Privacy policy
1) Introduction and contact details of the controller
1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Digital Butlers GmbH, Rispenweg 8, 15732 Schulzendorf, Deutschland, Tel.: +491634316174, E-Mail: info@ppc-butler.com. The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
2) Data collection when visiting our website
2.1 If you use our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to the site 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 anonymized form)
The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be 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.
2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller), this website uses an SSL or SSL-encrypted connection. TLS encryption. You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser line.
3) Hosting & content delivery network
For the hosting of our website and the presentation of page content, we use a provider that provides its services itself or through selected subcontractors exclusively on servers within the European Union.
All data collected on our website is processed on these servers.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
4) Cookies
We use cookies, i.e. small text files that are stored on your end device, to make your visit to our website attractive and to enable the use of certain functions. Some of these cookies are automatically deleted again after closing the browser (so-called “session cookies”), while others remain on your device for longer and enable page settings to be saved (so-called “persistent cookies”). In the latter case, you can find the storage period in the cookie settings overview of your web browser.
If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the performance of the contract, pursuant to Art. 6 para. 1 lit. a GDPR in the case of consent given or pursuant to Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.
You can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.
Please note that if you do not accept cookies, the functionality of our website may be restricted.
5) Making contact
5.1 Zoho Bookings
We use the services of the following provider to provide an online appointment booking function: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany
Data is also transferred to: Zoho Corp, USA.
For the purpose of making appointments, in accordance with Art. 6 para. 1 lit. b GDPR, first and last name and e-mail address (and telephone number if a telephone appointment is requested) are collected and stored in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the organization of appointments.
After the appointment has been held or the agreed appointment period has expired, your data will be deleted by the provider.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
5.2 Personal data is collected when you contact us (e.g. via contact form or email). Which data is collected when a contact form is used can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration.
The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted after your request has been processed. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.
6) Online marketing
Zoho
This website uses the software-based marketing service of the following provider for the provision and synchronization of various customer management services: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany
The service enables the automated processing of feed activities, the management of advertising in deployed marketing channels and the success analysis of marketing measures as well as centralized e-mail marketing and contact management.
To perform the various functions, cookies are used, i.e. small text files that are stored locally in the cache of your web browser on your end device and enable us to analyze your use of the website. The cookies collect certain information, such as the IP address, the location and the time the page was accessed.
Data may also be transferred to: Zoho Corp, USA.
All processing described above, in particular the setting of cookies for reading information on the terminal device used, will only be carried out if you have given us your consent in accordance with Art. 6 para. 1 lit. a GDPR have given your express consent to this. You can revoke your consent at any time with effect for the future by deactivating this service in the “cookie consent tool” provided on the website.
Other legal bases for data processing that are used in the context of specific service functions (such as the need for express consent pursuant to Art. 6 para. 1 lit. a GDPR when sending newsletters) remain unaffected by this.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
7) Web analysis services
7.1 Google Tag Manager
This website uses the “Google Tag Manager”, a service of the following provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”).
The Google Tag Manager provides a technical basis for bundling various web applications, including tracking and analysis services, and calibrating, controlling and linking them to conditions via a standardized user interface. The Google Tag Manager itself does not store or read any information on user devices. The service also does not carry out any independent data analyses. However, your IP address is transmitted to Google by the Google Tag Manager when you access the page and may be stored there. Also a transmission to servers of Google LLC. This is possible in the USA.
This processing will only be carried out if you have given us your consent in accordance with Art. 6 para. 1 lit. a GDPR have given your express consent to this. Without this consent, Google Tag Manager will not be used during your visit to our website. You can revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the “cookie consent tool” provided on the website.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further legal information on Google Tag Manager can be found at https://business.safety.google
7.2 Matomo
This website uses a web analysis service from the following provider: InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, (“Matomo”)
To protect site visitors, Matomo uses a so-called “config_id” to enable various analyses of site usage within a short time window of up to 24 hours. The “config_id” of the page is a randomly set, time-limited hash of a limited set of settings and attributes of the visitor. The config_id or config hash is a character string that is calculated for a visitor based on their operating system, browser, browser plugins, IP address and browser language. Matomo does not use device fingerprinting and uses an anonymized IP address of the site visitor to create the “config_id”.
If the information processed in this way includes personal user data, the processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes. To object to data processing of your visitor data for the future, we provide you with a separate objection option on our website.
If data collected with Matomo technology (including your pseudonymized IP address) is transferred to Matomo servers in New Zealand and processed for usage analysis purposes, we inform you that the European Commission has issued a so-called adequacy decision for New Zealand, which certifies compliance with European data protection standards for international data transfers.
If data is also transferred to the provider’s server and the web analysis service is not installed locally on our server, we have concluded an order processing contract with the provider that ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
7.3 Piwik PRO
This website uses the web analysis service of the following provider: Piwik PRO GmbH, Kurfürstendamm 21,10719 Berlin, Germany
With the help of cookies and/or comparable technologies (tracking pixels, web beacons, algorithms for reading end device and browser information), the service collects and stores pseudonymized visitor data, including information about the end device used, such as the IP address and browser information, in order to evaluate it for statistical analyses of usage behavior on our website and to create pseudonymized usage profiles. Among other things, this makes it possible to evaluate movement patterns (so-called heat maps), which show the duration of page visits and interactions with page content (e.g. text input, scrolling, clicks and mouse-overs). Pseudonymization rules out the possibility of direct personal identification. Your personal data is not merged with clear data collected in any other way.
All processing described above, in particular the reading or storage of information on the terminal device used, will only be carried out if you have given us your consent in accordance with Art. 6 para. 1 lit. a GDPR have given your express consent to this. You can revoke your consent at any time with effect for the future by deactivating this service in the “cookie consent tool” provided on the website.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
8) Page functionalities
8.1 Youtube
This website uses plugins to display and play videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data may also be transmitted to: Google LLC, USA
When you access a page on our website that contains such a plugin, your browser establishes a direct connection to the provider’s servers in order to load the plugin. Certain information, including your IP address, is transmitted to the provider.
If the playback of embedded videos is started via the plugin, the provider also uses cookies to collect information about user behavior, create playback statistics and prevent abusive behavior.
If you are logged into a user account with the provider during your visit to the site, your data will be assigned directly to your account when you click on a video. If you do not wish to be associated with your account, you must log out before clicking the play button.
All of the aforementioned processing, in particular the setting of cookies for the reading of information on the terminal device used, will only take place if you have given us your express consent to do so in accordance with Art. 6 para. 1 lit. a GDPR. 1 lit. a GDPR have given. You can revoke your consent at any time with effect for the future by deactivating this service via the “cookie consent tool” provided on the website.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8.2 Provenexpert widget
Graphic elements from the following provider are integrated on our website to display external customer ratings and/or an externally awarded quality mark: Expert Systems AG, Quedlinburger Straße 1, 10589 Berlin, Germany
When you call up a page of our website that contains such graphic elements, your browser establishes a direct connection to the provider’s servers in order to load the elements properly. In the process, certain browser information, including your IP address, is transmitted to the provider.
If personal data is also processed in the process, this is done in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the optimal marketing of our offer and the appealing design of our website.
8.3 TrustPilot
Graphic elements from the following provider are integrated on our website to display external customer ratings and/or an externally awarded quality mark: Trustpilot A/S, Pilestræde 58, 1112 Copenhagen, Denmark
When you call up a page of our website that contains such graphic elements, your browser establishes a direct connection to the provider’s servers in order to load the elements properly. In the process, certain browser information, including your IP address, is transmitted to the provider.
If personal data is also processed in the process, this is done in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the optimal marketing of our offer and the appealing design of our website.
8.4 Google Web Fonts
This site uses so-called web fonts from the following provider for the uniform display of fonts: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
When you access a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly and establishes a direct connection to the provider’s servers. In the process, certain browser information, including your IP address, is transmitted to the provider.
Data may also be transmitted to: Google LLC, USA
The processing of personal data in the course of establishing a connection with the font provider is only carried out if you have given us your consent in accordance with Art. 6 para. 1 lit. a GDPR have given your express consent to this. You can revoke your consent at any time with effect for the future by deactivating this service via the “cookie consent tool” provided on the website. If your browser does not support web fonts, a standard font will be used by your computer.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further information on Google’s privacy policy can be found here: https://business.safety.google
8.5 Google Meet
We use this provider to conduct online meetings, video conferences and/or webinars: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
This may also involve transmission to the servers of Google LLC. in the USA.
The provider processes different data, whereby the scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. Your data is processed as a communication participant and stored on the provider’s servers. In particular, this may include your login data (name, email address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).
In addition, image and sound contributions from participants as well as voice input in chats may be processed.
Art. 6 para. 1 lit. a GDPR serves as the legal basis for the processing of personal data required for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures). 1 lit. b GDPR as the legal basis. If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future.
Otherwise, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 para. 1 lit. a GDPR. 1 lit. f GDPR in the effective implementation of the online meeting, webinar or video conference.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8.6 Zoho Meetings
We use this provider to conduct online meetings, video conferences and/or webinars: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf
This may also result in a transmission to the servers of Zoho Corp. in the USA.
The provider processes different data, whereby the scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. Your data is processed as a communication participant and stored on the provider’s servers. In particular, this may include your login data (name, email address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).
In addition, image and sound contributions from participants as well as voice input in chats may be processed.
Art. 6 para. 1 lit. a GDPR serves as the legal basis for the processing of personal data required for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures). 1 lit. b GDPR as the legal basis. If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future.
Otherwise, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 para. 1 lit. a GDPR. 1 lit. f GDPR in the effective implementation of the online meeting, webinar or video conference.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8.7 Zoom
We use this provider to conduct online meetings, video conferences and/or webinars: Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA
The provider processes different data, whereby the scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. Your data is processed as a communication participant and stored on the provider’s servers. In particular, this may include your login data (name, email address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).
In addition, image and sound contributions from participants as well as voice input in chats may be processed.
Art. 6 para. 1 lit. a GDPR serves as the legal basis for the processing of personal data required for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures). 1 lit. b GDPR as the legal basis. If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future.
Otherwise, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 para. 1 lit. a GDPR. 1 lit. f GDPR in the effective implementation of the online meeting, webinar or video conference.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8.8 Applications for job advertisements by e-mail
We advertise current vacancies on our website in a separate section, for which interested parties can apply by e-mail to the contact address provided.
Applicants must provide all personal data necessary for an informed assessment, including general information such as name, address and contact details, as well as performance-related evidence and, where applicable, health-related information. Details of how to apply can be found in the job advertisement.
After receipt of the application by e-mail, the data will be stored and evaluated exclusively for the purpose of processing the application. In the event of queries, we will use either the applicant’s e-mail address or telephone number. The processing takes place on the basis of Art. 6 para. 1 lit. b GDPR (or Section 26 (1) BDSG), in the sense of which the application process is considered to be the initiation of an employment contract.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data such as information on severely disabled status) are requested from applicants as part of the application process, the processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR so that we can exercise the rights arising from labor law and social security and social protection law and fulfill our obligations in this regard.
Cumulatively or alternatively, the processing of special categories of data may also be based on Art. 9 para. 1 lit. h GDPR if it is carried out for the purposes of preventive health care or occupational medicine, for the assessment of the applicant’s fitness for work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector.
If the applicant is not selected or if an applicant withdraws their application prematurely, their submitted data and all electronic correspondence, including the application email, will be deleted after 6 months at the latest following a corresponding notification. This period is based on our legitimate interest in answering any follow-up questions about the application and, if necessary, to be able to comply with our obligations to provide evidence under the regulations on equal treatment of applicants.
In the event of a successful application, the data provided will be processed on the basis of Art. 6 para. 1 lit. b GDPR (for processing in Germany in conjunction with Section 26 (1) BDSG) for the purpose of implementing the employment relationship.
9) Tools and miscellaneous
9.1 Cookie consent tool
This website uses a so-called “cookie consent tool” to obtain effective user consent for cookies requiring consent and cookie-based applications. The “Cookie Consent Tool” is displayed to users in the form of an interactive user interface when they access a page, where they can give their consent to certain cookies and/or cookie-based applications by ticking a box. By using the tool, all cookies/services requiring consent are only loaded if the respective user gives their consent by ticking the relevant box. This ensures that such cookies are only set on the user’s end device if consent has been given.
The tool sets technically necessary cookies to save your cookie preferences. Personal user data is not processed in this context.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) (f) GDPR. 1 lit. f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.
Another legal basis for the processing is Art. 6 para. 1 lit. c GDPR. As the controller, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
Where necessary, we have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
Further information about the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
9.2 – Zoho Sign
For the digital signing of documents, we use the services of the following provider:
Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany
Data may also be transferred to: Zoho Corp, USA.
The service enables the legally valid signing of documents by electronic signature from any end device.
For this purpose, the service collects, stores and transmits not only the electronic signature for verification and proof of signature but also usage data of the end device used (in particular the IP address) and certain transaction data.
Processing is carried out on the basis of our legitimate interest in efficient and responsive business management and customer-friendly and effective document management in accordance with Art. 6 para. 1 lit. a GDPR. 1 lit. f GDPR.
We have concluded an order processing contract with the provider, which protects the data of our website visitors and prohibits disclosure to third parties.
10) Rights of the data subject
10.1 The applicable data protection law grants you the following data subject rights (rights of access and intervention) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the stated legal basis for the respective exercise requirements:
- Right to information pursuant to Art. 15 GDPR;
- Right to rectification pursuant to Art. 16 GDPR;
- Right to erasure pursuant to Art. 17 GDPR;
- Right to restriction of processing pursuant to Art. 18 GDPR;
- Right to information pursuant to Art. 19 GDPR;
- Right to data portability pursuant to Art. 20 GDPR;
- Right to withdraw consent granted pursuant to Art. 7 para. 3 GDPR;
- Right to lodge a complaint pursuant to Art. 77 GDPR.
10.2 RIGHT OF OBJECTION
IF WE PROCESS YOUR PERSONAL DATA AS PART OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS.
IF YOUR PERSONAL DATA ARE PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING. YOU CAN EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
11) Duration of storage of personal data
The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and – if relevant – additionally by the respective statutory retention period (e.g. retention periods under commercial and tax law).
When processing personal data on the basis of express consent pursuant to Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.
If there are statutory retention periods for data that are required in the context of legal or quasi-legal obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after expiry of the retention periods, provided that it is no longer required for contract fulfillment or contract initiation and/or we no longer have a legitimate interest in further storage.
When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.
When processing personal data for the purpose of direct marketing on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 para. 2 DSGVO ausüben.
Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data is deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.