DATA PROTECTION
1. Privacy at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data refers to any data that can be used to personally identify you. For detailed information on data protection, please refer to our Privacy Policy, which is listed below this text.
Data Collection on This Website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find the operator’s contact information in the “Information on the Data Controller” section of this Privacy Policy.
How do we collect your data?
Your data is collected, in part, when you provide it to us. This may include, for example, data that you enter into a contact form.
Other data is collected by our IT systems automatically or with your consent when you visit the website. This primarily consists of technical data (e.g., internet browser, operating system, or time of page view). This data is collected automatically as soon as you access this website.
What do we use your data for?
Some of the data is collected to ensure that the website functions properly. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right at any time to receive, free of charge, information about the source, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you may revoke that consent at any time with future effect. In addition, you have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to file a complaint with the competent supervisory authority.
Please feel free to contact us at any time regarding this matter or any other questions you may have about data protection.
Analytics Tools and Third-Party Tools
When you visit this website, your browsing behavior may be analyzed for statistical purposes. This is primarily done using so-called analytics tools.
You can find detailed information about these analytics programs in the following privacy policy.
2. Hosting
We host our website’s content with the following provider:
All-Inclusive
The provider is ALL-INKL.COM – Neue Medien Münnich, owned by René Münnich, Hauptstraße 68, 02742 Friedersdorf (hereinafter “All-Inkl”). For details, please refer to All-Inkl’s Privacy Policy: https://all-inkl.com/datenschutzinformationen/.
The use of All-Inkl is based on Article 6(1)(f) of the GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. If consent has been requested, processing is carried out 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 revoked at any time.
3. General Information and Mandatory Disclosures
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 applicable data protection laws and this Privacy Policy.
When you use this website, various types of personal data are collected. Personal data is information that can be used to identify you personally. This Privacy Policy explains what data we collect and how we use it. It also explains how and for what purpose this is done.
Please note that data transmission over the Internet (e.g., when communicating via email) may be subject to security risks. It is not possible to completely protect data from access by third parties.
Note on the Data Controller
The entity responsible for data processing on this website is:
VOMO Leichtbautechnik GmbH & Co KG
Borghorster Straße 48a
48366 Laer
Phone: 02554 – 9407800
Email: info@vomo-leichtbautechnik.de
The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g., names, email addresses, etc.).
Retention period
Unless a more specific retention period is stated in this Privacy Policy, we will retain your personal data until the purpose for which it was collected no longer applies. If you submit a valid request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted once these grounds no longer apply.
General Information on the Legal Basis for Data Processing on This Website
If you have consented to the processing of your data, we process your personal data on the basis of Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, provided that special categories of data pursuant to Art. 9(1) GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g., via device fingerprinting), data processing is additionally carried out on the basis of Section 25(1) TDDDG. Consent may be revoked at any time. If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Article 6(1)(b) of the GDPR. Furthermore, we process your data to the extent that it is necessary to fulfill a legal obligation on the basis of Article 6(1)(c) of the GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Article 6(1)(f) of the GDPR. The legal bases applicable in each individual case are described in the following sections of this Privacy Policy.
Recipients of personal data
As part of our business operations, we collaborate with various external parties. In some cases, this requires the transfer of personal data to these external parties. We only disclose personal data to external parties if it is necessary for the performance of a contract, if we are legally required to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Article 6(1)(f) of the GDPR, or if 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 (Art. 21 GDPR)
IF DATA PROCESSING IS BASED ON ART. 6, PAR. 1, SUBPAR. E OR F OF THE GDPR, YOU HAVE THE RIGHT AT ANY TIME, FOR REASONS RELATED TO YOUR SPECIFIC SITUATION, to object to the processing of your personal data; this also applies to profiling based on these provisions. THE SPECIFIC LEGAL BASIS ON WHICH PROCESSING IS BASED 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 THAT OUTWEIGH YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) OF THE GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING, TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) OF THE GDPR).
Right to File a Complaint with the Competent Supervisory Authority
In the event of violations 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 violation 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 receive data that we process automatically based on your consent or in fulfillment of a contract, either for yourself or for 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 be done to the extent that it is technically feasible.
Access, Correction, and Deletion
Under applicable law, you have the right at any time to receive, free of charge, information about your stored personal data, its source and recipients, and the purpose of the data processing, as well as the right to have this data corrected or deleted, if applicable. You may contact us at any time regarding this matter or any other questions you may have about personal data.
Right to Restriction of Processing
You have the right to request that the processing of your personal data be restricted. You may contact us at any time to exercise this right. The right to restriction of processing applies in the following cases:
- If you dispute the accuracy of your personal data stored 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 need your personal data, but you need 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 being erased.
- If you have filed an objection under Article 21(1) of the GDPR, a balancing of your interests against ours must be conducted. Until it is determined whose interests prevail, you have the right to request that the processing of your personal data be restricted.
If you have restricted the processing of your personal data, such data may—apart from its storage—be processed only with your consent or for the purpose of asserting, exercise, or defend legal claims, or to protect the rights of another natural or legal person, or for reasons of a substantial public interest of the European Union or a Member State.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential information—such as orders or inquiries you send to us as the website operator—this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the lock icon in your browser’s address bar.
If SSL or TLS encryption is enabled, the data you send to us cannot be intercepted by third parties.
4. Data Collection on This Website
Cookies
Our website uses so-called “cookies.” Cookies are small data packets that 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 (persistent 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 the integration of certain third-party services into websites (e.g., cookies used to process payment services).
Cookies serve various purposes. Many cookies are technically necessary, as certain website features would not work without them (e.g., the shopping cart feature or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.
Cookies that are necessary for carrying out the electronic communication process, for providing certain functions you have requested (e.g., the shopping cart function), or for optimizing the website (e.g., cookies for measuring web traffic) (necessary cookies), are stored on the basis of Art. 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 flawless and optimized provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG); consent may be revoked at any time.
You can configure your browser to notify you when cookies are set, to allow cookies only on a case-by-case basis, to block cookies in specific cases or generally, and to enable the automatic deletion of cookies when you close your browser. If you disable cookies, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this Privacy Policy.
Consent to Borlabs’ Use of Cookies
Our website uses Borlabs Cookie’s consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies, and to document this in compliance with data protection regulations. This technology is provided by Borlabs GmbH, Rübenkamp 32, 22305 Hamburg (hereinafter “Borlabs”).
When you visit our website, a Borlabs cookie is stored in your browser to record the consents you have given or any revocation of those consents. This data is not shared with the provider of the Borlabs cookie.
The collected data will be stored until you request that we delete it, delete the Borlabs cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. For details on how Borlabs handles data processing, please visit https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.
Borlabs’ cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Article 6(1)(c) of the GDPR.
Server Log Files
The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These include:
- Browser Type and Browser Version
- Operating system used
- Referrer URL
- Hostname of the connecting computer
- Time of the server request
- IP address
This data is not combined with data from other sources.
This data is collected on the basis of Article 6(1)(f) of the GDPR. The website operator has a legitimate interest in ensuring that its website functions properly and is optimized—to this end, server log files must be collected.
Contact form
If you submit inquiries to us via the contact form, we will store the information you provide in the inquiry form—including the contact information you provide there—for the purpose of processing your inquiry and in case of follow-up questions. We will not share this information without your consent.
The processing of this data is based on Article 6(1)(b) of the GDPR, provided that your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of inquiries directed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR), provided that such consent was requested; you may withdraw your consent at any time.
The data you enter in the contact form will remain with us until you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g., after your inquiry has been processed). Mandatory legal provisions—in particular retention periods—remain unaffected.
Inquiries by email, phone, or fax
If you contact us by email, phone, or fax, your inquiry—including all personal data contained therein (name, inquiry)—will be stored and processed by us for the purpose of handling your request. We will not disclose this data without your consent.
The processing of this data is based on Article 6(1)(b) of the GDPR, provided that your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of inquiries directed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR), provided that such consent was requested; you may withdraw your consent at any time.
The data you send us via contact requests will remain with us until you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular statutory retention periods—remain unaffected.
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 allows us to integrate tracking and analytics tools, as well as other technologies, into our website. Google Tag Manager itself does not create user profiles, store cookies, or perform any independent analysis. It is used solely to manage and deploy the tools integrated through it. However, Google Tag Manager does collect 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. If consent has been requested, processing is carried out 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 revoked at any time.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when processing data in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information, please visit the provider’s website at 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 website operators to analyze the behavior 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.
In addition, we can use Google Analytics to track, among other things, your mouse and scroll movements and clicks. Google Analytics also uses various modeling approaches to supplement the collected data sets and employs machine learning technologies in its data analysis.
Google Analytics uses technologies that enable user recognition for the purpose of analyzing user behavior (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 United States and stored there.
Use of this service is based on your consent pursuant to Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG. You may withdraw your consent at any time.
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. For details, please visit: https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information, please visit the provider’s website at the following link: https://www.dataprivacyframework.gov/participant/5780.
IP Anonymization
Google Analytics IP anonymization is enabled. This means that Google truncates your IP address within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before it is transmitted to the United States. Only in exceptional cases is the full IP address transmitted to a Google server in the United States 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 other services related to website and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google.
Browser Plugin
You can prevent Google from collecting and processing your data by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information on how Google Analytics handles user data, please see Google’s Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=de.
Google Signals
We use Google Signals. When you visit our website, Google Analytics collects, among other things, your location, search history, and YouTube history, as well as demographic data (visitor data). This data may be used for personalized advertising through Google Signals. If you have a Google Account, the visitor data from Google Signals is linked to your Google Account and used for personalized advertising. The data is also used to generate anonymized statistics on our users’ behavior.
Order Processing
We have entered into a data processing agreement with Google and fully comply with the strict requirements of the German data protection authorities regarding the use of Google Analytics.
Google Ads
The website operator uses Google Ads. Google Ads is an online advertising program provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads allows us to display ads in the Google search engine or on third-party websites when users enter specific search terms into Google (keyword targeting). Furthermore, targeted ads can be displayed based on user data available to Google (e.g., location data and interests) (audience targeting). As website operators, we can quantitatively evaluate this data by, for example, analyzing which search terms led to the display of our ads and how many ads resulted in corresponding clicks.
Use of this service is based on your consent pursuant to Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG. You may withdraw your consent at any time.
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. For details, see here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information, please visit the provider’s website at the following link: https://www.dataprivacyframework.gov/participant/5780.
Meta Pixel (formerly Facebook Pixel)
This website uses Facebook/Meta’s visitor action pixels to measure conversions. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also transferred to the United States and other third countries.
This allows the provider to track the behavior of website visitors after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables the provider to evaluate the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.
The data collected is anonymous to us as the operators of this website; we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, allowing it to be linked to the respective user profile and enabling Facebook to use the data for its own advertising purposes, in accordance with Facebook’s Data Use Policy (https://de-de.facebook.com/about/privacy/). This enables Facebook to display advertisements both on Facebook and outside of Facebook. As the site operator, we have no control over this use of the data.
Use of this service is based on your consent pursuant to Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG. You may withdraw your consent at any time.
We use the advanced alignment feature within Meta-Pixel.
Extended Matching allows us to send various types of data (e.g., city, state, ZIP code, hashed email addresses, names, gender, date of birth, or phone number) about our customers and prospects—which we collect through our website—to Meta (Facebook). By enabling this feature, we can tailor our advertising campaigns on Facebook even more precisely to people who are interested in our offerings. In addition, enhanced matching improves the attribution of website conversions and expands Custom Audiences.
To the extent that personal data is collected on our website using the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). This joint responsibility is limited exclusively to the collection of the data and its transfer to Facebook. The processing carried out by Facebook after the transfer is not part of the joint responsibility. The obligations incumbent upon us jointly have been set forth in a joint processing agreement. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing privacy notices when using the Facebook tool and for ensuring the tool is implemented on our website in compliance with data protection laws. Facebook is responsible for the data security of Facebook products. You can exercise your data subject rights (e.g., requests for information) regarding the data processed by Facebook directly with Facebook. If you exercise your data subject rights with us, we are obligated to forward these requests to Facebook.
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. For details, see here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.
You can find more information about protecting your privacy in Facebook’s Privacy Policy: https://de-de.facebook.com/about/privacy/.
You can also disable the “Custom Audiences” remarketing feature in the Ad Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
If you do not have a Facebook account, you can opt out of Facebook’s interest-based advertising on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information, please visit the provider’s website at the following link: https://www.dataprivacyframework.gov/participant/4452.
6. Our Own Services
Handling of Applicant Data
We offer you the opportunity to apply for a position with us (e.g., by email, mail, or via our online application form). Below, we provide information about 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 are carried out in accordance with applicable data protection laws and all other legal requirements, and that your data will be treated as strictly confidential.
Scope and Purpose of Data Collection
If you submit an application to us, we will process your related personal data (e.g., contact and communication information, application documents, notes taken during job interviews, etc.) to the extent necessary to decide whether to establish an employment relationship. The legal basis for this is Section 26 of the German Federal Data Protection Act (BDSG) under German law (initiation of an employment relationship), Article 6(1)(b) of the GDPR (general contract initiation), and—if you have provided consent—Article 6(1)(a) of the GDPR. You may withdraw your consent at any time. Your personal data will be shared within our company exclusively with those individuals involved in processing your application.
If your application is successful, the data you submitted will be stored in our data processing systems in accordance with Section 26 of the German Federal Data Protection Act (BDSG) and Article 6(1)(b) of the General Data Protection Regulation (GDPR) for the purpose of carrying out the employment relationship.
Data Retention Period
If we are unable to offer you a position, if you decline a job offer, or if you withdraw your application, we reserve the right to retain the data you have provided, based on our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the conclusion of the application process (rejection or withdrawal of the application). Afterward, the data will be deleted and the physical application documents will be destroyed. Retention serves, in particular, as evidence in the event of a legal dispute. If it becomes apparent that the data will be required after the 6-month period has expired (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 provided the appropriate consent (Art. 6(1)(a) of the GDPR) or if statutory retention requirements prevent its deletion.
Inclusion in the candidate pool
If we do not offer you a position, we may add you to our applicant pool. If you are added to the pool, all documents and information from your application will be transferred to the applicant pool so that we can contact you if suitable openings arise.
Inclusion in the applicant pool is based solely on your explicit consent (Art. 6(1)(a) of the GDPR). Providing consent is voluntary and has no bearing on the ongoing application process. The data subject may withdraw their consent at any time. In this case, the data will be permanently deleted from the applicant pool, unless there are legal grounds for retaining it.
Data from the applicant pool will be permanently deleted no later than two years after consent is granted.