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 as "data") that 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 services").
The terms used are not gender-specific.
As of March 9, 2026
TABLE OF CONTENTS
RESPONSIBLE
Rahaf Abuobeid, Untere Str. 31,69117 Heidelberg,Germany
Email address: rahaf@rahafabuobeid.com
Overview of processing activities
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 details.
Contact details.
Content data.
Contract details.
Usage data.
Metadata, communication data and process data.
Log data.
Categories of affected persons
Recipient of services and client.
Employees
Interested parties.
Communication partner.
Users.
Business and contractual partners.
Participant.
Third parties.
Whistleblower.
Purposes of processing
Provision of contractual services and fulfillment of contractual obligations.
Communication.
Security measures.
Direct marketing.
Range measurement.
Tracking.
Office and organizational procedures.
Target group definition.
Organizational and administrative procedures.
Feedback.
Surveys and questionnaires.
Marketing.
Profiles containing user-related information.
Provision of our online services and user-friendliness.
Information technology infrastructure.
Whistleblower protection.
Public relations.
Sales promotion.
Business processes and business management procedures.
RELEVANT LEGAL BASES
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Furthermore, should more specific legal bases 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 consent to the processing of his or her personal data for one or more specific purposes.
Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a 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) - The 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 Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding 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 data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.
SECURITY 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 varying likelihood and severity of the threat to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.
Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized 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), thus 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. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transfer of personal data
As part of our processing of personal data, it may be necessary to transfer or disclose this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure its protection.
International data transfers
Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the data transfer to third countries), 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 recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 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 for the protection of your data.
This dual safeguard ensures comprehensive protection of your data: The Data Protection Framework (DPF) forms the primary layer of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.
For each service provider, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, appropriate safeguards 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 EU Commission's information service: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General information on data storage and deletion
We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or for the protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.
In cases where multiple retention periods or deletion deadlines for a given date are specified, the longest period always applies. Data that is no longer retained for its originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.
Data retention and deletion: The following general retention periods apply to data storage and archiving under German law:
10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
8 years - accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Commencement of a time limit at the end of the year: If a time limit does not expressly begin 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 time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those 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, which includes profiling to the extent that it is related to such direct marketing.
Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.
Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
Right to data portability: You have the right to receive the personal data concerning you that 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 the legal requirements.
Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, 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.
Business services
We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers, and other cooperation partners (collectively referred to as "contractual partners"), for the initiation, execution, and processing of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication related to the respective contractual relationship.
The processing of your data serves in particular to fulfill our primary and secondary contractual obligations. This includes providing the agreed services, fulfilling any update and information obligations, handling warranty claims and other service disruptions, processing cancellations, terminations of ongoing contractual relationships, rescissions, refunds, and handling other contract-related declarations and inquiries. This covers both one-off contracts and ongoing contractual relationships.
The data processed includes, in particular, master data such as name, address and, if applicable, company name; contact details such as email address and telephone number; contract and service data such as subject matter of the contract, contract duration, order or transaction number; usage and performance data; payment and billing data; as well as communication content and history. Where necessary, we also process data that is disclosed or transmitted to us in the course of fulfilling an order.
Furthermore, we process data to protect our rights and to fulfill legal obligations. This includes, in particular, commercial and tax law retention obligations, documentation requirements, and, where applicable, obligations to provide evidence and accountability. Processing also takes place based on our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and those of our contractual partners from misuse, data breaches, confidentiality, and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other agents, insofar as this is necessary for the performance of the contract or for fulfilling legal obligations.
Personal data will only be disclosed to third parties if this is necessary for the performance of a contract, for carrying out pre-contractual measures, for safeguarding legitimate interests, or for fulfilling legal obligations. We will provide separate information about any further processing, particularly for marketing purposes, within the framework of this privacy policy.
We will inform our contractual partners which data is required in each individual case during the data collection process, for example in online forms through appropriate labeling or in personal contact.
Data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent its deletion. Statutory retention periods, particularly under commercial and tax law, may require longer storage. Data transmitted within the scope of a specific order is deleted after completion of the order and expiry of any applicable retention periods, provided there are no further legal or contractual obligations to retain the data.
The legal basis for processing is Article 6(1)(b) GDPR for the performance of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Article 6(1)(c) GDPR for compliance with legal obligations. Where processing is based on legitimate interests, it is carried out on the basis of Article 6(1)(f) GDPR. Where processing is based on Article 6(1)(f) GDPR, it is carried out to safeguard our legitimate interests in a proper and efficient business organization, the internal administration and documentation of business transactions, the enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests consist, in particular, of ensuring secure and legally compliant business operations and maintaining our entrepreneurial capacity.
Types of data processed: 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, term, customer category).
Affected persons: Service recipients and clients; interested parties; business and contractual partners.
Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures; business processes and management procedures.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
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).
Further information on processing procedures, methods and services:
Event Management: We process the data of participants in events and similar activities that we offer or organize (hereinafter referred to collectively as "participants" and "events") to enable them to participate in the events and utilize the services or promotions associated with their participation.If, in this context, we process health-related data, religious, political, or other special categories of data, this is done within the bounds of transparency (e.g., for thematically focused events, or for the purposes of health care, safety, or with the consent of the data subjects).The required information is marked as such during the order, purchase, or similar contract process and includes the information necessary for service provision and invoicing, as well as contact information to facilitate any necessary follow-up. If we gain access to information about end customers, employees, or other individuals, we process this information in accordance with legal and contractual requirements; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online service and web hosting
We process user data to provide our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved); log data (e.g., log files concerning logins or data retrieval or access times); content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
Storage and deletion: Deletion according to 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 procedures, methods and services:
Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called "server log files." Server log files may contain the address and name of the accessed web pages and files, the date and time of access, the amount of data 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. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and 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 that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.
Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. Please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). We therefore cannot assume any responsibility for the transmission of emails between the sender and their receipt on our server. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
USE OF COOKIES
The term "cookies" refers to functions that store information on and read it from users' devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. Where necessary, we obtain users' consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about the scope of this consent and which cookies are used.
Information on the legal basis for data protection: 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 duration: The following types of cookies are distinguished with regard to storage duration:
Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved and preferred content to be displayed directly when the user revisits a website. User data collected via cookies can also be used for audience measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these cookies are persistent and can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with legal requirements, including via their browser's privacy settings.
Types of data processed: Metadata, communication data and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
Affected persons: Users (e.g., website visitors, users of online services).
Legal basis: 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 procedures, methods and services:
Processing of cookie data based on consent: We use a consent management solution to obtain user consent for the use of cookies or for the processes and providers mentioned within the consent management solution. This process serves to obtain, log, manage, and revoke consent, particularly regarding the use of cookies and similar technologies that are used to store, read, and process information on users' devices. Within this process, user consent for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management process, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored to avoid repeated requests and to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to assign the consent to a specific user or their device. Unless specific information is available regarding the providers of consent management services, the following general guidelines apply: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details of the scope of consent (e.g., categories of cookies and/or service providers concerned), and information about the browser, system, and device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Contact and inquiry management
When you contact us (e.g. by mail, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to answer the contact requests and any requested measures.
Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as information relating to them, such as authorship or time of creation); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
Affected persons: Communication partners.
Purposes of processing and legitimate interests: 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 according to 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). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing procedures, methods and services:
Contact form: When you contact us via our contact form, email, or other communication channels, we process the personal data you provide to answer and process your request. This typically includes information such as your name, contact details, and any other information you provide that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; legal basis: 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).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or on the basis of a legal obligation. If the newsletter's content is specified during the registration process, this content is decisive for the user's consent. Normally, providing your email address is sufficient to register for our newsletter. However, to offer you a personalized service, we may ask for your name for a personal greeting in the newsletter or for further information if necessary for the newsletter's purpose.
Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove previously given consent. The processing of this data is limited to the purpose of defending against potential claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In cases where we are obligated to permanently respect objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The registration process is logged based on our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure email delivery system.
Contents:
Information about us, our services, promotions and offers.
Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Affected persons: Communication partners. Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post). Provision of contractual services and fulfillment of contractual obligations.
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to receiving further newsletters. You will find a link to unsubscribe at the end of each newsletter, or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
Prerequisite for using free services: Consent to receive mailings may be a prerequisite for using free services (e.g., access to certain content or participation in specific promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
CleverReach: Email distribution and automation services; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.cleverreach.com/de ; Privacy policy: https://www.cleverreach.com/de/datenschutz/ . Data processing agreement: Provided by the service provider.
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising 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 revoke their consent at any time or to object to promotional communication at any time free of charge via the contact options mentioned above.
After revocation or objection, we store the data necessary to prove previous authorization for contacting you or sending you information for up to three years after the end of the year in which the revocation or objection occurred, based on our legitimate interests. The processing of this data is limited to the purpose of defending against potential claims. Based on our legitimate interest in permanently respecting users' revocations or objections, we also store the data necessary to prevent renewed contact (e.g., depending on the communication channel, email address, telephone number, name).
Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
Affected persons: Communication partners.
Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post); marketing. Sales promotion.
Storage and deletion: Deletion according to 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).
Surveys and polls
We conduct surveys and questionnaires to collect information for the stated purpose of each survey or questionnaire. The surveys and questionnaires we conduct (hereinafter referred to as "surveys") are evaluated anonymously. Personal data is only processed to the extent necessary for providing and technically conducting the surveys (e.g., processing the IP address to display the survey in the user's browser or to enable resuming the survey using a cookie).
Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Affected persons: 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).
Storage and deletion: Deletion according to 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 procedures, methods 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 basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de/intl/de/forms ; Privacy policy: https://policies.google.com/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 ).
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 advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as 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 methods are used to store user information relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical data such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this data may also be processed.
In addition, users' IP addresses are stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing methods know the actual user identity, but only the information stored in their profiles.
The information contained in the profiles is typically stored in cookies or using similar methods. These cookies can later be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing provider.
In exceptional cases, it is possible to associate personal data with profiles, primarily when users are, for example, members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by giving their consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, through conversion tracking, we can analyze which of our online marketing methods have led to a conversion, i.e., a contract signed with us. Conversion tracking is used solely for the purpose of analyzing the success of our marketing activities.
Unless otherwise stated, please assume that the cookies used will be stored for a period of two years.
Information on the legal basis: If we request users' consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient, economical, and user-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 cancellation and objection:
We refer you to the privacy policies of the respective providers and the opt-out options provided by those providers. If no explicit opt-out option is specified, you can disable cookies in your browser settings. However, this may limit the functionality of our website. We therefore also recommend the following opt-out options, which are offered for specific areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Across all regions: https://optout.aboutads.info.
Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation; marketing. Profiles with user-related information (creation of user profiles).
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, 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).
Further information on processing procedures, methods and services:
LinkedIn Insight Tag: Code that is loaded when a user visits our online service and tracks the user's behavior and conversions, storing this information in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.linkedin.com ; Privacy policy: https://www.linkedin.com/legal/privacy-policy , Cookie policy: https://www.linkedin.com/legal/cookie_policy ; Data processing agreement: https://www.linkedin.com/legal/l/dpa ; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://legal.linkedin.com/dpa ). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
Presences 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 ourselves.
Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their 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 usage patterns and the resulting user interests. These profiles may then be used to display advertisements both within and outside the networks that are presumably tailored to the users' interests. Therefore, cookies are typically stored on users' computers to record their usage patterns and interests. Additionally, user profiles can also store data independent of the devices used by the users (especially if they are members of the respective platforms and logged in).
For a detailed description of the respective processing methods and the options for objecting (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the latter have access to user data and can take appropriate action and provide information directly. Should you nevertheless require assistance, you can contact us.
Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as information relating to them, such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
Affected persons: 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.
Storage and deletion: Deletion according to 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 procedures, methods and services:
LinkedIn: Social Network - We are jointly responsible with LinkedIn Ireland Unlimited Company for collecting (but not further processing) visitor data used to generate "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as their actions. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, along with information from user profiles, such as job title, country, industry, hierarchical level, company size, and employment status. Information regarding LinkedIn's processing of user data 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, in particular, regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for access or erasure directly to LinkedIn). The rights of users (in particular the right to access, erasure, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to its 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 ; Legal basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://legal.linkedin.com/dpa ). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
Plug-ins and embedded functions as well as content
We integrate functional and content elements into our online service that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as "content").
The integration of third-party content always requires that these providers process users' IP addresses, as they cannot send the content to users' browsers without them. The IP address is therefore necessary for displaying this content or these functions. We strive to use only content from providers who use the IP address solely for content delivery. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. These pixel tags allow information such as visitor traffic on the pages of this website to be analyzed. The pseudonymized information can also be stored in cookies on users' devices and may include, among other things, technical information about the browser and operating system, referring websites, the time of visit, and other information about the use of our online services, as well as be combined with such information from other sources.
Information on the legal basis: 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 based on our legitimate interests (i.e., our interest in efficient, economical, and user-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.
Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation. Marketing.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, 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 procedures, methods and services:
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: Data Privacy Framework (DPF). Opt-out options: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for displaying ads: https://myadcenter.google.com/personalizationoff .
Changes and updates
We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.
If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, those legal definitions apply. The following explanations are primarily intended to aid understanding.
Employees: The term "employees" refers to individuals who are in an employment relationship, whether as staff members, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established through 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 encompasses various phases, including its establishment, during which the employment contract is concluded; its performance, during which the employee carries out their work; and its termination, when the employment relationship ends, whether through dismissal, a mutual termination agreement, or otherwise. Employee data is all information relating to these individuals and situated within the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, leave entitlements, health data, and performance reviews.
Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar associations. This data may include, among other things, personal and demographic information 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 unambiguous identification and communication.
Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.
Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
Metadata, communication data, and procedural data: These categories contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, document author, and modification history. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs, which are used to track and verify operations.
Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information, revealing how users utilize applications, which features they prefer, how long they stay on specific pages, and the paths they take 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 analyzing user behavior, optimizing user experiences, personalizing 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 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 simply "profiling," encompasses any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Examples of such profiling include interests in specific content or products, click behavior on a website, or location. Cookies and web beacons are frequently used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes 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 generate performance reports.
Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience analysis, operators of online services can, for example, determine when users visit their websites and which content they are interested in. This allows them to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for audience analysis purposes to recognize returning visitors and thus obtain more accurate analyses of online service usage.
Tracking: "Tracking" refers to the process of observing user behavior across multiple online services. Typically, behavioral and interest information related to the online services used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
Controller: The term "controller" refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.
Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include the start and end dates of the contract, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options, and special terms or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
Payment data: Payment data encompasses all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction data, verification numbers, and invoice information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
Target group creation: Target group creation (also known as "Custom Audiences") refers to the process of defining target groups for advertising purposes, such as displaying advertisements. For example, based on a user's interest in specific products or topics online, it can be inferred that this user will be interested in advertisements for similar products or the online shop where they viewed those products. "Lookalike Audiences" (or similar target groups) are created when content deemed suitable is displayed to users whose profiles or interests are likely to match those of the users for whom the profiles were created. Cookies and web beacons are typically used to create Custom Audiences and Lookalike Audiences.
Created with the free data privacy generator Datenschutz-Generator.de by Dr. Thomas Schwenke