Preamble
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).
The terms used are not gender-specific.
Last updated: April 24, 2026
Table of Contents
- Preamble
- Controller
- Overview of Processing Activities
- Applicable Legal Bases
- Security Measures
- Transmission of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of Data Subjects
- Business Services
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Contact and Inquiry Management
- Newsletters and Electronic Notifications
- Web Analytics, Monitoring and Optimisation
- Presences on Social Networks (Social Media)
- Plug-ins and Embedded Functions and Content
- Amendment and Update
- Definitions
Controller
First name, Last name / Company
Street, House No.
Postal Code, City, Country
Email address: firstname.lastname@example.eu
Overview of Processing Activities
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of Data Processed
- Master data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Prospective customers.
- Communication partners.
- Users.
- Business and contractual partners.
Purposes of Processing
- Provision of contractual services and fulfilment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Office and organisational procedures.
- Organisational and administrative procedures.
- Feedback.
- Profiles with user-related information.
- Provision of our online offering and user experience.
- Information technology infrastructure.
- Public relations.
- Business processes and operational procedures.
Applicable Legal Bases
Applicable legal bases under the GDPR: The following provides an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also be applicable in individual cases, we will inform you of these in this privacy policy.
- Consent (Art. 6 para. 1 s. 1 lit. a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 s. 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and automated individual decision-making including profiling. The data protection laws of individual German federal states may also apply.
Security Measures
We implement appropriate technical and organisational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access to, input of, disclosure of, ensuring availability of, and separation of such data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and responses to data breaches. We also take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of privacy by design and by default.
Securing online connections via TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and more secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.
Transmission of Personal Data
In the course of our processing of personal data, it may be transmitted to or disclosed to other entities, companies, legally independent organisational units or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
International Data Transfers
Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, entities or companies (which is identifiable by the respective provider’s postal address or if the privacy policy expressly refers to data transfers to third countries), this is always done in accordance with legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission on 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.
This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses will serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.
For individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, corresponding safeguards apply, in particular Standard Contractual Clauses, explicit consent or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be obtained from the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or no further legal grounds for processing exist. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule apply where statutory obligations or special interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the pursuit of legal claims or for the protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.
Where multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always applies. Data that is no longer retained for its originally intended purpose but is kept due to legal requirements or other reasons is processed exclusively for the reasons justifying its retention.
Retention and deletion of data: The following general retention and archiving periods apply under German law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organisational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
- 8 years – Accounting vouchers, such as invoices and expense receipts (§ 147 para. 1 nos. 4 and 4a in conjunction with para. 3 s. 1 AO, and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
- 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are of significance for taxation purposes, e.g. hourly wage slips, operational accounting sheets, calculation documents, price tags, as well as payroll accounting documents insofar as they are not already accounting vouchers and cash register rolls (§ 147 para. 1 nos. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 nos. 2 and 3 in conjunction with para. 4 HGB).
- 3 years – Data required to take into account potential warranty and compensation claims or similar contractual claims and rights, and to process related inquiries, based on past business experience and common industry practices, is stored for the duration of the standard statutory limitation period of three years (§§ 195, 199 BGB).
Period commences at the end of the year: Where a period does not expressly start on a specific date and is at least one year in length, it automatically begins at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in the context of which data is stored, the triggering event is the point in time at which the termination or other ending of the legal relationship becomes effective.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 para. 1 lit. e or f GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and to access such data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively to request restriction of the processing of the data in accordance with legal requirements.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.
Business Services
We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively referred to as “contractual partners”), for the purpose of initiating, performing and executing contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken at request, as well as communication in connection with the respective contractual relationship.
The processing serves in particular the fulfilment of our primary and ancillary contractual obligations. These include the provision of agreed services, any update and information obligations, the handling of warranty claims and other service disruptions, the processing of cancellations, terminations of continuing obligations, reversals, refunds and the handling of other contract-related declarations and inquiries. Both one-off contracts and ongoing contractual relationships are covered.
Data processed includes in particular master data such as name, address and, where applicable, company name, contact data such as email address and telephone number, contract and service data such as the subject matter of the contract, contract duration, order or reference number, usage and service data, payment and billing data, as well as communication content and histories. Where necessary, we also process data disclosed or provided to us in the course of carrying out an order.
In addition, we process the data to safeguard our rights and to fulfil legal obligations. This includes in particular commercial and tax retention obligations, documentation obligations and, where applicable, proof and accountability obligations. We also process data on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, and in protecting our business operations and contractual partners against misuse, threats to data, trade secrets and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other auxiliary persons, insofar as this is necessary for the performance of the contract or the fulfilment of statutory obligations.
Personal data is only passed on to third parties insofar as this is necessary for the performance of the contract, the implementation of pre-contractual measures, the safeguarding of legitimate interests or the fulfilment of statutory obligations. We provide separate information on any processing beyond this, in particular for marketing purposes, within the framework of this privacy policy.
We inform contractual partners which data is required in individual cases during data collection, for example in online forms by means of appropriate labelling or in personal contact.
Data is deleted once it is no longer required for the aforementioned purposes and no statutory retention obligations preclude deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in connection with a specific order is deleted after completion of the order and expiry of any applicable retention periods, unless there are further statutory or contractual storage obligations.
The legal basis for processing is Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures and the performance of the respective contractual relationship, and Art. 6 para. 1 lit. c GDPR for compliance with legal obligations. Where processing is based on legitimate interests, it is carried out on the basis of Art. 6 para. 1 lit. f GDPR, namely to safeguard our legitimate interests in proper and efficient business organisation, internal administration and documentation of business transactions, the assertion and defence of legal claims, ensuring IT and data security, prevention of misuse and fraud, and the economic management and further development of our business operations.
- Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; prospective customers. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures. Business processes and operational procedures.
- Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR); legal obligation (Art. 6 para. 1 s. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
Provision of the Online Offering and Web Hosting
We process users’ data in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.
- Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user experience; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
Further information on processing activities, procedures and services:
- Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web host”); Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files retrieved, the date and time of retrieval, the volume of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the load and stability of the servers; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidentiary purposes is exempted from deletion until the respective incident has been finally clarified.
Use of Cookies
The term “cookies” refers to functions that store and read information on users’ devices. Cookies can also be used for different purposes, such as to ensure the functionality, security and convenience of online offerings and to create analyses of visitor flows. We use cookies in accordance with statutory regulations. Where necessary, we obtain users’ prior consent. If consent is not required, we rely on our legitimate interests. This applies where storing and reading information is essential in order to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent may be withdrawn at any time. We provide clear information about the scope of consent and which cookies are used.
Notes on data protection legal bases: Whether we process personal data using cookies depends on whether consent has been given. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as explained above in this section and in the context of the respective services and procedures.
Storage duration: With regard to storage duration, the following types of cookies are distinguished:
- Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, login status can be saved and preferred content can be displayed directly when the user revisits a website. Similarly, user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period may be up to two years.
General information on withdrawal and objection (opt-out): Users may withdraw the consents they have given at any time and may also object to processing in accordance with statutory regulations, including by means of the privacy settings of their browser.
- Types of data processed: Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR). Consent (Art. 6 para. 1 s. 1 lit. a) GDPR).
Further information on processing activities, procedures and services:
- Processing of cookie data on the basis of consent: We use a consent management solution through which users’ consent is obtained for the use of cookies or for the procedures and providers referred to in the consent management solution. This procedure is used to obtain, log, manage and withdraw consents, in particular with regard to the use of cookies and comparable technologies used to store, read and process information on users’ devices. In the context of this procedure, users’ consents are obtained for the use of cookies and the associated processing of information, including the specific processing activities and providers named in the consent management procedure. Users also have the option of managing and withdrawing their consents. Consent declarations are stored in order to avoid having to ask again and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies, in order to be able to assign consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: The duration of storage of consent is up to two years. A pseudonymous user identifier is created and stored together with the time of consent, the details of the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, system and device used; Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR).
Contact and Inquiry Management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the information provided by the enquiring persons is processed insofar as this is necessary to respond to the contact enquiries and any requested measures.
- Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions and information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offering and user experience.
- Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR).
Further information on processing activities, procedures and services:
- Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us in order to respond to and handle the respective enquiry. This generally includes details such as name, contact information and, where applicable, further information communicated to us that is necessary for appropriate handling. We use this data exclusively for the stated purpose of making contact and communicating; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
Newsletters and Electronic Notifications
We send newsletters, emails and other electronic notifications (hereinafter “newsletters”) exclusively with the consent of the recipients or on a statutory basis. Where the contents of a newsletter are specifically described in the course of registration, they are decisive for users’ consent. To subscribe to our newsletter, it is normally sufficient to provide your email address. To offer you a personalised service, however, we may ask for your name for a personal salutation in the newsletter, or for additional information if this is necessary for the purposes of the newsletter.
Deletion and restriction of processing: We may retain unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to provide evidence of previously given consent. The processing of this data is restricted to the purpose of potential defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The registration process is logged on the basis of our legitimate interests for the purpose of demonstrating that it has been carried out properly. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Direct marketing (e.g. by email or by post).
- Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR).
- Right to object (opt-out): You may cancel your subscription to our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you may use one of the contact options listed above, preferably email.
Further information on processing activities, procedures and services:
- Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file which is retrieved from our server, or that of our mailing service provider if we use one, when the newsletter is opened. In the course of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter on the basis of technical data or the target groups and their reading behaviour based on their retrieval locations (which – This text section must be unlocked with a premium licence. –; Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR).
Web Analytics, Monitoring and Optimisation
Web analytics (also referred to as “reach measurement”) serves to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. By means of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used, or are used repeatedly. We can also identify which areas need optimisation.
In addition to web analytics, we may also use testing procedures to test, for example, different versions of our online offering or its components in order to optimise them.
Unless stated otherwise below, profiles — i.e. data aggregated into a single usage process — may be created for these purposes and information may be stored in and read from a browser or device. The information collected includes in particular websites visited and elements used thereon, as well as technical information such as the browser used, the computer system used and information on usage times. Where users have consented to the collection of their location data from us or from the providers of services we use, location data may also be processed.
Furthermore, users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user experience.
- Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of up to two years).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
Further information on processing activities, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analytical information to a device in order to identify which content users have accessed within one or more usage sessions, which search terms they have used, whether they have accessed it again, or have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users that refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. Analytics does, however, provide approximate geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, sub-continent (and ID-based counterparts). For EU traffic, IP address data is used solely for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible and is not used for any further purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
Presences on Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We draw attention to the fact that user data may be processed outside the European Union in this context. This may entail risks for users, as it could, for example, make it more difficult to enforce users’ rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles may be created based on users’ usage behaviour and the interests derived therefrom. These profiles may in turn be used to place advertisements inside and outside the networks that are presumed to match users’ interests. For this purpose, cookies are generally stored on users’ computers, in which users’ usage behaviour and interests are stored. In addition, data may also be stored in users’ profiles regardless of the devices they use (particularly if they are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing forms and opt-out options, we refer you to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we also point out that these can most effectively be asserted with the providers. Only the latter have access to users’ data and can take appropriate measures and provide information directly. If you still need assistance, please do not hesitate to contact us.
- Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions and information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; feedback (e.g. collecting feedback via online form). Public relations.
- Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
Further information on processing activities, procedures and services:
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors that is used to create “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, and the actions they take. It also includes details about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from users’ profiles, such as job function, country, industry, seniority level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy.
We have concluded a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular specifies the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users may, for example, send requests for access or deletion directly to LinkedIn). The rights of users (in particular the right to access, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Plug-ins and Embedded Functions and Content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).
The integration always requires the third-party providers of this content to process users’ IP addresses, as without the IP address they would not be able to send the content to users’ browsers. The IP address is therefore necessary for the display of this content or functions. We endeavour to only use content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may furthermore be stored in cookies on users’ devices and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other details about the use of our online offering, but may also be linked to such information from other sources.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is the permission given. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user experience.
- Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of up to two years).
- Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).
Further information on processing activities, procedures and services:
- Google Fonts (retrieved from Google server): Retrieval of fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with Google Fonts’ Cascading Style Sheets (CSS) and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on Google’s server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the particular browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics measuring the popularity of font families. These aggregated usage statistics are published on Google Fonts’ “Analytics” page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertising; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=en.
Amendment and Update
We ask you to regularly review the content of our privacy policy. We update the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g. consent) or any other individual notification.
Where we provide addresses and contact information of companies and organisations in this privacy policy, please be aware that addresses may change over time and we ask you to verify the details before making contact.
Definitions
This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.
- Master data: Master data comprises essential information required for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions or systems by enabling clear assignment and communication.
- Content data: Content data comprises information generated in the course of creating, editing and publishing content of all types. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates.
- Contact data: Contact data is essential information that enables communication with individuals or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
- Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the manner in which data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It may include information about file size, creation date, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission routes. Procedural data describes the processes and procedures within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and verifying operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which functions they prefer, how long they spend on certain pages and what paths they take through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data which consists of using such personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) to analyse, evaluate or predict them (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
- Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for the analysis of system problems, security monitoring or the creation of performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include the behaviour or interests of visitors in certain information, such as the content of web pages. Using reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them to better tailor the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes in order to recognise returning visitors and to obtain more precise analyses of the use of an online offering.
- Controller: The “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, analysis, storage, transmission or deletion.
- Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the nature of the agreed services or products, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
- Payment data: Payment data encompasses all information required to process payment transactions between buyers and sellers. This data is of critical importance for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank account details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorisations and fees.
Created with the free privacy policy generator by Dr. Thomas Schwenke