particular, you have the right to obtain information about your personal data processed by us, the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom your data have been or will be disclosed, the intended storage period or the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it has not been collected from you by us, the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and the intended effects of such processing concerning you, as well as your right to be informed about which guarantees exist in accordance with Art. 46 DSGVO in case of transfer of your data to third countries;
– Right to rectification pursuant to Art. 16 of the GDPR: You have the right to have any inaccurate data relating to you rectified without delay and/or to have any incomplete data stored by us completed;
– Right to deletion pursuant to Art. 17 DSGVO: You have the right to demand the deletion of your personal data if the requirements of Art. 17 (1) DSGVO are met. However, this right does not exist in particular if the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;
– Right to restriction of processing pursuant to Art. 18 of the GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is being verified; if you refuse the erasure of your data due to unlawful data processing and instead request the restriction of the processing of your data; if you require your data for the assertion, exercise or defence of legal claims after we no longer need this data after the purpose has been achieved; or if you have lodged an objection for reasons relating to your particular situation as long as it has not yet been determined whether our legitimate grounds prevail;
– Right to information pursuant to Art. 19 DSGVO: If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
– Right to data portability pursuant to Art. 20 DSGVO: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller, insofar as this is technically feasible;
– Right to revoke consent given in accordance with Art. 7 (3) DSGVO: You have the right to revoke consent to the processing of data once given at any time with effect for the future. In the event of revocation, we will immediately delete the data concerned unless further processing can be based on a legal basis for processing without consent. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation;
– Right to lodge a complaint pursuant to Art. 77 GDPR: If you consider that the processing of personal data concerning you infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, without prejudice to any other administrative or judicial remedy.
13.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA IN THE CONTEXT OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE AT ANY TIME ON GROUNDS ARISING FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR THE PURPOSES OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSES OF SUCH MARKETING. YOU MAY EXERCISE THE RIGHT TO OBJECT AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
14) Duration of storage of personal data
The duration of the storage of personal data is measured on the basis of the respective legal basis, the processing purpose and – if relevant – additionally on the basis of the respective statutory retention period (e.g. retention periods under commercial and tax law).
When processing personal data on the basis of explicit consent pursuant to Art. 6 para. 1 lit. a DSGVO, this data is stored until the data subject revokes his/her consent.
If there are statutory retention periods for data that is processed within the scope of legal or quasi-legal obligations on the basis of Art. 6 Para. 1 lit. b DSGVO, this data will be routinely deleted after expiry of the retention periods, insofar as it is no longer required for the fulfilment of a contract or the initiation of a contract and/or there is no further justified interest on our part in continuing to store it.
When processing personal data on the basis of Art. 6(1)(f) DSGVO, such data shall be stored until the data subject exercises his/her right to object pursuant to Art. 21(1) DSGVO, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
When processing personal data for the purpose of direct marketing on the basis of Art. 6(1)(f) DSGVO, such data shall be stored until the data subject exercises his or her right to object pursuant to Art. 21(2) DSGVO.
Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.