Privacy Policy
Preamble
With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as «data») we process for which purposes and in which scope. The privacy statement 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 «online services»).
The terms used are not gender-specific.
Last Update: 1. July 2024
Table of Contents
Controller
Raan GmbH
Unterm Damel 17
35745 Herborn
Germany
Authorised Representatives: Raffael A. Fruscio, Andrea Fruscio
E-Mail Address:
marketing@raan-group.com
Legal Notice:
https://circular-pro.com/imprint/
Contact details of the data protection officer (Art. 13 para. 1 lit. b) GDPR): A data protection officer has been appointed.
The contact email is data.de@raan-group.com
Overview of processing operations
The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.
Categories of Processed Data
- Inventory data.
- Payment Data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Images and/ or video recordings.
- Audio recordings.
- Contact Information (Facebook).
- Event Data (Facebook).
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Prospective customers.
- Communication partner.
- Users.
- Business and contractual partners.
- Persons depicted.
- Customers.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Web Analytics.
- Targeting.
- Office and organisational procedures.
- Remarketing.
- Conversion tracking.
- Clicktracking.
- Affiliate Tracking.
- Organizational and Administrative Procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Authentication processes.
- Provision of our online services and usability.
- Information technology infrastructure.
- Public relations.
- Sales promotion.
- Business processes and management procedures.
Relevant legal bases
Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes
- Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – 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.
- Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate Interests (Article 6 (1) (f) GDPR) – the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states may apply.
Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as «Swiss DPA»). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).
Reference to the applicability of the GDPR and the Swiss DPA: These privacy policy serves both to provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms used in the GDPR are applied. In particular, instead of the terms used in the Swiss FADP such as «processing» of «personal data», «predominant interest», and «particularly sensitive personal data», the terms used in the GDPR, namely «processing» of «personal data», as well as «legitimate interest» and «special categories of data» are used. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP within its scope of application.
Security Precautions
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
TThe measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ 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 that is transferred between the website or app and the user’s browser (or between two servers), thereby safeguarding the data from unauthorized access.
TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with 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 securely and encryptedly transmitted.
Transmission of Personal Data
In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.
Data Transmission within the Group of Companies: We may transfer personal data to other companies within our group of companies or otherwise grant them access to this data. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate business and economic interests or otherwise, if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or otherwise a legal permission is present.
International data transfers
Data Processing in Third Countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if the processing is done within the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies, this is only done in accordance with legal requirements. If the data protection level in the third country has been recognized by an adequacy decision (Article 45 GDPR), this serves as the basis for data transfer. Otherwise, data transfers only occur if the data protection level is otherwise ensured, especially through standard contractual clauses (Article 46 (2)(c) GDPR), explicit consent, or in cases of contractual or legally required transfers (Article 49 (1) GDPR). Furthermore, we provide you with the basis of third-country transfers from individual third-country providers, with adequacy decisions primarily serving as the foundation. «Information regarding third-country transfers and existing 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.
EU-US Trans-Atlantic Data Privacy Framework: Within the context of the so-called «Data Privacy Framework» (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as secure within the adequacy decision of 10th July 2023. The list of certified companies as well as additional information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/s/. We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.
Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DPA). If the Federal Council does not determine that there is an adequate level of protection (list of states: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures. These measures may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection regulations previously recognised by the FDPIC or a competent data protection authority of another country.
Under Art. 16 of the Swiss DSG, exceptions can be made for the disclosure of data abroad if certain conditions are met, including the consent of the affected person, contract execution, public interest, protection of life or physical integrity, publicly made data or data from a legally provided register. Such disclosures always comply with the legal requirements.
General Information on Data Retention and Deletion
We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or special interests require a 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 legal prosecution or 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 specifically applicable to certain processing processes.
In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.
If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.
Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.
Further information on processing methods, procedures and services used:
- Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:
– 10 Years – Fiscal Code/Commercial Code – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents, booking receipts and invoices (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 1, 4 and 4a of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 Numbers 1 and 4, Paragraph 4 of the German Commercial Code (HGB)).
– 6 Years – Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 2, 3, 5 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 of the German Commercial Code (HGB)).
– 3 Years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code). - Data Retention and Deletion: The following general deadlines apply for retention and archiving according to Swiss law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years – Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on past business experience and standard industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is relevant in certain cases (Art. 127, 130 CO). Claims for rent, lease and capital interest as well as other periodic services, from the supply of food, for catering and for debts to landlords, as well as from handicraft work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries and from the employment relationship of employees expire after five years (Art. 128 CO).
Rights of Data Subjects
Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right of withdrawal for consents: You have the right to revoke consents at any time.
- Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
- Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
- Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
- Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of the data subjects under the Swiss DPA:
As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:
- Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
- Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as «contractual partners») within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.
- Processed data types: Inventory data (For example, the 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 phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and Administrative Procedures; Business processes and management procedures. Conversion tracking (Measurement of the effectiveness of marketing activities).
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Online shop, order forms, e-commerce and delivery.: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery, or performance of other services. If necessary for the execution of an order, we use service providers, in particular postal, freight and shipping companies, in order to carry out the delivery or execution to our customers. For the processing of payment transactions we use the services of banks and payment service providers. The required details are identified as such in the course of the ordering or comparable purchasing process and include the details required for delivery, or other way of making the product available and invoicing as well as contact information in order to be able to hold any consultation; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Consulting: We process the data of our clients as well as prospects and other commissioning parties or contractual partners (collectively referred to as «clients») in order to be able to provide our services to them. The processes that are part of and for the purposes of consulting include: contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, capturing and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, invoicing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the nature, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship with the client.
If it is necessary for our contract performance, for the protection of vital interests or legally required, or if there is consent from the clients, we disclose or transmit client data in compliance with professional legal requirements to third parties or agents such as authorities, subcontractors or in the field of IT, office or similar services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). - Software and Platform Services: We process the data of our users, registered and any test users (hereinafter uniformly referred to as «users») in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to develop it further. The required details are identified as such within the context of the conclusion of the agreement, order or comparable contract and include the details required for the provision of services and invoicing as well as contact information in order to be able to hold any further consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Commission-based matching and agency services: We process the information provided by interested parties as part of the request for agency for the purposes of establishing, implementing and, if necessary, terminating a contract for the brokerage of offers from providers of the requested products or services.
We use the contact data of the interested parties to specify their request by means of the agreed or otherwise permitted communication channel (e.g., telephone or e-mail) and to suggest suitable suppliers or offers based on the specified request. In addition, we can ask interested parties questions about the success of our agency services at a later point in time, in accordance with legal requirements.
We process the data of the interested parties, as well as the suppliers, to fulfil our contractual obligations, in order to link the enquiry of the interested parties submitted to us with the offers of the suppliers matching it and to forward it to the corresponding suppliers, or to recommend the suppliers.
We can record the entries in the online form sent by interested parties in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with the statutory accountability obligations (Article 5 (2) GDPR). These details will be stored for a period of three to four years if we have to prove the original request (e.g. to be able to prove that we are entitled to contact the interested party); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Business processes and operations
Personal data of service recipients and clients – including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.
The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.
Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.
- Processed data types: Inventory data (For example, the 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 phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or access times.).
- Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners. Customers.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Security measures; Provision of our online services and usability. Communication.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Customer Management and Customer Relationship Management (CRM): Processes required in the context of customer management and Customer Relationship Management (CRM) include customer acquisition in compliance with data protection regulations, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, management of CRM systems, secure account management, customer segmentation and targeting; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Customer Account: Customers can create an account within our online offer (e.g. customer or user account, «customer account» for short). If the registration of a customer account is required, customers will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent registration and use of the customer account, we store the IP addresses of the contractual partners along with the access times, in order to be able to prove the registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the customers’ responsibility to back up their data when terminating the customer Account; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- YouTube: YouTube with extended data protection
This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited («Google»), Gordon House, Barrow Street, Dublin 4, Ireland. When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. The YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account. We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user’s browser, which contains personal data similar to cookies and can be used to recognize the user. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780. After activating a YouTube video, further data processing operations may be triggered over which we have no influence. The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time. Further information about data protection at YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=de. The company is certified in accordance with the «EU-US Data Privacy Framework» (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780. - Crisp: Chatbot and assistance software and related services; Service provider: Crisp IM SARL, 2 Boulevard de Launay, 44100 Nantes, France; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:Nummer 1 Customer Messaging Platform für Startups und KMU’s – Crisp ; Privacy Policy:Privacy Statement | Crisp .The service is hosted in the EU. Basis for third country transfers: Switzerland – adequacy decision (France).
- FusionAuth: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: FusionAuth, 11080 Circle Point Rd, Suite 405, Westminster, CO 80020; USA Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fusionauth.io/ ; Privacy Policy: Privacy Policy – FusionAuth . The service is hosted in the EU.
Payment Procedure
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively referred to as «payment service providers»).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Contact data (e.g. postal and email addresses or phone numbers).
- Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Business processes and management procedures; Conversion tracking (Measurement of the effectiveness of marketing activities); Marketing. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Stripe: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://stripe.com/de; Privacy Policy: https://stripe.com/en-de/privacy. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).
- WooCommerce: E-Commerce software for the purpose of operating online shops, payment processing, and customer management processes; Service provider: Executed on servers and/or computers under our controllership; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://woocommerce.com/. Privacy Policy: https://automattic.com/privacy/.
Provision of online services and web hosting
We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
- Data subjects: Users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).). Security measures.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Provision of online offer on rented hosting space: For the provision of our online services, 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 hoster»); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called «server log files». Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user’s operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
- Amazon Web Services (AWS): Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://aws.amazon.com/; Privacy Policy: https://aws.amazon.com/privacy/; Data Processing Agreement: https://aws.amazon.com/compliance/gdpr-center/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Luxembourg).
- Mittwald: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.mittwald.de; Privacy Policy: https://www.mittwald.de/datenschutz; Data Processing Agreement: https://www.mittwald.de/faq/service-informationen/faq/datenschutz-alles-wichtige-zur-dsgvo. Basis for third-country transfers: Switzerland – Adequacy decision (Germany).
Use of Cookies
Cookies are small text files or other types of storage markers that store information on end devices and read information from them. For example, to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used of an online offer. Furthermore, cookies can be used for various concerns, such as for the functionality, security, and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on Consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless it is not required by law. Permission is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide a telemedia service (i.e., our online offer) expressly requested by the users. The revocable consent is clearly communicated to them and contains information on the respective cookie usage.
Notes on the legal basis for data protection: The legal basis on which we process users’ personal data with the help of cookies depends on whether we ask them for consent. If users accept, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies are based on our legitimate interests (e.g., in a commercial operation of our online offer and its usability improvement) or, if this occurs within the fulfillment of our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are used by us in the course of this data protection declaration or within the scope of our consent and processing processes.
Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a site. Similarly, user data collected via cookies can be used for reach measurement. Unless we provide users with explicit information about the nature and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and the storage duration can be up to two years.
General notes on revocation and objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing according to legal requirements, also via the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
- Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users’ consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users’ devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Cookiebot: Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users’ devices as well as their processing; Service provider: Usercentrics A/S, Havnegade 39, 1058 Kopenhagen, Dänemark; Website: https://www.cookiebot.com; Privacy Policy: https://www.cookiebot.com/en/privacy-policy/; Data Processing Agreement: Provided by the service provider; Further Information: Stored data (on the server of the service provider): The IP number of the user in anonymous form (the last three digits are set to 0), date and time of the consent, user agent of the user’s browser, the URL from which the consent was sent, An anonymous, random and encrypted key value. the consent status of the user.
Special Notes on Applications (Apps)
We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.
Legal basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Payment Data (e.g. bank details, invoices, payment history). Contract data (e.g. contract object, duration, customer category).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Commercial use: We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as «users») in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to develop it further. The required details are identified as such within the scope of the conclusion of a contract for the use of the application, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Storage of the universally unique identifier (UUID): The application stores a so-called Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality of the application and storing the user’s settings. This identifier is generated when the application is installed (but is not connected to the device, so no device ID in this sense), remains stored between the start of the application and its updates and is deleted when users remove the application from their device.
Registration, Login and User Account
Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).
Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of information relevant to their user account, such as technical changes.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion». Deletion after termination.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used::
- Registration with a real name: Due to the nature of our services, we ask users to use our services only with their real names. This means that the use of pseudonyms is not permitted; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Users’ profiles are public: The users’ profiles are not publicly visible or accessible.
- Two-factor Authentication: Two-factor authentication provides an extra layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, in addition to your password, you must perform another authentication measure (e.g. enter a code sent to a mobile device – we will inform you about the procedure we use); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Single Sign-on Authentication
Single Sign-On» or «Single Sign-On Authentication or Logon» are procedures that allow users to log in to our online services using a user account with a provider of Single Sign-On services (e.g. a social network). The prerequisite for Single Sign-On Authentication is that users are registered with the respective Single Sign-On provider and enter the required access data in the online form provided for this purpose, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via the button.
Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in with the respective single sign-on provider under this user ID and an ID that cannot be used for other purposes (so-called «user handle»). Whether we receive further data depends solely on the single sign-on procedure used, the data releases selected as part of authentication and also which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, there can be different data, usually the e-mail address and the user name. The password entered by the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.
Users are requested to note that their data stored with us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actual. If, for example, the e-mail addresses of users change, users must change these manually in their user account with us.
We can use single sign-on authentication, provided that it has been agreed with users in the context of pre-fulfillment or fulfilment of the contract, in the context of consent processing and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure authentication system.
Should users decide to no longer want to use the link of their user account with the Single Sign-On provider for the Single Sign-On procedure, they must remove this link within their user account with the Single Sign-On provider. If users wish to delete their data from us, they must cancel their registration with us.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Authentication processes. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion». Deletion after termination.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Apple Single-Sign-On: Authentication services for user logins, provision of single sign-on functionalities, management of identity information and application integrations; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.apple.com. Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.
- Google Single-Sign-On: Authentication services for user logins, provision of single sign-on functionalities, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Opt-Out: Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors for the purposes of creating „Page-Insights» (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from the users’ profiles, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding 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 special agreement with LinkedIn Irland, the ‘Page Insights Joint Controller Addendum (the ‘Addendum’)’ (https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and wherein LinkedIn has agreed to fulfill the rights of the affected parties (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of the users (in particular to access to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, particularly regarding the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter «publication medium»). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Contact and Inquiry Management
When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Further information on processing methods, procedures and services used:
- Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Crisp: Chatbot and assistance software and related services; Service provider: Crisp IM SARL, 2 boulevard de Launay, 44100 Nantes, France; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://crisp.chat/en/; Privacy Policy: https://crisp.chat/en/privacy/. Basis for third-country transfers: Switzerland – Adequacy decision (France).
Chatbots and chat functions
We provide online chats and chatbot functions as a means of communication (together referred to as «Chat Services»). A chat is an online conversation that is conducted with a certain degree of immediacy. A chatbot is software that answers users’ questions or informs them about messages. If you use our chat functions, we may process your personal data.
If you use our Chat Services within an online platform, your identification number is also stored within the respective platform. We may also collect information about which users interact with our Chat Services and when. Furthermore, we store the content of your conversations via the Chat Services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.
We would like to inform users that the respective platform provider can find out that and when users communicate with our Chat Services and can collect technical information about the user’s device used and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of communication via Chat Services (i.e., information about who has communicated with whom) could be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their regulations, to which we refer for further information.
If users agree to activate information with regular messages to a chatbot, they have the possibility to unsubscribe from the information for the future at any time. The chatbot points out to users how and with which terms they can unsubscribe the messages. By unsubscribing from the chatbot messages, Users’ data is deleted from the directory of message recipients.
We use the aforementioned information to operate our Chat Services, e.g. to address users personally, to answer their inquiries, to transmit any requested content and also to improve our Chat Services (e.g. to «teach» chatbots answers to frequently asked questions or to identify unanswered inquiries).
Information on Legal basis: We use the Chat Services on the basis of a consent if we first obtain the permission of the users to process their data by the Chat Services. If we use Chat Services to answer user queries about our services or our company, this is done for contractual and pre-contractual communication. In addition, we use Chat Services based on our legitimate interests in optimizing the Chat Services, its operating efficiency and enhancing the positive user experience.
Withdrawal, objection and deletion: You can revoke a given consent at any time or contradict the processing of your data in the context of our chatbot use.
- Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing: Communication.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Crisp: Crisp: Chatbot and assistance software and related services; Service provider: Crisp IM SARL, 2 boulevard de Launay, 44100 Nantes, France; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://crisp.chat/de/; Privacy Policy: Privacy Statement | Crisp The service is hosted in the EU. Basis for third country transfers: Switzerland – adequacy decision (France).
Chatbots and chat functions
We offer online chats and chatbot functions (collectively referred to as «chat services») as a means of communication. A chat is an online conversation conducted with a certain degree of timeliness. A chatbot is software that answers users’ questions or informs them of messages. If you use our chat functions, we may process your personal data. You decide yourself within the chat which of your data is processed. - Crisp: Chatbot and assistance software and related services; Service provider: Crisp IM SARL, 2 boulevard de Launay, 44100 Nantes, France; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://crisp.chat/de/; Privacy Policy: Privacy Statement | Crisp The service is hosted in the EU. Basis for third country transfers: Switzerland – adequacy decision (France). Chatbots and chat functions
Video Conferences, Online Meetings, Webinars and Screen-Sharing
We use platforms and applications of other providers (hereinafter referred to as «Conference Platforms») for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as «Conference»). When using the Conference Platforms and their services, we comply with the legal requirements.
Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific Conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the Conference Platforms, then further data may be processed in accordance with the agreement with the respective Conference Provider.
Logging and recording: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are recorded, this will be transparently communicated to the participants in advance and they will be asked – if necessary – for their consent.
Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.
Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users’ data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings. Log data (e.g. log files concerning logins or data retrieval or access times.).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Persons depicted.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication. Office and organisational procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
Newsletter and Electronic Communications
We send newsletters, emails, and other electronic notifications (hereinafter «newsletters») exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users’ consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to demonstrate previously given consent. The processing of these data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed. In case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions and offers.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing: Direct marketing (e.g. by e-mail or postal). Web Analytics (e.g. access statistics, recognition of returning visitors).
- Retention and deletion: 3 years – Contractual claims (AT) (Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 1478, 1480 of the Austrian Civil Code).). 10 years – Contractual claims (CH) (Data required to consider potential compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the statutory limitation period of ten years, unless a shorter period of 5 years is applicable, which is relevant in certain cases. This period begins at the end of the calendar year in which the claim arose (Articles 127 and 128 Swiss Code of Obligations (CO))).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
- Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
Further information on processing methods, procedures and services used:
- Measurement of opening rates and click rates: The newsletters contain a so-called «web beacons», which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Order process reminder emails: When users cancel an order process, we can send them a notice of the cancellation and remind them to continue. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight or forgetting. The dispatch is based on consent, which users can object to at any time; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/de/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: Switzerland – Adequacy decision (Germany).
Commercial communication by E-Mail, Postal Mail, Fax or Telephone
We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
The recipients have the right to withdraw their consent at any time or to object to the advertising communication at any time.
After revocation or objection, we store the data required to prove the past authorization to contact or send up to three years from the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation, respectively objection of the users, we further store the data necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing: Direct marketing (e.g. by e-mail or postal); Marketing. Sales promotion.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Web Analysis, Monitoring and Optimization
Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.
Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called «cookies») or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention 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 two years.).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Google Analytics: We use Google Analytics to perform measurement and analysis of the use of our online services by users based on 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 analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers.
In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses. Analytics does provide coarse geo-location data by deriving the following metadata from IP addresses: City (and the derived latitude, and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU-based traffic, IP-address data is used solely for geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers before forwarding traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP Masking (Pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); 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). - Google Signals (Google Analytics function): Google signals are session data from sites and apps that Google associates with users who have signed in to their Google accounts, and who have turned on Ads Personalization. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion export to Ads. These are the areas where more information is gathered when Google Signals is activated (but only for users with Ads Personalization enabled): Cross Platform reporting – Connection of data about devices and activities from different sessions using your User-ID or Google-signals data providing an understanding of user behavior at each step of the conversion process, from initial contact to conversion and beyond; Remarketing with Google Analytics – Creation of remarketing audiences from Google Analytics data, and sharing of those audiences with linked advertising accounts; Demographics & Interests: Google Analytics collects additional information about demographics and interests from users who are signed in to their Google accounts and who have turned on Ads Personalization; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://support.google.com/analytics/answer/7532985?hl=en; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Further Information: https://business.safety.google/adsservices/ (Types of processing and data processed).
- No collection of detailed location and device data (Google Analytics function): No detailed location and device data is recorded (further information: https://support.google.com/analytics/answer/12017362).
- Google Tag Manager: We use Google Tag Manager, a software provided by Google, which enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that serve to record and analyse visitor activities. This technology assists us in improving our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies with user profiles, or perform any independent analyses. Its function is limited to simplifying and making the integration and management of tools and services we use on our website more efficient. Nevertheless, when using Google Tag Manager, users’ IP addresses are transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in this process. However, this data processing only occurs if services are integrated via the Tag Manager. For more detailed information about these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
- Fullstory : website analysis service; Service provider: Fullstory, Inc., 818 Marietta Street, Atlanta, G A 30318 USA; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR); Website: https://www.fullstory.com ; Privacy Policy: https://www.fullstory.com/legal/privacy/ ; Basis for third country transfer: EU-US Data Privacy Framework (DPF) ; Option to object (opt-out): https://www.fullstory.com/optout. Cookie lifespan: 2 months session replay and 12 months for analytics data.
Online Marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as «Content») based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called «cookie») or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.
The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.
Notes on revocation and objection:
We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called «opt-out»). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
- Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Event Data (Facebook) («Event Data» is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), login information, and Contact Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account); Contact Information (Facebook) («Contact Information» is data that (clearly) identifies data subjects, such as names, email addresses and phone numbers, that can be transmitted to Facebook, e.g. via Facebook pixels or uploads for matching purposes to form Custom Audiences. After the matching to create target groups, the Contact Information is deleted).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Affiliate Tracking; Marketing; Profiles with user-related information (Creating user profiles); Provision of our online services and usability; Remarketing. Clicktracking.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention 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 two years.).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Meta Pixel and Custom Audiences (Custom Audiences): With the help of the Meta-Pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or other software in apps), Meta is on the one hand able to determine the visitors of our online services as a target group for the presentation of ads (so-called «Meta ads»). Accordingly, we use Meta-Pixels to display Meta ads placed by us only to Meta users and within the services of partners cooperating with Meta (so-called «audience network» https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Meta (so-called «custom audiences»). With the help of Meta-Pixels, we also want to ensure that our Meta ads correspond to the potential interest of users and do not appear annoying. The Meta-Pixel also enables us to track the effectiveness of Meta ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Meta ad (known as «conversion tracking»); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement («Controller Addendum», https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Advanced matching for the Meta-Pixel: In addition to the processing of Event Data in the context of the use of the Meta-Pixel (or equivalent functions, e.g. in apps), Contact Information (data identifying individual persons, names, email addresses and telephone numbers) is also collected by Meta within our online offer or transmitted to Meta. The processing of contact information serves to form target groups (so-called » Custom Audiences») for the display of content and advertising information based on the presumed interests of users. The collection, or transmission and matching with data available on Meta is not in plain text, but as so-called «hash values», i.e. mathematical representations of the data (this method is used, for example, in the storage of passwords). After the matching to create target groups, the Contact Information is deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR); Privacy Policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further Information: https://www.facebook.com/legal/terms/data_security_terms.
- Facebook Ads: Placement of ads within the Facebook platform and analysis of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: We refer to the privacy and advertising settings in the users’ profiles on the Facebook platforms, as well as to Facebook’s consent procedures and contact options for exercising access and other data subject rights, as described in Facebook’s privacy policy. Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement («Controller Addendum», https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and Conversion Tracking: Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that adds users who use an online service to a pseudonymous remarketing list so that users can be shown ads on other online services based on their visit to the online service
; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms. - Enhanced Conversions for Google Ads: When users click on our Google ads and subsequently use the advertised service (so-called «conversion»), the data entered by the user, such as email address, name, residential address or telephone number, may be transmitted to Google. The hash values are then matched with existing Google accounts of the users to better evaluate and improve their interaction with the ads (e.g., clicks or views) and thus their performance; Legal Basis: Consent (Article 6 (1) (a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
- Google Adsense with personalized ads: We integrate the service Google Adsense, which enables the placement of personalized advertisements within our online offering. Google Adsense analyzes user behavior and uses this data to deliver targeted advertising that is aligned with the interests of our visitors. We receive financial compensation for each advertisement placement or other types of usage of these ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
- Google Adsense with non-personalized ads: We use the service Google Adsense to display non-personalised advertisements in our online offering. These advertisements are not based on individual user behaviour but are selected based on general characteristics such as the content of the page or your approximate geographical location. We receive a fee for the display or other use of these advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
- Instagram Ads: Placement of ads within the Instagram platform and analysis of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: We refer to the data protection and advertising settings in the user’s profile on the Instagram platform as well as Instagram’s consent procedure and Instagram’s contact options for exercising information and other data subject rights in Instagram’s privacy policy. Further Information: User event data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the joint controllership agreement («Controller Addendum», https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user’s behavior and conversions, as well as stores it in a profile (possible use cases: measuring campaign performance, optimizing ad delivery, building custom and similar target groups); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy, cookie policy: https://www.linkedin.com/legal/cookie-policy; Data Processing Agreement: https://www.linkedin.com/legal/l/dpa; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Microsoft Advertising: Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://about.ads.microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland); Opt-Out: https://account.microsoft.com/privacy/ad-settings/. Further Information: https://help.ads.microsoft.com/#apex/ads/en/ext60212.
- UTM Parameter: Analysis of sources and user actions based on an extension of web addresses referring to us with an additional parameter, the «UTM» parameter. For example, a UTM parameter «utm_source=platformX &utm_medium=video» can tell us that a person clicked the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video). With the help of this information, we can, for example, check our visibility on the Internet or the effectiveness of our campaigns; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Profiles in Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
- Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form); Public relations; Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Affiliate Tracking; Marketing; Profiles with user-related information (Creating user profiles). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Facebook Pages: Profiles within the social network Facebook – We are jointly responsible (so called «joint controller») with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see «Things that you and others do and provide» in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see «Device Information» in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under «How we use this information?» Facebook also collects and uses information to provide analytics services, known as «page insights,» to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook («Information about Page-Insights», https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the «Information about Page Insights» (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors for the purposes of creating „Page-Insights» (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from the users’ profiles, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding 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 special agreement with LinkedIn Irland, the ‘Page Insights Joint Controller Addendum (the ‘Addendum’)’ (https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and wherein LinkedIn has agreed to fulfill the rights of the affected parties (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of the users (in particular to access to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, particularly regarding the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - Reddit: Social network / community and conversation platform; Service provider: Reddit Ireland Limited, Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, D02 T292, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.reddit.com/; Privacy Policy: https://www.reddit.com/policies/privacy-policy. Basis for third-country transfers: Switzerland – Adequacy decision (Ireland).
Plugins and embedded functions and content
Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as «third-party providers»). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as «Content»).
The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties 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 also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention 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 two years.).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- YouCanBookMe: Online booking tool; Service provider: YouCanBookMe Ltd
Unit 407
Bedford Heights
Brickhill Drive
Bedford
MK41 7PH
United Kingdom; Website: https://youcanbook.me/; Privacy Policy: https://youcanbook.me/privacy. Basis for third-country transfers: EEA – Adequacy decision (United Kingdom), Switzerland – Adequacy decision (United Kingdom). - Google Fonts (Provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Management, Organization and Utilities
We use services, platforms and software from other providers (hereinafter referred to as » third-party providers») for the purposes of organizing, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.
Within this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.
- Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Contact data (e.g. postal and email addresses or phone numbers).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures. Communication.
- Retention and deletion: Deletion in accordance with the information provided in the section «General Information on Data Retention and Deletion».
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Jira: Web application for error management, troubleshooting and operational project management; Service provider: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.atlassian.com/de/software/jira; Privacy Policy: https://www.atlassian.com/legal/privacy-policy; Data Processing Agreement: https://www.atlassian.com/legal/data-processing-addendum; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Standard Contractual Clauses (Part of the Data Processing Agreement). Further Information: Data Transfer Impact Assessment: https://www.atlassian.com/legal/data-transfer-impact-assessment.
- Figma: Interactive design, prototyping, and collaboration for digital projects. Graphic editing, vector tools, commenting features, and version control. Data storage and processing in the cloud for teamwork; Service provider: Figma, Inc., 760 Market St FL 10, 94102 San Francisco, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.figma.com/; Privacy Policy: https://www.figma.com/summary-of-policy/; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA – Data Privacy Framework (DPF).