Privacy Policy

We take the protection of personal data very seriously and comply with the relevant legal regulations. The following declaration informs you about what type of data is collected for what purpose and to what extent this data is made accessible to third parties.

We take the protection of personal data very seriously and comply with the relevant legal provisions. The following policy explains what type of data is collected, for what purpose, and to what extent this data is made available to third parties.

1. Hosting and Content Delivery Networks (CDN)

This website is hosted externally. The personal data collected on this website is stored on the servers of the hosting provider(s). This may primarily include IP addresses, contact enquiries, meta and communication data, contractual data, contact details, names, website visits and other data generated via a website.

External hosting is carried out for the purpose of fulfilling our contractual obligations towards our potential and existing customers (Article 6(1)(b) of the GDPR) and in the interest of ensuring the secure, fast and efficient provision of our online services by a professional provider (Article 6(1)(f) of the GDPR). Where relevant consent has been sought, processing takes place exclusively on the basis of Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

Our hosting provider(s) will only process your data to the extent that this

Our hosting provider(s) will only process your data to the extent necessary to fulfil their service obligations and will comply with our instructions regarding this data.

We host the content of our website with the following providers:

Neue Medien Muennich
Hoster: ALL-INKL.COM - Neue Medien Münnich
Owner: René Münnich
Hauptstraße 68 | D-02742 Friedersdorf, Germany

Please refer to the privacy policy for further details: https://all-inkl.com/en/privacy-policy/

Data Processing
We have entered into a data processing agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law, which ensures that the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

2. General Information and Mandatory Information

Data Protection
The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various items of personal data are collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. It is not possible to guarantee complete protection of data against access by third parties.

Information on the data controller
The data controller responsible for data processing on this website is:

CASCOO Europe GmbH
Lütke Haar 15
59602 Rüthen, Germany
Tel.:+49 2952 970958-80
Fax:+49 2952 970958-29
E-Mail: info(at)feil.eu

Note on the transfer of data to third countries that are not considered safe under data protection law, and the transfer of data to US companies that are not DPF-
certified

Among other things, we use tools from companies based in third countries that do not offer an adequate level of data protection, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to these countries and processed there. We would like to point out that in third countries that do not offer an adequate level of data protection, a level of data protection comparable to that in the EU cannot be guaranteed.

We would like to point out that the USA, as a safe third country, generally offers a level of data protection comparable to that of the EU. Data transfers to the USA are therefore permitted if the recipient holds certification under the ‘EU-US Data Privacy Framework’ (DPF) or has appropriate additional safeguards in place. Information on transfers to third countries, including the recipients of the data, can be found in this privacy policy.

Recipients of personal data
As part of our business activities, we work with various external organisations. In some cases, this requires the transfer of personal data to these external organisations. We only disclose personal data to external parties where this is necessary for the performance of a contract, where we are legally obliged to do so (e.g. disclosure of data to tax authorities), where we have a legitimate interest in the disclosure pursuant to Article 6(1)(f) of the GDPR, or where another legal basis permits the disclosure of data. When using data processors, we only disclose our customers’ personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of your consent to data processing
Many data processing operations are only possible with your explicit consent. You may withdraw any consent you have already given at any time. The lawfulness of the data processing carried out prior to the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in specific cases and to direct marketing (Article 21 of the GDPR)
Where data processing is carried out on the basis of Article 6(1)(e) or (f) of the GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation; this also applies to profiling based on these provisions. The specific legal basis on which processing is carried out can be found in this privacy policy. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims (objection under Article 21(1) of the GDPR).

If your personal data is processed 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. This also applies to profiling insofar as it is related to such marketing. If you object, your personal data will no longer be used for the purposes of direct marketing (objection under Article 21(2) of the GDPR).

Right to lodge a complaint with the relevant supervisory authority
In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place where the alleged infringement occurred. This right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to data portability
You have the right to have data which we process automatically on the basis of your consent or in fulfilment of a contract provided to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place insofar as it is technically feasible.

Access, rectification and erasure
Subject to the applicable legal provisions, you have the right at any time to obtain, free of charge, information about your stored personal data, its origin and recipients, and the purpose of the data processing, and, where applicable, the right to have this data rectified or erased. You may contact us at any time regarding this matter or any other questions relating to personal data.

Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You may contact us at any time in this regard. The right to restriction of processing applies in the following cases:

If you dispute the accuracy of your personal data held by us, we generally need time to verify this. For the duration of the verification process, you have the right to request that the processing of your personal data be restricted.
If the processing of your personal data was or is unlawful, you may request that the processing be restricted instead of having the data erased.
If we no longer require your personal data, but you require it to exercise, defend or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of it being erased.
If you have lodged an objection under Article 21(1) of the GDPR, a balancing of interests between yours and ours must be carried out. Until it has been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data – apart from its storage – may only be processed with your consent, or for the purpose of establishing, exercising or defending legal claims, or to protect the rights of another natural or legal person, or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption
For security reasons and to protect the transmission of confidential content – such as orders or enquiries that you send to us as the website operator – this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address bar of your browser changes from ‘http://’ to ‘https://’ and by the padlock symbol in your browser bar.
When SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website
If, following the conclusion of a contract involving a fee, you are required to provide us with your payment details (e.g. account number for a direct debit authorisation), these details are required for payment processing.

Payment transactions using standard payment methods (Visa/MasterCard, direct debit) are carried out exclusively via an encrypted SSL or TLS connection. You can recognise an encrypted connection by the fact that the browser’s address bar changes from ‘http://’ to ‘https://’ and by the padlock icon in your browser bar.
With encrypted communication, the payment details you send to us cannot be intercepted by third parties.

Objection to promotional emails
We hereby object to the use of contact details published in accordance with the legal requirement to provide an imprint for the purpose of sending unsolicited advertising and information material. The operators of this website expressly reserve the right to take legal action in the event of the unsolicited sending of promotional information, for example via spam emails.

3. Data collection on this website

Cookies
Our website uses so-called ‘cookies’. Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser deletes them automatically.

Cookies may be set by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable certain services provided by third-party companies to be integrated into websites (e.g. cookies used to process payment services).

Cookies serve various purposes. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide specific functions you have requested (e.g. the shopping basket function) or to optimise the website (e.g. cookies for measuring website traffic) (necessary cookies), are stored on the basis of Article 6(1)(f) of the GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies to ensure the technically fault-free and optimised provision of its services. Where consent has been sought for the storage of cookies and similar recognition technologies, processing takes place exclusively on the basis of this consent (Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG); consent may be withdrawn at any time.

You can configure your browser so that you are notified when cookies are set and can choose to allow cookies only on a case-by-case basis, block cookies in specific cases or generally, and enable the automatic deletion of cookies when you close your browser. If you disable cookies, the functionality of this website may be restricted.

You can find out which cookies and services are used on this website in this privacy policy.

Consent via the JTL Shop Standard Tool
Our website uses JTL Shop’s consent technology to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies, and to document this in accordance with data protection regulations. The provider of this technology is:

JTL-Software-GmbH
Rheinstr. 7
41836 Hückelhoven

When you visit our website, a connection is established with our servers to obtain your consents and other declarations regarding the use of cookies. JTL then stores a cookie in your browser so that it can associate the consents you have given – or any withdrawal thereof – with you. The data collected in this way is stored until you request its deletion, delete the cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.
This is used to obtain the legally required consents for the use of cookies. The legal basis for this is Article 6(1)(c) of the GDPR.

Data processing on behalf of a controller
We have entered into a data processing agreement (DPA) for the use of the aforementioned service. This is a contract required under data protection law, which ensures that the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Server log files
The website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and version
Operating system used
Referrer URL
Hostname of the accessing computer
Time of the server request
IP address
This data is not combined with other data sources.

The collection of this data is based on Article 6(1)(f) of the GDPR. The website operator has a legitimate interest in ensuring the technically error-free display and optimisation of its website – to this end, the server log files must be collected.

Contact form
If you send us enquiries via the contact form, the details you provide in the enquiry form – including the contact details you enter there – will be stored by us for the purpose of processing your enquiry and in the event of any follow-up questions. We will not pass on this data without your consent.

The processing of this data is based on Article 6(1)(b) of the GDPR, provided that your enquiry relates to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR), provided that consent has been sought; consent may be withdrawn at any time.

The data you enter in the contact form will be retained by us until you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your enquiry has been fully processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

Enquiries by email, telephone or fax
If you contact us by email, telephone or fax, your enquiry – including any personal data it contains (name, enquiry) – will be stored and processed by us for the purpose of dealing with your request. We will not pass on this data without your consent.

The data you send to us via contact enquiries will be retained by us until you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your enquiry has been fully processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.

4. Social media
We maintain publicly accessible profiles on social media platforms. You can find a list of the specific social media platforms we use below.
Social media platforms such as Facebook, X, etc. are generally able to analyse your user behaviour in detail when you visit their website or a website featuring integrated social media content (e.g. ‘Like’ buttons or advertising banners). Visiting our social media pages triggers numerous data-processing operations relevant to data protection.

Specifically:
If you are logged into your social media account and visit our social media page, the operator of the social media portal may associate this visit with your user account. However, your personal data may also be collected even if you are not logged in or do not have an account with the relevant social media portal. In this case, data is collected, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of social media platforms can create user profiles that record your preferences and interests. This enables interest-based advertising to be displayed to you both on and off the respective social media platform. If you have an account with the relevant social network, interest-based advertising may be displayed on all devices on which you are currently logged in or have previously been logged in. Please also note that we are not able to track all data processing activities on social media platforms. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media platforms. For further details, please refer to the terms of use and privacy policies of the respective social media platforms.

Legal basis
Our social media accounts are intended to ensure the most comprehensive online presence possible. This constitutes a legitimate interest within the meaning of Article 6(1)(f) of the GDPR. The analytics processes initiated by the social networks may be based on different legal grounds, which must be specified by the operators of the social networks (e.g. consent within the meaning of Article 6(1)(a) of the GDPR).

Data controller and exercising your rights
When you visit one of our social media pages (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered by that visit. You may, in principle, exercise your rights (right of access, rectification, erasure, restriction of processing, data portability and the right to lodge a complaint) both against us and against the operator of the relevant social media portal (e.g. against Facebook).
Please note that, despite our joint responsibility with the social media platform operators, we do not have full control over the data processing operations carried out by the social media platforms. Our options depend largely on the corporate policy of the respective provider.

Retention period
Data collected directly by us via our social media presence will be deleted from our systems as soon as you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory legal provisions – in particular retention periods – remain unaffected.

We have no influence over the retention period of your data stored by the operators of social networks for their own purposes. For further details, please contact the operators of the social networks directly (e.g. in their privacy policy, see below).

Facebook
We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter ‘Meta’). According to Meta, the data collected is also transferred to the USA and other third countries.
We have entered into a joint processing agreement (Controller Addendum) with Meta. This agreement sets out which data processing operations we and Meta are responsible for when you visit our Facebook page. You can view this agreement via the following link: https://www.facebook.com/legal/terms/page_controller_addendum.

You can adjust your advertising settings yourself in your user account. To do so, click on the following link and log in: https://www.facebook.com/settings?tab=ads.

Data transfers to the USA are based on the EU Commission’s Standard Contractual Clauses. Further details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://en-gb.facebook.com/help/566994660333381.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/4452 Instagram We have a profile on

Instagram
The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Data transfers to the USA are based on the European Commission’s Standard Contractual Clauses. You can find details here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://en-gb.facebook.com/help/566994660333381.

For details on how Instagram handles your personal data, please refer to Instagram’s privacy policy: https://privacycenter.instagram.com/policy/. The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the US designed to ensure compliance with European data protection standards when data is processed in the US. Every company certified under the DPF undertakes to comply with these data protection standards.

Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/4452

LinkedIn
We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.
If you wish to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Data transfers to the USA are based on the EU Commission’s Standard Contractual Clauses. Further details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

For details on how LinkedIn handles your personal data, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the US designed to ensure compliance with European data protection standards when data is processed in the US. Every company certified under the DPF undertakes to comply with these data protection standards.

Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/5448

YouTube
We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For details on how they handle your personal data, please refer to YouTube’s privacy policy: https://policies.google.com/privacy?hl=de.

Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/5780

Xing
We have a profile on Xing. The provider is New Work SE, Baumwall 7, 20459 Hamburg, Germany. For details on how they handle your personal data, please refer to Xing’s privacy policy: https://privacy.xing.com/en/privacy-policy

5. Analytics tools and advertising

Google Tag Manager
We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Tag Manager is a tool that enables us to integrate tracking or analytics tools and other technologies into our website. Google Tag Manager itself does not create user profiles, store cookies or carry out independent analyses. It serves solely to manage and deploy the tools integrated via it. However, Google Tag Manager records your IP address, which may also be transferred to Google’s parent company in the United States.

The use of Google Tag Manager is based on Article 6(1)(f) of the GDPR. The website operator has a legitimate interest in the quick and straightforward integration and management of various tools on its website. Where consent has been sought, processing takes place exclusively on the basis of Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be withdrawn at any time.

Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Analytics
This website uses features of the web analytics service Google Analytics. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, time spent on the site, operating systems used and the user’s location. This data is aggregated into a user ID and assigned to the website visitor’s respective device.

Furthermore, we can use Google Analytics to record, amongst other things, your mouse and scroll movements and clicks. Google Analytics also uses various modelling approaches to supplement the data sets collected and employs machine learning technologies in its data analysis.
Google Analytics uses technologies that enable user recognition for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google regarding the use of this website is generally transmitted to a Google server in the USA and stored there.

The use of this service is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG. You may withdraw your consent at any time.
The transfer of data to the USA is based on the European Commission’s Standard Contractual Clauses. Further details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

The company holds certification under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards when data is processed in the USA. Every organisation certified under the DPF undertakes to comply with these data protection standards. Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/5780.

IP anonymisation
Google Analytics IP anonymisation is enabled. This means that your IP address is truncated by Google within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data held by Google.

Google Static
This website uses the functions of Google Static. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland. Google Static enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, time spent on the site, operating systems used and the user’s origin. This data is aggregated into a user ID and assigned to the website visitor’s respective device. Furthermore, we can use Google Analytics to record, amongst other things, your mouse and scroll movements and clicks.

Furthermore, Google Analytics uses various modelling approaches to supplement the data sets collected and employs machine learning technologies in its data analysis.
If you have a Google account, you can opt out of personalised advertising via the following link: https://adssettings.google.com/anonymous?hl=de.

Use of this service is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG. You may withdraw your consent at any time.
Further information and the data protection provisions can be found in Google’s privacy policy at: https://policies.google.com/technologies/ads?hl=de.
The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards when data is processed in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this is available from the provider via the following link: https://www.dataprivacyframework.gov/participant/5780.

6. Our own services

Handling of applicant data
We offer you the opportunity to apply for a job with us (e.g. by email, post or via the online application form). Below, we provide information on the scope, purpose and use of your personal data collected as part of the application process. We assure you that the collection, processing and use of your data will be carried out in accordance with applicable data protection legislation and all other legal provisions, and that your data will be treated in strict confidence.

Scope and purpose of data collection
When you submit an application to us, we process your associated personal data (e.g. contact and communication details, application documents, notes taken during interviews, etc.) to the extent necessary to decide whether to enter into an employment relationship. The legal basis for this is Section 26 of the German Federal Data Protection Act (BDSG) (initiation of an employment relationship), Article 6(1)(b) of the General Data Protection Regulation (GDPR) (general pre-contractual measures) and – provided you have given your consent – Article 6(1)(a) of the GDPR. Consent may be withdrawn at any time. Your personal data will be disclosed within our company exclusively to those persons involved in processing your application.

If your application is successful, the data you have submitted will be stored in our data processing systems on the basis of Section 26 of the BDSG and Article 6(1)(b) of the GDPR for the purpose of carrying out the employment relationship.

Data retention period
If we are unable to offer you a job, if you decline a job offer or if you withdraw your application, we reserve the right to retain the data you have provided on the basis of our legitimate interests (Article 6(1)(f) of the GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The retention of data serves, in particular, as evidence in the event of a legal dispute. If it becomes apparent that the data will be required after the expiry of the six-month period (e.g. due to an impending or pending legal dispute), the data will not be deleted until the purpose for its continued retention no longer applies.

Data may also be retained for a longer period if you have given your consent (Article 6(1)(a) of the GDPR) or if statutory retention obligations prevent deletion.

Inclusion in the candidate pool
If we do not make you a job offer, there may be the option of adding you to our candidate pool. Should you be included, all documents and details from your application will be transferred to the candidate pool so that we can contact you should suitable vacancies arise.
Inclusion in the candidate pool is based solely on your explicit consent (Article 6(1)(a) of the GDPR). Giving your consent is voluntary and is not linked to the current recruitment process. The data subject may withdraw their consent at any time. In this case, the data in the candidate pool will be irrevocably deleted, provided there are no legal grounds for retention. The data in the candidate pool will be irrevocably deleted no later than two years after consent is given.