Privacy Policy

As of May 2023

Table of Contents

I. Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:

Resourcify GmbH
Schopenstehl 13
20095 Hamburg
Germany

+49 40 22861738
hello@resourcify.com
https://www.resourcify.com/

II. Contact details of the data protection officer

The designated data protection officer is:

DataCo GmbH
Dachauer Str. 65
80335 Munich
Germany

+49 89 7400 45840
www.dataguard.de

III. General information on data processing

1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

2. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (1) (a) GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) GDPR will serve as the legal basis for the processing of data.

3. Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

IV. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:

1. Right of access (Art. 15 GDPR)

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

  • Purposes of processing.
  • Categories of personal data being processed.
  • Recipients or categories of recipients to whom the personal data have been or will be disclosed.
  • Planned storage period or the criteria for determining this period.
  • The existence of the rights of rectification, erasure or restriction or opposition.
  • The existence of the right to lodge a complaint with a supervisory authority.
  • If applicable, origin of the data (if collected from a third party).
  • If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
  • If applicable, transfer of personal data to a third country or international organization.

2. Right to rectification (Art. 16 GDPR)

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing (Art. 18 GDPR)

You may request the restriction of the processing of your personal data under the following conditions:

  • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
  • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
  • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
  • If you have objected to the processing pursuant and it is not yet certain whether the legitimate interests of the data controller override your interests.

4. Right to erasure ("Right to be forgotten") (Art. 17 GDPR)

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
  • You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data.
  • You object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
  • Your personal data has been processed unlawfully.
  • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
  • Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

The right to deletion does not exist if the processing is necessary

  • to exercise the right to freedom of speech and information;
  • to fulfill a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
  • for reasons of public interest in the field of public health.
  • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes.
  • to enforce, exercise or defend legal claims.

5. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

6. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) GDPR; this also applies to profiling based on these provisions.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

7. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR. A list, of the locally competent supervisory authorities in Germany can be found on the website of the Federal Commissioner for Data Protection at the following link: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html

V. Provision of website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

  • Browser type and version used
  • The user's operating system
  • The IP address of the user
  • Date and time of access
  • Web pages from which the user’s system accessed our website

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) (1) (f) GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (1) (f) GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.
If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.

5. Objection and removal

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.

VI. Use of cookies

1. Description and scope of data processing

When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select. You can make changes in your browser settings or via our consent manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie. Below we describe what kind of cookies we use:

We use technically necessary cookies, which are required for the technical structure of the website. Without these cookies, our website cannot be displayed (completely correctly) or the support functions are not possible.

The following data is stored and transmitted in the technical necessary cookies:

  • Language settings

We use cookies on our website that are not technically necessary. Technically unnecessary cookies are text files that are not only used for the functionality of the website, but also collect other data.

As a result, the following data will be processed:

  • IP-address
  • Internet user location
  • Date and time of the website visit
  • Customization of advertisements to the user
  • Tracking of the surfing behavior
  • Linking the website visit with other social media platforms

2. Purpose of data processing

The purpose of using technically necessary cookies is to ensure the functionality of our website. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

We need technical necessary cookies for the following purposes:

  • Applying language settings

The use of technically not necessary cookies is carried out for the purpose of improving the quality of our website, its content and thus our reach and profitability. By setting these cookies, we learn how the website is used and can thus constantly optimize our offer. These cookies serve us particularly for the following purposes:

Wir nutzen einen oder mehrere Drittanbieter, um Werbung für unsere Produkte und Dienstleistungen auf anderen Websites zu schalten.

3. Legal basis for data processing

The regulations of the Telecommunications-Telemedia Data Protection Act (TTDSG) are relevant for the storage of information in the end user's terminal equipment and/or access to information already stored in the end user's terminal equipment. If the setting and reading of cookies is technically necessary, this is done to ensure the functionality of our website. In this case, the storage of and access to cookies on your terminal equipment is carried out on the basis of § 25(2)(2) TTDSG. This storage of and access to the information in your terminal equipment serves to facilitate your use of our website and to be able to offer you our services as you have requested. Some functions of our website also do not work without the use of these cookies and could therefore not be offered. The cookies are generally deleted after the session ends (e.g. logging out or closing the browser) or after the expiry of a specified duration. Information on different storage periods for cookies can be found in the following sections of this data protection declaration.

As far as cookies are set that are not technically necessary, this is done on the basis of your expressed consent, which you can provide via the cookie banner. The basis for storing and accessing information in this case is § 25(1) TTDSG in conjunction with. Art. 6(1)(1)(a), Art. 7 GDPR. You can withdraw your consent at any time with effect for the future or subsequently grant it again by configuring your settings for cookies accordingly. Alternatively, you can prevent the storage of cookies by making the appropriate settings in your browser software. Please note that the browser settings you make only affect the browser you are using. If personal data is processed following the storage of and access to the information on your terminal equipment, the provisions of the GDPR are relevant. Information on this can be found in the following sections of this privacy policy.

VII. Newsletter

1. Description and scope of data processing

You can subscribe to a newsletter on our website free of charge. When subscribing for the newsletter, the data from the input mask is transmitted to us.

  • Email address

No data will be passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.

2. Purpose of data processing

The user's email address is collected to deliver the newsletter to the recipient.
Additional personal data as part of the registration process is collected to prevent misuse of the services or email address.

3. Legal basis for data processing

The legal basis for the processing of data provided by the user after registration for the newsletter is Art. 6 (1) (1) (a) GDPR if the user has given his consent.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user's email address will therefore be stored as long as the newsletter subscription is active.

The other personal data collected during the registration process is generally deleted after a period of seven days.

5. Objection and removal

The subscription for the newsletter can be cancelled by the data subject at any time. For this purpose, every newsletter contains an opt-out link.

Through this, it is also possible to withdraw the consent to the storage of personal data collected during the registration process.

VIII. Contact via email

1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) (f) GDPR. Our legitimate interest is to optimally answer your request that you send by email.

If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

The user may object to the processing of the data provided at any time by sending a message to our email address datenschutz@resourcify.de.

In this case, all personal data stored while establishing contact will be deleted.

IX. Contact form

1. Description and scope of data processing

A Contact form is available on our website, which can be used for electronic contact. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

When sending the message the following data will also be stored:

  • Email address
  • Last name
  • First name
  • Telephone / mobile phone number
  • Date and time of contact
  • Job title
  • Company
  • Your message

2. Purpose of data processing

The processing of the personal data from the input mask as well as if you contact us by mail serves us exclusively for the purpose of establishing contact.

The other personal data processed during the sending process serve to prevent misuse of the Contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) GDPR.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the Contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

If the user contacts us via the input mask in the contact form or via e-mail, the user can object to the storage of his or her personal data at any time.

The user may object to the processing of the data provided at any time by sending a message to our e-mail address datenschutz@resourcify.de.

In this case, all personal data stored while establishing contact will be deleted.

X. Application via email and application form

1. Scope of processing personal data

There is a form on our website which can be used for electronic job applications. If an applicant makes use of this possibility, the data entered in the input mask will be transmitted to us and stored. The data is:

  • First name
  • Last name
  • Telephone / mobile phone number
  • Email address
  • Salary expectations
  • Language skills
  • Curriculum vitae

Alternatively, you can send us your application by email. In this case, we collect your email address and the information you provide in the email.

After sending your application, you will receive confirmation of receipt of your application documents from us by email.

Your data will not be passed on to third parties. The data will be used exclusively for processing your application.

2. Purpose of data processing

The processing of personal data from the application form serves us solely to process your application. If you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the application form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for the processing of the data is the initiation of the contractual relationship at the request of the data subject, Art. 6 (1) (1) (b) Alt. 1 GDPR and § 26 (1) (1) BDSG (Federal Act of Dataprotection).

The legal basis for the processing of data within the context of the applicant pool is the applicant's express consent, Art. 6 (1) (1) (a) GDPR.

4. Duration of storage

After completion of the application procedure, the data will be stored for up to six months. Your data will be deleted after six months at the latest. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Exercising your rights

The applicant may exercise his/her rights at any time by sending a message to our e-mail address datenschutz@resourcify.de.

XI. Hosting

The website is hosted on servers of a service provider commissioned by us.

Our service provider is:

ALL-INKL.COM - New Media Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website.

The stored information is:

  • Browser type and version
  • Used operating system
  • Referrer URL
  • Hostname of the accessing computer
  • Time and date of the server request
  • IP address of the user's device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - and server log files are therefore recorded.

The server of the website is geographically located in Germany.

XII. Usage of Plugins

We use plugins for various purposes. The plugins used are listed below:

Use of Google Analytics

1. Scope of the processing of personal data

We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and the representative in the Union Google Ireland Ltd, Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (hereinafter: Google). Google Analytics examines, among other things, the origin of visitors, the time they spend on individual pages, and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google sets a cookie on your computer. This allows personal data to be stored and evaluated, in particular the activity of the user (especially which pages have been visited and which elements have been clicked on), device and browser information (especially the IP address and operating system), data about the advertisements displayed (especially which advertisements were displayed and whether the user clicked on them) and also data from advertising partners (especially pseudonymized user IDs).

We use Google Analytics (Universal Analytics) to evaluate your use of our online presence, to compile reports on your activities and to use further Google services associated with the use of our online presence and internet usage.
We have requested the anonymization of IP addresses, which means that Google will shorten your IP address as promptly as technically possible. However, it cannot be ruled out that your data will be transmitted to the servers of Google LLC based in the USA.

On behalf of the operator of this online presence, Google will use this information for the purpose of evaluating your use of the online presence, compiling reports on the activities of the online presence and providing other services relating to the use of the online presence and internet usage to the operator of the online presence.

More information on the processing of data by Google can be found here: https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing

The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (1) (a) GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law.

5. Withdrawal option

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent up to the revocation.

You can prevent the collection as well as the processing of your personal data by Google by preventing the storage of third-party cookies on your computer, using the "Do Not Track" function of a supporting browser, disabling the execution of script code in your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

You can also prevent the collection of data generated by the cookie and related to your use of the online presence (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=de

You can deactivate the use of your personal data by Google using the following link:
https://adssettings.google.de

For more information on objection and removal options vis-à-vis Google, see:
https://policies.google.com/privacy?gl=DE&hl=de

6. Danger notice

Your personal data will also be transferred to the USA. There is no adequacy decision for the USA according to Art. 45 (3) GDPR. We would like to point out that data transfer without an adequacy decision entails certain risks, which we would like to inform you about below:

Intelligence services in the USA use certain online identifiers (such as the IP address or unique identification numbers) as a starting point for monitoring individuals. In particular, it cannot be ruled out that these intelligence services have already collected information about you, with the help of which the data transmitted here can be traced back to you.
Providers of electronic communications services headquartered in the U.S. are subject to monitoring by U.S. intelligence services pursuant to 50 U.S. Code § 1881a ("FISA 702"). Accordingly, providers of electronic communications services headquartered in the U.S. have an obligation to provide personally identifiable information to U.S. authorities pursuant to 50 U.S. Code § 1881a, with no possible recourse available to you. Even encryption of data at the electronic communications service provider's data centers may not provide adequate protection because, with respect to imported data in its possession or custody or under its control, an electronic communications service provider has a direct obligation to provide access to or surrender such data. This obligation may explicitly extend to the cryptographic keys without which the data cannot be read.

The fact that this is not merely a "theoretical risk" is demonstrated by the ECJ ruling of July 16, 2020 (Case C 311/18, ,,Schrems-II").

With Google, we have concluded guarantees in the form of standard data protection clauses pursuant to Art. 46 (2) lit. c DSGVO. A copy of the standard data protection clauses can be requested from us.

Use of Hotjar

1. Scope of processing of personal data

We use the Hotjar web analysis service of Hotjar Ltd, Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta (Hereinafter: Hotjar). Hotjar uses cookies, i.e. small text files, which are stored locally in the cache of your web browser on your end device and which enable an analysis of the use of our online presence by you. Personal data can thus be stored and evaluated, in particular the user's activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system) and a tracking code (pseudonymised user ID). The information thus collected will be transferred by Hotjar to a server in Ireland and stored there in an anonymised form. Further information on the collection and storage of data by Hotjar can be found at:
https://www.hotjar.com/legal/policies/privacy

2. Purpose of data processing

The use of the Hotjar Plug-In serves to better understand the needs of our users and to optimize the offer on this online presence.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (1) (a) GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent Hotjar from collecting and processing your personal data by preventing the storage of third-party cookies on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser, or by using a script blocker such as a "Do Not Track" function.B. Install NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

With the following link you can deactivate the use of your personal data by Hotjar:
https://www.hotjar.com/legal/compliance/opt-out

For more information on objection and removal options against Hotjar please visit:
https://www.hotjar.com/legal/policies/privacy

Use of HubSpot

1. Scope of processing of personal data

We use functions of HubSpot Inc., 2nd Floor, 25 First Street, Cambridge, MA 02141, USA (Hereinafter referred to as HubSpot). This is an integrated software solution that covers various aspects of our online marketing. These include, among other things: Email marketing (newsletters and automated mailings, e.g. to provide downloads), social media publishing & reporting, reporting (especially traffic sources, access, etc. ...), contact management (especially user segmentation & CRM), landing pages and contact forms. HubSpot sets a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user's activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs).

Further information on the collection and storage of data by HubSpot can be found at:
https://legal.hubspot.com/privacy-policy

2. Purpose of data processing

The use of the HubSpot Plug-In serves exclusively for the optimization of our marketing.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (1) (a) GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent HubSpot from collecting and processing your personal data by preventing the storage of cookies from third parties on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net) or Ghostery (https://www.ghostery.com) in your browser.

You can find further information on objection and removal options against HubSpot at:
https://legal.hubspot.com/privacy-policy

You can also find further information on objection and removal options against HubSpot at: https://legal.hubspot.com/privacy-policy

This privacy policy has been created with the assistance of DataGuard.