Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly as "data") we process, for what purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender-specific.
As of: 26 August 2026
Table of Contents
Preamble
Controller
Overview of processing activities
Relevant legal bases
Security measures
Disclosure of personal data
International data transfers
General information on data storage and erasure
Rights of data subjects
Business services
Payment procedures
Use of cookies
Contact and inquiry management
Promotional communication via email, post, fax or telephone
Surveys and questionnaires
Web analysis, monitoring and optimisation
Online marketing
Customer reviews and rating procedures
Presence in social networks (Social Media)
Plug-ins and embedded functions as well as content
Amendments and updates
Definitions of terms
Data Controller
Stephen Haneder humbleguys Karlsplatz 3 80335 Munich Germany
Authorised representatives: Stephen Haneder
E-mail address: contact@humbleguys.de
Phone: +49 162 873 81 59
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of processed data
● Inventory data.
● Employee data.
● Payment data.
● Location data.
● Contact data.
● Content data.
● Contract data.
● Usage data.
● Meta, communication and procedural data.
Categories of data subjects
● Beneficiaries and clients.
● Employees.
● Interested parties.
● Communication partners.
● Users.
● Business and contractual partners.
● Participants.
● Third parties.
● Whistleblowers.
Purposes of processing
● Provision of contractual services and fulfilment of contractual obligations. ● Communication.
● Direct marketing.
● Reach measurement.
● Tracking.
● Office and organisational procedures.
● Conversion measurement.
● Target group formation.
● Organisational and administrative procedures.
● Feedback.
● Surveys and questionnaires.
● Marketing.
● Profiles with user-related information.
● Provision of our online offer and user-friendliness.
● Information technology infrastructure.
● Whistleblower protection.
● Public relations.
● Sales promotion.
● Business processes and commercial procedures.
Relevant legal bases
Relevant legal bases under the GDPR: Below is 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 be applicable in individual cases, we will inform you of these in the privacy policy.
● Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
● Performance of a contract and prior enquiries (Art. 6 (1) (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 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
● Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG). The BDSG contains in particular special regulations on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as
automated individual decision-making, including profiling. Furthermore, state data protection acts of the individual federal states may apply.
Security measures
We take appropriate technical and organisational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security 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 access to, inputting of, transmission of, securing the availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the erasure of data and responses to data compromise. We also take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorised access, we rely on
TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.
Transfer of personal data
In the course of our processing of personal data, it may happen that this data is transferred or disclosed to other bodies, companies, legally independent organisational units or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with 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 organisation: We may transfer personal data to other departments or units within our organisation or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate entrepreneurial and business interests or takes place if it is necessary to fulfil our contract-related obligations or if the consent of the data subjects or legal permission has been obtained.
International data transfers
Data processing in third countries: Insofar as we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this occurs within the scope of using third-party services or disclosing or transferring data to other persons, bodies or companies (which becomes recognisable from the postal address of the respective provider or if the data transfer to third countries is explicitly referred to in the privacy policy), this is always done in accordance with the legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10/07/2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.
This two-fold protection ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should any changes arise within the framework of the DPF, the standard contractual clauses will step in 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 under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, appropriate
security measures apply, 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-prot ection_en?prefLang=de.
General information on data storage and erasure
We delete personal data that we process in accordance with statutory provisions as soon as the underlying consent is revoked or there are no further legal bases for processing. This applies to cases where the original purpose of processing no longer exists or the data is no longer required. Exceptions to this rule apply if statutory obligations or specific interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal enforcement or to protect the rights of other natural or legal persons, must be archived accordingly.
Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there are multiple specifications regarding the retention period or deletion deadlines of any data, the longest period is always applicable. Data that is no longer retained for its originally intended purpose, but rather due to statutory requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.
Retention and deletion of data: The following general periods apply to retention and archiving under German law:
● 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the working instructions and other organisational documents required for their understanding (Section 147 (1) No. 1 in conjunction with (3) of the German Fiscal Code (AO), Section 257 (1) No. 1 in conjunction with (4) of the German Commercial Code (HGB)).
● 8 years - Accounting vouchers, such as invoices and expense vouchers (Section 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO, Section 14b (1) of the German Value Added Tax Act (UStG) and Section 257 (1) No. 4 in conjunction with (4) HGB).
● 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents, provided they are of importance for taxation, e.g. hourly wage slips, cost accounting sheets, calculation documents, price labels, but also payroll documents, provided they are not already accounting vouchers, and cash register rolls (Section 147 (1) No. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) No. 2 and 3 in conjunction with (4) HGB).
● 3 years - Data required to take into account potential warranty and damage claims or similar contractual claims and rights, as well as to process related enquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 of the German Civil Code (BGB)).
Commencement of the period at the end of the year: Unless a period explicitly begins on a specific date and is at least one year long, it starts automatically at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships under which data is stored, the event triggering the period is the date on which termination takes effect or other termination of the legal relationship.
Rights of the data subjects
Rights of the data subjects under the GDPR: As a data subject under the GDPR, you have various rights, which arise in particular from Art. 15 to 21 GDPR:
● Right to object: You have the right, on grounds relating to your particular situation, to object at any time to processing of personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
● Right to withdraw consent: You have the right to withdraw any consent given at any time.
● Right of access: You have the right to obtain confirmation as to whether or not data concerning you are being processed, and access to this data, as well as further information and a copy of the data in accordance with statutory provisions.
● Right to rectification: You have the right, in accordance with statutory provisions, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
● Right to erasure and restriction of processing: You have the right, in accordance with statutory provisions, to request that data concerning you be erased without delay, or alternatively, in accordance with statutory provisions, to request restriction of processing of the data.
● Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to request its transmission to another controller in accordance with statutory provisions.
● Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.
Business services
We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers and other cooperation partners (collectively referred to as "contractual partners"), for the initiation, implementation and execution of contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures that take place upon request, as well as communication in connection with the respective contractual relationship.
The processing serves in particular to fulfil our main and ancillary contractual obligations. This includes the provision of the agreed services, any update and information obligations, the processing of warranty and other service disruptions, the processing of revocations, terminations of continuing obligations, reversals, refunds as well as the processing of other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.
In particular, master data such as name, address and, if applicable, company, contact details such as email address and telephone number, contract and service data such as subject matter of the contract, contract term, order or transaction number, usage and service data, payment and billing data as well as communication content and histories are processed. To the extent necessary, we also process data disclosed or transmitted to us in the course of executing an order.
Furthermore, we process the data to protect our rights and to fulfil legal obligations. This includes in particular commercial and tax retention obligations, documentation obligations and, if applicable, proof and accountability obligations. In addition, processing is carried out on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security as well as in protecting our business operations and our contractual partners from misuse, endangerment of data, secrets and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other vicarious agents, insofar as this is necessary for the execution of the contract or to fulfil legal obligations.
Personal data is only passed on to third parties to the extent necessary for the performance of a contract, for the implementation of pre-contractual measures, for the protection of legitimate interests or for the fulfilment of legal obligations. We will provide separate information on any further processing, in particular for marketing purposes, in this privacy policy.
We inform the contractual partners which data is required in individual cases during the data collection process, for example in online forms by means of appropriate labelling or in personal contact.
The data is deleted as soon as it is no longer required for the aforementioned purposes and there are no conflicting legal retention obligations.
Statutory retention periods, in particular under commercial and tax law, may require longer storage. We delete data transmitted in the context of a specific order after completion of the order and expiry of any retention periods, unless there are other legal or contractual obligations to store the data.
The legal basis for the processing is Art. 6 (1) (b) GDPR for the implementation of pre-contractual measures and for the performance of the respective contractual relationship, as well as Art. 6 (1) (c) GDPR for the fulfilment of legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6 (1) (f) GDPR. Insofar as the processing is based on Art. 6 (1) (f) GDPR, it is carried out to protect our legitimate interests in a proper and efficient business organisation, the internal administration and documentation of business transactions, the assertion and defence of legal claims, ensuring IT and data security, the prevention of abuse and fraud, as well as the economic management and further development of our business operations. These interests consist in particular in ensuring safe and legally secure business operations as well as in safeguarding our entrepreneurial capacity to act.
● Processed types of data: 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. contract subject matter, term, customer category).
● Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
● Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures.
Business processes and economic procedures.
● Retention and erasure: Erasure in accordance with the specifications in the section "General information on data storage and erasure".
● Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing operations, procedures and services:
● Agency services: We process the data of our customers within the scope of our contractual services, which may include, for example, conceptual and strategic advice, campaign planning, software and design development/advice or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) (b) GDPR).
Payment method
Within the framework of contractual and other legal relationships, on the basis of legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, in addition to banks and credit institutions, use other service providers for this purpose (collectively "payment service providers"). Payment transactions are carried out using state-of-the-art technology exclusively via encrypted connections, so that the data entered is protected against unauthorised access during transmission.
The data processed by the payment service providers includes master data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related details. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit-card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit reference agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer to the GTCs and data protection notices of the payment service providers.
For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and to assert rights of cancellation, information and other data subject rights.
● 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. contract object, term, customer category); Usage data (e.g. page views and duration 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, times, identification numbers, persons involved).
● Data subjects: Service recipients and clients; Business and contractual partners. Interested parties.
● Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and operational procedures.
● Retention and deletion: Deletion in accordance with the specifications in the section "General Information on Data Storage and Deletion".
● Legal basis: Performance of a contract and prior contractual enquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing operations, procedures and services:
● PayPal: Payment services (technical connection of
online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider:
PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Performance of a contract and prior contractual enquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
● 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 a contract and prior contractual enquiries (Art. 6 (1) (b) GDPR); Website:
https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
Use of cookies
The term "cookies" refers to functions that store and read information on users' terminal devices. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online services, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain the users' prior consent where required. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online service. Consent can be revoked at any time. We provide clear information on its 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 is 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 duration: With regard to storage duration, 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 terminal device (e.g. browser or mobile application).
● Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. This allows, for example, the login status to be saved and preferred content to be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage duration can be 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 declare an objection to the processing in accordance with legal requirements, including by means of the privacy settings of their browser.
● Processed data types: Meta, communication, and process data (e.g. IP addresses, times, identification numbers, involved persons). ● Data subjects: Users (e.g. website visitors, users of online services).
● Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures, and services:
● Processing of cookie data based on consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers mentioned in the
consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consent, in particular relating to the use of cookies and comparable technologies used to store, read, and
process information on users' terminal devices. Within the framework of this procedure, users' consent for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. In the absence of specific information on the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. In this process, a pseudonymous
user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers), as well as information about the browser, the system, and the terminal device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Contact and Enquiry Management
When contacting us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the details of the inquiring persons are processed to the extent necessary to answer the contact inquiries and any requested measures.
● Processed data types: Contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as information relating to them, such as details of authorship or time of creation). Metadata, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
● Data subjects: Communication partners.
● Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and
user-friendliness.
● Retention and erasure: Erasure in accordance with the specifications in the section "General Information on Data Storage and Erasure".
● Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and prior 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 email or other communication channels, we process the personal data transmitted to us to answer and process the respective inquiry. This usually includes details such as name, contact information and, where applicable, further information communicated to us and required for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal basis: Performance of a contract and prior contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of promotional communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw consent given at any time or to object to promotional communication at any time free of charge via the contact options mentioned above.
Following withdrawal of consent or objection, we store the data required to prove the previous authorisation to contact or send messages for up to three years after the end of the year of withdrawal or objection, based on our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. Based on the legitimate interest in permanently respecting the withdrawal or objection of users, we also store the data required to avoid re-contacting them (e.g. depending on the communication channel, the email address, telephone number, name).
● Processed data types: Master 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. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation).
● Data subjects: Communication partners.
● Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post); Marketing. Sales promotion.
● Retention and erasure: Erasure in accordance with the details in the section "General information on data storage and erasure".
● Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Surveys and polls
We conduct surveys and inquiries in order to collect information for the respectively communicated purpose of the survey or inquiry. The surveys and inquiries we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed to the extent necessary to provide and technically carry out the surveys (e.g. processing the IP address in order to display the survey in the user's browser or to enable the survey to be resumed using a cookie).
● Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and duration of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
● Data subjects: Participants.
● Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Surveys and questionnaires (e.g. surveys with input options, multiple-choice questions).
● Retention and erasure: Erasure in accordance with the specifications in the section "General information on data storage and erasure".
● Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Further information on processing operations, procedures and services:
● Google Forms: Creation and evaluation of online forms, surveys, feedback forms, etc.; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://docs.google.com/forms/;
Privacy Policy: https://business.safety.google/privacy/;
Data Processing Agreement:
https://cloud.google.com/terms/data-processing-addendum. Basis for
third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
Web analysis, monitoring and optimisation
Web analysis (also referred to as "reach measurement") is used to evaluate the visitor flows of our online offer and can include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offer or its functions or content are used most frequently, or invite users to return. It also enables us to understand which areas require optimisation.
In addition to web analysis, we can also use testing procedures, for example to test and optimise different versions of our online offer or its components.
Unless stated otherwise below, profiles, i.e. data summarised for a user process, may be created for these purposes and information may be stored in a browser or in an end device and then read. The information collected includes, in particular, websites visited and elements used there, as well as technical information, such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
In addition, the IP addresses of the users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. Generally, within the scope of web analysis, A/B testing and optimisation, no clear data of users (such as e-mail addresses or names) is stored, but rather pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis of data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
● Processed data types: Usage data (e.g. page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta-,
communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
● Retention and deletion: Deletion in accordance with the specifications in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (Unless stated otherwise, cookies and similar storage methods may be stored on users' devices for a period of two years.).
● Security measures: IP Masking (pseudonymisation of the IP address). ● Legal bases: 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 analyse the use of our online offer 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 recognise which content users have accessed within one or different usage processes, which search terms they have used, whether they have accessed them again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users referring 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 different devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: City (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible and is not used for any further purposes. When Google Analytics collects measurement data, all IP lookups are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website:
https://marketingplatform.google.com/intl/de/about/analytics/;
Security measures: IP Masking (pseudonymisation of the IP address); Privacy Policy: https://business.safety.google/privacy/;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF),
Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Option to object (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 as well as the 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 display of promotional and other content (collectively referred to as "Content") based on the potential interests of users, as well as the measurement of their 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 relevant to the display of the aforementioned content about the user 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, these can also be processed.
In addition, the IP addresses of the users are stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) for user protection. Generally, in the context of the online marketing process, no clear data of the users (such as email addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the online marketing processes, do not know the actual identity of the user, but only the information stored in their profiles.
The statements in the profiles are generally stored in the 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, analysed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing process provider.
Exceptionally, it is possible to assign clear data to the profiles, primarily if the users are, for example, members of a social network whose online marketing process we use and the network connects the user profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, for example by giving consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, within the scope of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. for example to the conclusion of a contract with us. Conversion measurement is used solely for the analysis of the success of our marketing measures.
Unless stated otherwise, we ask you to assume that cookies used are stored for a period of two years.
Information 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, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic, 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 privacy policy of the respective providers and the objection options (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, there is, on the one hand, the possibility that you deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered collectively directed at respective regions:
a) Europe: https://youronlinechoices.eu/.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-regional: https://optout.aboutads.info.
● Types of data processed: Usage data (e.g. page views and duration of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta-,
Communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing and legitimate interests: Range measurement (e.g. access statistics, recognition of returning visitors); Tracking (e.g. interest-/behaviour-based profiling, use of cookies);
Target group creation; Marketing; Profiles with user-related information (creation of user profiles). Conversion measurement (measurement of the effectiveness of marketing measures).
● Retention and deletion: Deletion in accordance with the specifications in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless stated otherwise, cookies and similar storage methods can be stored on users' devices for a period of two years).
● Security measures: IP masking (pseudonymisation of the IP address). ● Legal bases: 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 Ads and Conversion Measurement: Online marketing process for the purpose of placing content and advertisements within the service provider's advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the advertisements, i.e. whether users have taken them as an opportunity to interact with the advertisements and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:
https://marketingplatform.google.com; Privacy Policy:
https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/.
Data processing terms between controllers and
Standard Contractual Clauses for third-country transfers of data:
https://business.safety.google/adscontrollerterms.
Customer reviews and evaluation processes
We participate in review and rating procedures to evaluate, optimise and promote our services. If users rate us via the participating rating platforms or procedures or otherwise provide feedback, the General Terms and Conditions or Terms of Use and the privacy policy of the providers also apply. As a rule, rating also requires registration with the respective providers.
In order to ensure that the rating persons have actually used our services, we transfer the necessary data regarding the customer and the service used to the respective rating platform with the consent of the customer (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
● Processed types of data: Contract data (e.g. subject matter of contract, term, customer category); Usage data (e.g. page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
● Data subjects: Recipients of services and clients. Users (e.g. website visitors, users of online services).
● Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Marketing.
● Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing, procedures and services:
● Review widget: We integrate so-called "review widgets" into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a "badge". Although the corresponding content of the widget is displayed within our online offer, it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offer to the server of the widget provider, and the widget provider receives certain technical data (access data, including IP address) that is necessary for the content of the widget to be delivered to the user's browser. Furthermore, the widget provider receives information that users have visited our online offer. This information can be stored in a cookie and used by the widget provider to recognise which online offers participating in the rating process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Social media presence
We maintain online presences within social networks and process user data within this framework in order to communicate with the users active there or to offer information about us.
We point out that user data may be processed outside the area of the European Union. This may result in risks for users because, for example, the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For this purpose, cookies are usually stored on the users' computers, in which the user's usage behaviour and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (in particular 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 possibilities of objection (opt-out), we refer to the data protection declarations and information of the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data in each case and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.
● Processed types of data: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as information concerning them, such as details of authorship or time of creation); Usage data (e.g. page views and duration of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Inventory data (e.g. full name, residential address, contact information, customer number, etc.). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online form); Public relations; Provision of our online offer and user-friendliness.
Information technology infrastructure (operation and provision of
information systems and technical devices (computers, servers, etc.)). ● Retention and deletion: Deletion in accordance with the details 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, enables sharing of photos and videos, commenting and favouriting of posts, sending messages, subscribing 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: Data Privacy Framework (DPF).
● Facebook Pages: Profiles within the social network Facebook - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data of visitors to our Facebook page ("Fanpage"). This includes in particular information about user behaviour (e.g. content viewed or interacted with, actions carried out) as well as device information (e.g. IP address, operating system, browser type,
language settings, cookie data). Further details can be found 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 on how people interact with our page and its content. This is based on an agreement with Facebook ("Page Insights Joint Controller Addendum":
https://www.facebook.com/legal/terms/page_controller_addendum), which regulates,
among other things, security measures and the exercise of data subject rights. Further information can be found here:
https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct 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. The 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 a possible transfer 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: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
● LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors 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, as well as the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as details from user profiles, such as job function, country, industry, seniority level, company size and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have entered into a specific 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 satisfy the rights of the data subjects (i.e. users can, for example, direct 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. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. LinkedIn Ireland Unlimited Company is solely responsible for the further processing of the data, in particular as regards the transfer of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, 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: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/privacy-policy). Objection option (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
● Pinterest: Social network, enables sharing of photos, commenting, favouriting and curating of posts, sending messages, subscribing to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com.
Privacy policy: https://policy.pinterest.com/de/privacy-policy. ● Threads: Social network; 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.threads.com/. Privacy policy: https://help.instagram.com/515230437301944. ● X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.
● 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://business.safety.google/privacy/; Basis for third country transfers: Data Privacy Framework (DPF). Objection option (Opt-Out):
https://myadcenter.google.com/.
Plug-ins and embedded features as well as content
We integrate functional and content elements into our online offer, which 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 presupposes that the third-party providers of this content process the IP address of the users, as they could not send the content to their browsers without the IP address. The IP address is therefore required for the display of this content or functions. We strive to only use content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" allow information, such as visitor traffic on the pages of this website, to be evaluated. Furthermore, the pseudonymous information may be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details about the use of our online offer, but can also be linked with 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 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 duration of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); meta-,
communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved); location data (information on the geographical position of a device or a person); contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details on authorship or time of creation).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing and legitimate interests: Provision of our online offer and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest-/behaviour-based profiling, use of cookies);
Target group creation; marketing. Profiles with user-related information (creation of user profiles).
● Retention and deletion: Deletion in accordance with the specifications 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 bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing operations, procedures and services:
● Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
● Google Fonts (procurement from Google server): Procurement of fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols in terms of up-to-dateness and loading times, their uniform presentation and consideration of possible licensing restrictions. The IP address of the user is communicated to the font provider so that the fonts can be made available in the user's browser. Furthermore, technical data (language settings, screen resolution, operating system, hardware used) necessary for providing the fonts depending on the devices and technical environment used are transmitted. This data may be processed on a server of the font provider in the USA - When visiting our online offer, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). Google
Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referrer URL (i.e. the webpage on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analysed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so Google can determine how often a particular font family is requested. For the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts "Analytics" page. Finally, the referrer URL is logged so that the data can be used for production maintenance and to generate an aggregated report of the top integrations based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:
https://fonts.google.com/; Privacy Policy:
https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Further information:
https://fonts.google.com/faq?hl=de#privacy.
● Font Awesome (provision on own server): Display of fonts and symbols; Service provider: The Font Awesome Icons are hosted on our server, no data is transmitted to the provider of Font Awesome; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
● Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and location data of the users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website:
https://mapsplatform.google.com/; Privacy Policy:
https://business.safety.google/privacy/. Basis for third-country transfers: Data Privacy Framework (DPF).
● Instagram Plugins and Content: Instagram Plugins and Content - This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of
"Event Data" which Facebook collects via functions of Instagram (e.g. content embed functions) running on our online offer or receives in the context of a transmission for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of the users; b) delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) improvement of ad delivery and personalisation of features and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have entered into a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e. users can send, for example, access requests or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain details of individual users and are anonymous to us), then this processing is not carried out under joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms",
https://www.facebook.com/legal/terms/dataprocessing) , the
"Data Security Terms"
(https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of Standard Contractual Clauses ("Facebook-EU Data Transfer Addendum,
https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to access, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/.
● LinkedIn Plugins and Content: LinkedIn Plugins and Content - This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.linkedin.com; Privacy Policy:
https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement: https://de.linkedin.com/legal/l/dpa; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/l/dpa). Opt-Out Option:
https://www.linkedin.com/mypreferences/g/guest-retargeting-opt-out. ● MyFonts: Fonts; data processed as part of the font retrieval includes the identification number of the webfont project (anonymised), the URL of the licensed website which is linked to a customer number to identify the licensee and the licensed webfonts, and the referrer URL; the anonymised webfont 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 bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.myfonts.com. Privacy Policy: https://www.myfonts.com/de/a/font/legal/website-use-privacy-policy.
● OpenStreetMap: We integrate the maps of the "OpenStreetMap" service, which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). Users' data is used by OpenStreetMap solely for the purpose of displaying map functions and for temporary storage of chosen settings. This data may include, in particular, IP addresses and location data of users, which are, however, not collected without their consent (usually executed within the settings of their end devices or browsers); Service provider: FOSSGIS e.V., Bundesallee 23, 10717 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.openstreetmap.de. Privacy Policy: https://osmfoundation.org/wiki/Privacy_Policy.
● Pinterest Plugins and Content: Pinterest Plugins and Content - This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Pinterest; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy Policy:
https://policy.pinterest.com/de/privacy-policy.
● YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-Out Option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
● YouTube Videos: Videos stored on YouTube are embedded within our online offer. The integration of these YouTube videos takes place via a special domain using the component "youtube-nocookie" in the so-called "privacy-enhanced mode". In "privacy-enhanced mode", until the video starts, only information including your IP address and details about the browser and your end device can be stored on your end device in cookies or using comparable methods, which YouTube needs for the output, control and optimization of the video display. As soon as you play the videos, additional information for analyzing user behavior as well as for storage in the user profile and for personalization of content and ads can be processed by YouTube. The storage period for the cookies can be up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://business.safety.google/privacy/; Basis for
third-country transfers: Data Privacy Framework (DPF). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-pri vacy-enhanced-mode%2Cerweiterten-datenschutzmodus-aktivieren.
● Vimeo Video Player: Integration of a video player; Service provider: Vimeo Inc., 555 West 18th Street New York, New York 10011, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://vimeo.com; Privacy Policy: https://vimeo.com/legal/terms/de/datenschutz/policy; Data Processing Agreement: https://vimeo.com/legal/enterprise-terms/dpa. Basis for third-country transfers: Standard Contractual Clauses
(https://vimeo.com/legal/enterprise-terms/dpa).
Change and update
We ask you to inform yourself regularly about the content of our privacy policy. We 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 cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the details before making contact.
Definitions of terms
This section provides an overview of the terminology used in this privacy policy. Insofar as the terminology is legally defined, their legal definitions shall apply. The following explanations, however, are primarily intended to facilitate understanding.
● Employees: Employees are defined as persons who are in an employment relationship, whether as staff, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration, while the employee performs their work. The employment relationship comprises various phases, including the commencement, in which the employment contract is concluded, the performance, in which the employee carries out their work activities, and the termination, when the employment relationship ends, whether by notice, mutual termination agreement, or otherwise. Employee data is all information relating to these persons and standing in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data, and performance assessments.
● Inventory data: Inventory data comprises essential information required for the identification and management of contractual partners, user accounts, profiles, and
similar associations. This data may include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems, by enabling clear allocation and communication.
● Content data: Content data comprises information generated during the creation, editing, and publication of 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 only limited to the actual content itself, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
● Contact details: Contact details are essential information that enables communication with individuals or organisations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
● Conversion tracking: Conversion tracking (also referred to as
"visit action evaluation") is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on users' devices within the websites where the marketing measures take place, and then accessed again on the target website. For example, we can track whether the advertisements we have placed on other websites were successful.
● Metadata, communication and procedural data: Metadata, communication and procedural data are categories that contain information about the way 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 may include details of file size, creation date, the author of a document, and modification histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, social network messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, as well as audit logs used to track and review operations.
● Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages, and the paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving
products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
● Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or 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, comprises any kind of automated processing of personal data consisting of using this personal data to analyse, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour, and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
● Reach measurement: Reach measurement (also referred to as Web Analytics) is used to evaluate visitor flows to an online service and can include the behaviour or interests of visitors in specific information, such as content of websites. With the help of reach analysis, operators of online services can, for example, recognise at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to recognise returning visitors and thus obtain more precise analyses of the use of an online service.
● Location data: Location data is generated when a mobile device (or another device with the technical requirements for determining location) connects to a cellular network cell, a WLAN, or similar technical means and functions of location determination. Location data serves to indicate the geographically determinable position on Earth where the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
● Tracking: "Tracking" is spoken of when the behaviour of users can be traced across several online services. As a rule, behavioural and
interest information in relation to the online services used is stored in cookies or on the servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to show users advertisements that are likely to correspond to their interests.
● Controller: "Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
● Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it is collecting, evaluating, storing, transmitting, or deleting.
● Contractual data: Contractual data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This category of data is essential for the management and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contractual data may include start and end dates of the contract, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
● Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for electronic 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, authorisations, and fees.
● Target group formation: Target group formation (or "Custom Audiences") is referred to when target groups are determined for advertising purposes, e.g. displaying 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 shop in which they viewed the products. "Lookalike Audiences" (or similar target groups) are spoken of, on the other hand, when content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of forming Custom Audiences and Lookalike Audiences, cookies and web beacons are usually used.
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