Privacy policy
Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of 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 offer”).
The terms used are not gender-specific.
Status: November 14, 2025
Table of contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of the data subjects
- Business services
- Business processes and procedures
- Use of online platforms for offer and sales purposes
- Providers and Services used in the course of business activities
- Payment procedure
- Provision of the online offer and web hosting
- Use of cookies
- Blogs and publication media
- Contact and request management
- Artificial intelligence (AI)
- Cloud services
- Newsletter and electronic notifications
- Advertising communication via e-mail, post, fax or telephone
- Competitions and contests
- Web analysis, monitoring and optimization
- Online marketing
- Presence in social networks (social media)
- Plug-ins and embedded functions and content
- Change and update
- Definitions of terms
Person responsible
Nautic Alliance Holding GmbH
Mr. Klaus Pitter
Raimund-Obendrauf-Straße 30
8230 Hartberg
Austria
Persons authorized to represent the company: Representation by the management: Klaus Pitter
Phone: +43 (0)3332 66240
E-mail: info@nauticalliance.com
Legal Notice: https: //nauticalliance.com/impressum/
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Employee data.
- Payment data.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Event data (Facebook).
- Protocol data.
Categories of affected persons
- Beneficiary and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Competition and contest participants.
- Business and contractual partners.
- Third parties.
- Customers.
Purposes of the processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Target group formation.
- Organizational and administrative procedures.
- Organizing competitions and contests.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Information technology infrastructure.
- Financial and payment management.
- Public relations.
- Sales promotion.
- Business processes and business management procedures.
- Artificial intelligence (AI).
Relevant legal bases
Relevant legal bases according to the GDPR
Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Austria:
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). In particular, the Data Protection Act contains special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer as well as automated decision-making in individual cases.
Relevant legal basis according to the Swiss Data Protection Act:
If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (“Swiss FADP” for short). Unlike the GDPR, for example, the Swiss FADP does not generally require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss FADP). In addition, personal data will only be obtained by us for a specific purpose that is recognizable to the data subject and will only be processed in a manner that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).
Reference to validity of GDPR and Swiss DPA:
This data protection notice serves to provide information in accordance with both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data”, “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is truncated (also known as “IP masking”). The last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or make it significantly more difficult to identify a person by their IP address.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the group of companies: Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to it. This data transfer takes place on the basis of our legitimate business and commercial interests. This includes, for example, improving business processes, ensuring efficient and effective internal communication, optimizing the use of our human and technological resources and enabling us to make informed business decisions. In certain cases, the transfer of data may also be necessary in order to fulfill our contractual obligations, or it may be based on the consent of the data subject or legal permission.
International data transfers
Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which can be recognized by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and define contractual obligations to protect your data.
This dual protection ensures comprehensive protection of your data: The DPF forms the primary layer of protection, while the Standard Contractual Clauses serve as additional security. Should there be any changes to the DPF, the standard contractual clauses act as a reliable fall-back option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.
For the individual service providers, we will inform you whether they are certified in accordance with the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by a Swiss adequacy decision dated 07.06.2024. In addition, we have concluded standard data protection clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and stipulate contractual obligations to protect your data.
This dual protection ensures comprehensive protection of your data: The DPF forms the primary layer of protection, while the standard data protection clauses serve as additional security. Should there be any changes to the DPF, the standard data protection clauses act as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.
For the individual service providers, we will inform you whether they are certified in accordance with the DPF and whether standard data protection clauses are in place. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. For data transfers to other third countries, appropriate safeguards apply, including international contracts, specific safeguards, standard data protection clauses approved by the FDPIC or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority of another country.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive. We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.
Retention and deletion of data: The following general retention and archiving periods apply in accordance with Austrian 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 organizational documents (Federal Fiscal Code (BAO §132), Commercial Code (UGB §§190-212)).
- 6 years – Other business documents: Commercial or business letters received, copies of commercial or business letters sent and other documents, provided they are relevant for tax purposes. These include, for example, hourly wage slips, company accounting sheets, calculation documents, price labels and payroll accounting documents, provided they are not already accounting documents and cash register strips (Federal Fiscal Code (BAO §132), Commercial Code (UGB §§190-212)).
- 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on past business experience and common industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you 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 the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to a supervisory authority: In accordance with the statutory provisions 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 in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Rights of data subjects under the Swiss DPA:
As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain the information necessary for you to exercise your rights under this law and to ensure transparent data processing.
- Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased 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”), in the context of contractual and comparable legal relationships and related measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to inquiries.
We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. to involve 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 pass on 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 other forms of processing, such as for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
Online store, order forms, e-commerce and service fulfillment: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and provision, delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultations;
Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Business processes and procedures
Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.
The data collected is used to fulfill contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organization of the company.
Personal data may be passed on to third parties if this is necessary to fulfill the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content). contract object, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Employee data (information on employees and other persons in an employment relationship).
- Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services); employees (e.g. employees, applicants, temporary staff and other employees). Customers.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
Further information on processing operations, procedures and services:
- Customer management and customer relationship management (CRM): Procedures required in the context of customer management and customer relationship management (CRM) (e.g. Customer acquisition in compliance with data protection regulations, measures to promote customer loyalty and retention, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, administration of CRM systems, secure account management, customer segmentation and target group formation); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Contact management and maintenance: Procedures required to organize, maintain and secure contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adapting contact strategies); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Wish list: Customers can create a product/wish list. In this case, the products will be stored as part of the fulfillment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts and the control of payment flows (e.g. creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. Creation and checking of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Financial accounting and taxes: Procedures required for the recording, administration and control of financially relevant business transactions and for the calculation, reporting and payment of taxes (e.g. Account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Sales: Procedures required for the planning, implementation and control of measures for the marketing and sale of products or services (e.g. customer acquisition, preparation and tracking of offers, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Economic analyses and market research: The available data on business transactions, contracts, inquiries, etc. are analyzed for business purposes and to identify market trends, the wishes of contractual partners and users. The group of data subjects may include contractual partners, interested parties, customers, visitors and users of the controller’s online offering. The analyses are carried out for the purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, profiles of registered users and their details of services used are taken into account. The analyses are used exclusively by the controller and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. In addition, the privacy of the users is taken into account; the data is pseudonymized as far as possible for analysis purposes and, if feasible, processed anonymously (e.g. as aggregated data); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms that are operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms to measure reach and for interest-based marketing.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons affected: Service recipients and clients. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Providers and Services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.
- Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
- Persons concerned: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Payment procedure
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively “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 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 by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about 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 general terms and conditions and the data protection information of the payment service providers.
Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.
- Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Affected persons: Service recipients and clients; business and contractual partners. Interested parties.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc, 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore assume no responsibility for the transmission path of the emails between the sender and receipt on our server; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
- WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offers; Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider).
- JSDelivr: Content Delivery Network (CDN), which helps to deliver media and files quickly and efficiently, especially under high load; Service provider: ProspectOne, Królewska 65A/1, 30-081, Kraków, Poland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.jsdelivr.com. Privacy Policy: https://www.jsdelivr.com/terms/privacy-policy.
- Microsoft Azure: Services in the area of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://azure.microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://azure.microsoft.com/de-de/support/legal/. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/en-us/support/legal/), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/en-us/support/legal/).
- Yoast SEO: Optimization of websites for search engines; Service provider: Yoast B.V., Don Emanuelstraat 3, 6602 GX Wijchen, Netherlands; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://yoast.com/; Privacy Policy: https://www.newfold.com/privacy-center?currencyCode=EUR&langPref=de. Further information: Operation within a dedicated hosting environment.
Use of cookies
The term “cookies” refers to functions that store information on users’ end devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user’s consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope and which cookies are used.
Information on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that they may be stored for up to two years.
General information on revocation and objection (opt-out):
Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
BorlabsCookie: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of information on data protection and cookies, enabling users to revoke or adjust their consents; Service provider: Execution on servers and/or computers under its own responsibility under data protection law; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language and types of consent and the time they were given are stored on the server and in the cookie on the user’s device.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is only 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. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- 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 user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact and request management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Affected persons: Communication partner.
- Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Artificial intelligence (AI)
We use artificial intelligence (AI), whereby personal data is processed. The specific purposes and our interest in using AI are set out below. In accordance with the term “AI system” as defined in Article 3 No. 1 of the AI Regulation, we understand AI to mean a machine-based system that is designed to operate autonomously to varying degrees, can be adaptable after its introduction and produces results such as predictions, content, recommendations or decisions from the input received, which can influence physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human control, purpose limitation, data minimization, integrity and confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can be either the consent of the data subject or legal permission.
When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with the applicable provisions. We also observe the obligations incumbent on us when using or operating the purchased AI services. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or legal authorization. We attach particular importance to transparency, fairness and the preservation of human control over AI-supported decision-making processes.
We implement appropriate and robust technical and organizational measures to protect the processed data. These ensure the integrity and confidentiality of the processed data and minimize potential risks. By regularly reviewing AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
- Processed data types: Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services). Third parties.
- Purposes of processing: Artificial intelligence (AI).
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information and make predictions (“AI”, i.e. “artificial intelligence”, is to be understood in the applicable legal sense of the term); Service provider OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openai.com/de-DE/chatgpt/overview/; Privacy Policy: https://openai.com/de-DE/policies/privacy-policy/. Option to object (opt-out): https://privacy.openai.com/policies?modal=select-subject.
- Google Gemini: AI-powered system designed to provide advanced speech and image processing capabilities. It uses machine learning to understand and generate natural language and analyze images, thus offering versatile application possibilities in various areas; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/processorterms/?hl=de. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/processorterms/?hl=de), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/processorterms/?hl=de).
Cloud services
We use software services accessible via the Internet and executed on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. Cloud service providers also process usage data and metadata that they use for security purposes and to optimize their services.
If we use cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on users’ devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Affected persons: Interested parties; communication partners. Business and contractual partners.
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the users. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Contents
Information about us, our services, promotions and offers.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Affected persons: Communication partner.
- Purposes of processing: Direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Option to object (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 unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or its server, if we use a dispatch service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to 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 the user profiles and their further processing are based on the user’s consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider.
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove the previous authorization for contacting or sending up to three years after 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. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Affected persons: Communication partner.
- Purposes of processing: direct marketing (e.g. by email or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Competitions and contests
We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, execution and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).
If participants’ contributions are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that inquiries regarding the competition should be directed to us.
Participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because no further queries about the competition are to be expected. In principle, participants’ data will be deleted no later than 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. in order to answer queries about the prizes or to fulfill the prize; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. in order to be able to process warranty claims. Furthermore, participants’ data may be stored for longer, e.g. in the form of reporting on the competition in online and offline media.
If data is also collected for other purposes as part of the competition, its processing and retention period will be based on the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
- Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Affected persons: Competition and contest participants.
- Purposes of the processing: Organization of competitions and contests.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used, or invite visitors to reuse them. It also enables us to understand which areas require optimization.
In addition to web analysis, we may also use test procedures, for example to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the 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 from us or from the providers of the services we use, it is also possible to process location data.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is 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 dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Remarketing; target group formation; reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city’s inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/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: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms); Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data). - Google Signals (Google Analytics function): Google signals are session data from websites and apps that Google associates with users who have signed in to their Google accounts and enabled ad personalization. This association of data with these logged-in users is used to enable cross-device reporting, cross-device remarketing and cross-device conversion measurement. This includes: Cross-platform reporting – linking data about devices and activity from different sessions using your User ID or Google Signals data, enabling an understanding of user behavior at each step of the conversion process, from first contact to conversion and beyond; Remarketing with Google Analytics – creating remarketing audiences from Google Analytics data and sharing these audiences with linked advertising accounts; Demographics and interests – Google Analytics collects additional information about demographics and interests from users who are logged into their Google accounts and have ad personalization enabled; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/7532985?hl=de; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms). Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
- Target group formation with Google Analytics: We use Google Analytics to present ads that are placed via Google’s advertising services and those of its partners specifically to those users who have already shown an interest in our online offering or who have certain characteristics (e.g. interests in specific topics or products that are determined based on the websites they visit). We transmit this data to Google as part of so-called “remarketing” or “Google Analytics audiences”. The aim of using remarketing audiences is to ensure that our ads match the potential interests of users as closely as possible; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Legal basis: https://business.safety.google/adsprocessorterms/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Google Tag Manager: We use Google Tag Manager, a software from Google that enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that are used to record and analyze visitor activity. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create any user profiles, does not store any cookies with user profiles and does not carry out any independent analyses. Its function is limited to simplifying the integration and management of tools and services that we use on our website and making them more efficient. Nevertheless, when using the Google Tag Manager, the IP address of the user is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on 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 (Art. 6 para. 1 sentence 1 lit. 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: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms). - Google Universal Analytics: Reach measurement and web analysis – We use Universal Analytics, a version of Google Analytics, to perform a user analysis based on a pseudonymous user identification number. This identification number does not contain any clear data, such as names or e-mail addresses. It is used to assign analysis information to a user, e.g. to recognize which content users have called up during use or whether they call up our online offer again. Pseudonymous profiles of users are created with information from the use of various devices; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; General Terms and Conditions: https://business.safety.google/adsprocessorterms/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms); Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data).
Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) for user protection. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are generally stored in cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if, for example, the users are members of a social network whose online marketing processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies are stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is 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.
Information on revocation and objection:
We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are summarized for each area:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-territory: https://optout.aboutads.info.
- Processed data types: Content data (e.g. text or image messages and posts and the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Event data (Facebook) (“Event data” is information that is sent to the provider Meta via Meta pixels (whether via apps or other channels), for example, and relates to people or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations and product purchases. Event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as comments written, login information or contact information such as names, email addresses or telephone numbers. “Event data” is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are 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 behavior, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Custom Audiences; Marketing; Profiles with user-related information (Creating user profiles). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Meta pixel and target group formation (custom audiences): With the help of the meta pixel (or comparable functions, for the transmission of event data or contact information via interfaces in apps), it is possible for the Meta company to determine the visitors of our online offer as a target group for the display of advertisements (so-called “meta ads”). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of the partners cooperating with Meta (so-called “audience network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Meta (so-called “custom audiences”). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a meta ad (so-called “conversion measurement”); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. 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: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- Facebook Ads: Placement of advertisements within the Facebook platform and evaluation of the ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Opt-Out: We refer to the data protection and advertising settings in the user’s profile on the Facebook platforms as well as to Facebook’s consent procedures and contact options for exercising information and other data subject rights, as described in Facebook’s privacy policy; Further information: Event Data of users, i.e. .i.e. behavioral and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the Joint Controller Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- Google Ad Manager: We use the “Google Ad Manager” service to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for our online offering to users who may have a potential interest in our offering or have previously shown an interest in it, and to measure the success of the ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms. If Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Instagram ads: Placement of ads within the Instagram platform and evaluation of the ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Possibility of objection (opt-out): We refer to the data protection and advertising settings in the user’s profile on the Instagram platform as well as in the context of Instagram’s consent procedure and Instagram’s contact options for exercising information and other data subject rights in Instagram’s privacy policy; Further information: Event User data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the Joint Controller Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA.
Presence 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 result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network that allows you to share photos and videos, comment on and favorite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- Facebook pages: Profiles within the Facebook social network – The controller, together with Meta Platforms Ireland Limited, is responsible for the collection and transmission of data from visitors to our Facebook page (“fan page”). This includes, in particular, information about user behavior (e.g. content viewed or interacted with, actions performed) and device information (e.g. IP address, operating system, browser type, language settings, cookie data). You can find more information on this in the Facebook data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the “Page Insights” service, which provide information about how people interact with our site and its content. The basis for this is an agreement with Facebook (“Information on Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subjects’ rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore send requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transmission to Meta Platforms Inc. in the USA; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Facebook events: Event profiles within the Facebook social network – We use the “Events” function of the Facebook platform to draw attention to events and dates and to get in touch with users (participants and interested parties) and to exchange information. In doing so, we process personal data of the users of our event pages, insofar as this is necessary for the purpose of the event page and its moderation. This data includes information on first and last names, as well as published or privately shared content, as well as values on the status of participation and the time details for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Insights”, to event providers to give them insights into how people interact with their event pages and with the content associated with them; service providers: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors’ data used to create the “page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s data protection information: https://www.linkedin.com/legal/privacy-policy.
We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of the data subjects (i.e. users can, for example, send requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer 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 (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Option to object (opt-out): https://myadcenter.google.com/personalizationoff.
Plug-ins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, but may also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is 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 dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Location data (information on the geographical position of a device or person).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioral profiling, use of cookies); target group formation. Marketing.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and can process it for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimization of their offer. – We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and may process it for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The processed data may include, in particular, IP addresses and user location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- MyFonts: Fonts; data processed as part of the font retrieval process the identification number of the web font project (anonymized), the URL of the licensed website linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; Service provider: Monotype Imaging Holdings Inc, 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.myfonts.co. Privacy policy: https://www.myfonts.com/info/legal/#Privacy.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Change and update
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- Employees: Employees are defined as persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is defined by an employment contract or agreement. It involves the employer’s obligation to pay remuneration to the employee while the employee performs work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee performs his or her work activities, and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance appraisals.
- Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
- Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
- Contact details: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
- Artificial intelligence (AI): The purpose of processing data using artificial intelligence (AI) includes the automated analysis and processing of user data in order to recognize patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of data, the training and application of AI models as well as the continuous review and optimization of the results and is carried out exclusively with the consent of the users or on the basis of legal permission.
- Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
- Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Log data: Log data is information about events or activities that have been logged on a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them to better adapt the content of their websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing: The term “remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: The term “tracking” is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
- Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
- Payment data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorizations and fees.
- Target group formation: Custom audiences are defined when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products. In turn, “lookalike audiences” (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
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