Disclaimer: The following template has been prepared by a lawyer (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV), Certified Data Protection Officer (TÜV Süd) ) in accordance with the typical requirements of an online shop. However, you should only use the template after careful review and adaptation to your specific business model. The following template therefore contains additional notes that you must observe and red passages that you must particularly check and, if necessary, adapt. Please remove the notes after editing. If in doubt, seek legal advice. Copyright: You may use the template within the domain/website as long as your Marketpress license is valid for it. Passing it on to third parties, including customers (e.g., as a developer), is not permitted.

Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also briefly referred to as “data”) we process for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, mobile, and within external online presences, such as our social media profiles (hereinafter collectively referred to as” online offering”).

The terms used are not gender-specific.

Status: XX.XX.20XX

Please state the date of the privacy policy.

Controller

First Name, Last Name / Company
Street, House No.
Postal Code, City
Country

Email address: Your email address

Phone: Your phone number (optional)

Imprint: URL of your imprint (optional, but recommended)

Notes: For sole proprietorships, please use the term “Owner” and not “Managing Director”.

Contact Data Protection Officer

First Name, Last Name / Company
Street, House No.
Postal Code, City
Country

Note: Only the email address is mandatory; the other details are optional. Data protection officers only need to be specified if they have been appointed. An appointment is necessary according to § 38 BDSG-Neu (Federal Data Protection Act-New) for 20 or more employees who process personal data (for which an email inbox is practically sufficient).

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.

Note: The following information includes the typical processed data and categories of data subjects (these themselves, as well as the explanations in brackets, are for clarification only and can be adjusted or deleted).

Types of Data Processed

Inventory data (e.g., names, addresses).
Content data (e.g., entries in online forms).
Contact data (e.g., email, phone numbers).
Meta/communication data (e.g., device information, IP addresses).
Usage data (e.g., visited websites, interest in content, access times).
Location data (information about the geographical position of a device or person).
Contract data (e.g., subject matter of contract, term, customer category).
Payment data (e.g., bank details, invoices, payment history).

Categories of Data Subjects

Business and contractual partners.
Prospective customers.
Communication partners.
Customers.
Users (e.g., website visitors, users of online services).

Purposes of Processing

Assessment of creditworthiness and solvency.
Provision of our online offering and user-friendliness.
Visit action evaluation.
Office and organizational procedures.
Cross-Device Tracking (cross-device processing of user data for marketing purposes).
Direct marketing (e.g., by email or postal mail).
Interest-based and behavioral marketing.
Contact inquiries and communication.
Conversion measurement (measuring the effectiveness of marketing measures).
Profiling (creation of user profiles).
Remarketing.
Reach measurement (e.g., access statistics, recognition of recurring visitors).
Security measures.
Tracking (e.g., interest/behavior-based profiling, use of cookies).
Provision of contractual services and customer service.
Management and response to inquiries.
Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated Decisions in Individual Cases

Credit report (decision based on a credit check).

Relevant Legal Bases

In the following, we communicate the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence and establishment may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will communicate 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.
Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security Measures

In accordance with legal requirements and taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk 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.

The 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, input, transfer, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

SSL encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Note: Remove the reference to encryption if your offering is not encrypted. However, delivering the website via https should be considered mandatory.

Transfer and Disclosure of Personal Data

In the course of our processing of personal data, it may happen that data is transferred to or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if processing takes place within the framework of using third-party services or disclosing/transferring data to other persons, entities, or companies, this is only done in accordance with legal requirements.

Subject to explicit consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard protection clauses of the EU Commission, in the presence of certifications, or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the data protection level as secure for certain companies from the USA within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you within the privacy policy which of our service providers are certified under the Data Privacy Framework.

Use of Cookies

Cookies are small text files, or other storage notes, that store information on end devices and read information from end devices. For example, to store the login status in a user account, shopping cart content in an e-shop, accessed content, or used functions of an online offering. Cookies can also be used for various purposes, e.g., for the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not legally required. Consent is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide users with a telemedia service (i.e., our online offering) explicitly requested by them. The revocable consent is clearly communicated to users and contains information about the respective cookie usage.

Notes on data protection legal bases: On which data protection legal basis we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the economic operation of our online offering and improvement of its usability) or, if this is done within the framework of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or within the framework of our consent and processing processes.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the data collected with the help of cookies can be used for reach measurement. Unless we explicitly inform users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years.

General notes on revocation and objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “Opt-Out”). You can initially declare your objection via your browser settings, e.g., by deactivating the use of cookies (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices within the information on the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure, within which users’ consents to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained, managed, and revoked by users. The consent declaration is stored to avoid having to ask for it again and to be able to prove the consent in accordance with the legal obligation. The storage can take place server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following notes apply: The storage duration of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.

Cookie settings/objection option:

If you use a cookie consent banner (which is recommended), you can enter the option to call it up here (e.g., a link or a so-called [shortcode] that is automatically converted into a button/link by your software).

Notes on the processing of cookie data based on consent: You should only keep this option (and otherwise delete it) if you obtain “real” opt-in, i.e., user consent to the use of cookies (e.g., with so-called “cookie consent/opt-in banners” or as part of a registration process).

Since a cookie opt-in is generally necessary according to the ECJ when using marketing tools frequently used in e-commerce (e.g., Google Analytics or Facebook Pixel), this option is pre-selected.

This means that you should not use cookies (or third-party services on your websites that, in turn, use cookies) until users have given their consent. Only essential cookies, which users expect, such as a shopping cart function in an online shop or local reach measurement with the Matomo tool, are permitted.

Commercial and Business Services

We process data of our contractual and business partners, e.g., customers and prospective clients (collectively referred to as “contractual partners”), within the scope of contractual and comparable legal relationships, as well as related measures and in the context of communication with contractual partners (or pre-contractually), e.g., to answer inquiries.

We process this data to fulfill our contractual obligations, secure our rights, and for administrative tasks associated with this information, as well as for business organization. We only disclose contractual partners’ data to third parties within the scope of applicable law to the extent necessary for the aforementioned purposes, to fulfill legal obligations, or with the consent of the data subjects (e.g., to involved telecommunication, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners will be informed about further forms of processing, e.g., for marketing purposes, within this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, through special marking (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete data after the expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually 10 years). If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the effective date of termination or other cessation of the legal relationship. Data disclosed to us by the contractual partner within the scope of an order will be deleted by us in accordance with the order’s specifications, generally after the order’s completion.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms apply in the relationship between users and the providers.

Customer Account: Contractual partners can create an account within our online offering (e.g., customer or user account, in short “customer account”). If the registration of a customer account is required, contractual partners will be informed of this as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and use of the customer account, we store the IP addresses of customers along with the access times, in order to prove registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data related to the customer account will be deleted, unless their retention is required for legal reasons. It is the customers’ responsibility to back up their data upon termination of the customer account.

Business Analyses and Market Research: For business reasons and to identify market trends, as well as the wishes of contractual partners and users, we analyze the data available to us regarding business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, prospective clients, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users including their information, e.g., regarding services utilized. The analyses serve solely our purposes and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized, values. Furthermore, we respect the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).

Shop and E-commerce: We process our customers’ data to enable them to select, purchase, or order chosen products, goods, and associated services, as well as to facilitate their payment and delivery or execution. If necessary for the execution of an order, we use service providers, particularly postal, freight forwarding, and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable acquisition process and includes the details necessary for delivery or provision and billing, as well as contact information for any necessary communication.

Types of Data Processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Prospective clients, business and contractual partners, customers.
Purposes of Processing: Provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, management and answering of inquiries, security measures, evaluation of visitor actions, interest-based and behavioral marketing, profiling (creation of user profiles).
Legal Bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Note: Please remove the passage regarding the customer account or analysis of customer data if you do not offer a customer account or do not analyze your customers’ data as described.

Payment Service Providers

Within the scope of contractual and other legal relationships, due to legal obligations, or otherwise based on our legitimate interests, we offer efficient and secure payment options to the data subjects and for this purpose, we use additional payment service providers besides banks and credit institutions (collectively “payment service providers”).

The data processed by payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs (Transaction Authentication Numbers), and checksums, as well as contract, amount, and recipient-related information. This information is required to carry out the transactions. However, the entered data 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 denying the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and creditworthiness checks. For this, we refer to the terms and conditions and privacy policies of the payment service providers.

For payment transactions, the terms and conditions and privacy policies of the respective payment service providers apply, which can be accessed on their respective websites or transaction applications. We also refer to these for further information and for exercising rights of withdrawal, access, and other data subject rights.

Types of Data Processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of contract, term, customer category), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Customers, prospective clients.
Purposes of Processing: Provision of contractual services and customer service.
Legal Bases: Fulfillment of 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).

Services Used and Service Providers:

PayPal: Payment services and solutions (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; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Otherwise, adjust the list of services and providers as needed.

Credit Check

If we provide services in advance or incur comparable economic risks (e.g., when ordering on account), we reserve the right, in order to protect legitimate interests, to obtain identity and creditworthiness information for the purpose of assessing credit risk based on mathematical-statistical procedures from specialized service companies (credit agencies).

We process the information received from credit agencies regarding the statistical probability of payment default within the scope of a proper discretionary decision on the establishment, execution, and termination of the contractual relationship. We reserve the right, in the event of a negative credit check result, to refuse payment on account or any other advance service.

The decision on whether we provide services in advance is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes based on the information from the credit agency.

If we obtain explicit consent from contractual partners, the legal basis for the creditworthiness information and the transmission of customer data to the credit agencies is consent. If no consent is obtained, the creditworthiness information is obtained based on our legitimate interests in the security of our payment claims.

Types of Data Processed: Inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., email, phone numbers), contract data (e.g., subject matter of contract, term, customer category).
Data Subjects: Customers, prospective clients.
Purposes of Processing: Assessment of creditworthiness and credit rating.
Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Automated Decisions in Individual Cases: Creditworthiness information (decision based on a credit check).

Services Used and Service Providers:

Verband der Vereine Creditreform e.V.: Credit agency; Service provider: Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss, Germany; Website: https://www.creditreform.de/; Privacy Policy: https://www.creditreform.de/datenschutz.

Note: Remove the passage on credit checks if you do not perform credit checks. Review and modify the list of service providers as needed. A customer’s creditworthiness check is permissible if there is otherwise a risk of payment default, i.e., if the goods are delivered without payment having been received (i.e., if the customer chooses to purchase on account). Conversely, there is no risk of payment default if the customer, for example, chooses the prepayment option or makes payment via third-party providers, such as PayPal.

It should also be noted that obtaining an automatic creditworthiness report constitutes an “Automated Decision in Individual Cases” according to Art. 22 GDPR, i.e., a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but it is widely considered to be the case, including by the author of this template.

However, if you wish to exclude any risk, you should obtain consent. Consent is also necessary if the creditworthiness information is already used to decide whether the “on account” option should be displayed at all. This is because the customer might have chosen prepayment or PayPal anyway, and the credit check would not have been necessary. Such consent could, for example, read as follows:

 I agree that a credit check will be performed to decide in an automated procedure (Art. 22 GDPR) whether the option of purchase on account is offered. Further information on the credit check, the credit agencies used, the procedure, and the possibilities for objection can be found in our [Link]Privacy Policy[/Link].

Provision of Online Offering and Web Hosting

To be able to provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed in the context of providing the hosting service may include all information concerning the users of our online offering that arises during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Email Sending and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders, as well as further information concerning email sending (e.g., the involved providers) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that emails are generally not sent encrypted on the internet. As a rule, emails are encrypted during transmission, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume responsibility for the transmission path of emails between the sender and their receipt on our server.

Collection of Access Data and Log Files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the retrieved web pages and files, date and time of retrieval, transferred data volumes, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

The server log files can be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability.

Types of Data Processed: Content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Note: If not already done: Please ask the respective web hosts for a so-called “Auftragsverarbeitungsvertrag” (or “Data Processing Agreement”). This is legally required because the host collects personal data of website visitors on your behalf.

Contact

When contacting us (e.g., via contact form, email, phone, or social media), the information of the inquiring persons is processed insofar as this is necessary to answer contact inquiries and any requested measures.

Responding to contact inquiries within the scope of contractual or pre-contractual relationships is done to fulfill our contractual obligations or to answer (pre-)contractual inquiries, and otherwise based on our legitimate interests in responding to the inquiries.

Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Communication partners, interested parties.
Purposes of processing: Contact inquiries and communication, management and answering of inquiries.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and service providers used:

Contact form: If users contact us via our contact form, email, or other communication channels, we process the data communicated to us in this context to handle the stated concern. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise based on our legitimate interests as well as the interests of the communication partners in responding to the concerns and our legal retention obligations.
Help Scout: Management of contact inquiries and communication; Service provider: Help Scout Inc., 131 Tremont St, Boston, MA 02111-1338, USA; Website: https://www.helpscout.net; Privacy Policy: https://www.helpscout.net/company/legal/privacy/; Basis for third-country transfer: Standard Contractual Clauses (https://www.helpscout.com/company/legal/dpa/); Data Processing Agreement: https://www.helpscout.com/company/legal/dpa/.

Note: If external CRM systems are used, their providers should be named. Adjust this information or remove the specified service provider. Furthermore, data processing agreements (or “Data Processing Agreement”) must be concluded with the providers. If the providers process user data in a third country, special guarantees must be in place (e.g., Standard Contractual Clauses).

Newsletters and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described during registration, this description is decisive for the users’ consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personalized addressing in the newsletter, or other information if required for the purposes of the newsletter.

Double Opt-In Procedure: Registration for our newsletter generally takes place via a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with third-party email addresses. Newsletter registrations are logged to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the email service provider are also logged.

Deletion 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 a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is simultaneously confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a block list (so-called “blacklist”).

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the sending of emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on Legal Bases: The sending of newsletters is based on the recipients’ consent or, if consent is not required, on our legitimate interests in direct marketing, provided and insofar as this is legally permitted, e.g., in the case of existing customer advertising. Insofar as we commission a service provider with the sending of emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

Content: Information about us, our services, promotions, and offers.

Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), meta/communication data (e.g., device information, IP addresses), usage data (e.g., visited websites, interest in content, access times).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g., via email or postal mail).
Legal bases: 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., revoke your consent or object to further receipt. A link to unsubscribe from the newsletter can be found either at the end of each newsletter or you can otherwise use one of the contact options provided above, preferably email, for this purpose.

Services and service providers used:

Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server or that of our email service provider when the newsletter is opened. During this retrieval, technical information such as browser and system details, as well as your IP address and the time of retrieval, are collected. This information is used for the technical improvement of our newsletter based on technical data or for understanding target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open and click rates, as well as the storage of measurement results in user profiles and their further processing, are based on the users’ consent. Unfortunately, a separate revocation of success measurement is not possible; in this case, the entire newsletter subscription must be canceled or objected to. In that case, the stored profile information will be deleted; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
CleverReach: Email marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy Policy: https://www.cleverreach.com/de/datenschutz/; Data Processing Agreement: Concluded with provider.
Mailchimp: Email sending and email marketing platform; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/; Data Processing Agreement: https://mailchimp.com/legal/; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (inclusion in the Data Processing Agreement); Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Please delete the newsletter clause if you do not send newsletters. Otherwise, adjust the list of services and providers as well as the information on newsletter content and success measurement as needed.

Web Analysis, Monitoring, and Optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and can include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, viewed content, visited websites and elements used there, and technical information such as the browser used, the computer system used, and usage times. If users have consented to the collection of their location data, this may also be processed depending on the provider.

User IP addresses are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) are stored within the framework of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on Legal Bases: 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 based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of recurring visitors), tracking (e.g., interest/behavior-based profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
Security measures: IP masking (pseudonymization 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).

Services and service providers used:

etracker: Web analysis/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy Policy: https://www.etracker.com/datenschutz/; Data Processing Agreement: https://www.etracker.com/av-vertrag/.
Google Analytics: We use Google Analytics for measuring and analyzing the use of our online offering based on a pseudonymous user identification number. This identification number does not contain unique data such as names or email addresses. It serves to assign analytical information to an end device to recognize which content users have accessed within one or different usage processes, which search terms they have used, have re-accessed, or have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographical 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. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad display: https://myadcenter.google.com/personalizationoff; Further information: https://business.safety.google/adsservices/ (types of processing and processed data).
Google as Recipient of Consent: The consent given by users within a consent dialogue (also known as “Cookie Opt-In/Consent”, “Cookie Banner”, etc.) serves several purposes. Firstly, it helps us fulfill our obligation to obtain consent for storing and reading information on and from users’ end devices (according to ePrivacy directives). Secondly, it covers the processing of users’ personal data in accordance with data protection regulations. Furthermore, this consent also applies to Google, as the company is obliged under the Digital Markets Act to obtain consent for personalized services. Therefore, we share the status of consents given by users with Google. Our consent management software informs Google whether consents have been given or not. The goal is to ensure that users’ given or not given consents are taken into account when using Google Analytics and when integrating functions and external services. Thus, user consents and their revocation within Google Analytics and other Google services in our online offering can be dynamically adjusted depending on the user’s selection; 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://support.google.com/analytics/answer/9976101?hl=de; Privacy Policy: https://policies.google.com/privacy.
Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (for more information, please refer to this privacy policy). With the Tag Manager itself (which implements the tags), no user profiles are created or cookies stored, for example. Google only learns the user’s IP address, which is necessary to run Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement:
https://business.safety.google/adsprocessorterms; Basis for third-country transfer: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Further information: https://privacy.google.com/businesses/adsservices (types of processing and processed data).
Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and identifies returning users with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; With the “digital fingerprint”, user movements within our online offering are recorded using pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected through the use of Matomo is processed only by us and not shared with third parties; Website: https://matomo.org/.
Matomo: Matomo is a software used for web analysis and reach measurement. When using Matomo, cookies are generated and stored on the users’ end devices. The user data collected through the use of Matomo is processed only by us and not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Data deletion: The cookies have a storage period of a maximum of 13 months.

Please delete the section on web analysis, monitoring, and optimization if you do not use any web analysis, monitoring, and optimization tools on your website. Adjust the list of services and providers as needed.

Online Marketing

We process personal data for online marketing purposes, 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 potential user interests, as well as the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which information relevant for the display of the aforementioned content is stored about the user. This information may include, for example, viewed content, visited websites, online networks used, but also communication partners and 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, this data may also be processed.

User IP addresses are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored within the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or by similar methods. These cookies can later generally also be read on other websites that use the same online marketing procedure, analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing procedure provider.

In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if users are members of a social network whose online marketing procedures we use and the network links the user profiles with the aforementioned information. Please note that users may make additional agreements with the providers, e.g., by consenting during registration.

In principle, we 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 procedures have led to a so-called conversion, i.e., for example, to a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., 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., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information on the geographical position of a device or person).
Data Subjects: Users (e.g., website visitors, users of online services), interested parties.
Purposes of Processing: Tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of returning visitors), audience formation (determining target groups relevant for marketing purposes or other content output), cross-device tracking (cross-device processing of user data for marketing purposes).
Security Measures: IP Masking (pseudonymization 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).
Right to Object (Opt-Out): We refer to the privacy notices of the respective providers and the objection options specified for the providers (so-called “Opt-Out”). If no explicit opt-out option has been provided, there is the possibility that you can disable cookies in your browser settings. However, this may limit the functions of our online offering. We therefore also recommend the following opt-out options, which are offered summarized for respective regions:a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.

Services and Service Providers Used:

Meta Pixel and Audience Creation (Custom Audiences): With the help of the Meta Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Meta can, on the one hand, determine the visitors of our online offering as a target group for displaying advertisements (so-called “Meta Ads”). Accordingly, we use the Meta Pixel to display the Meta Ads placed by us only to those users on Meta platforms and within the services of Meta’s cooperating partners (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interest in specific topics or products, which become apparent from the visited websites) that we transmit to Meta (so-called “Custom Audiences”). With the help of the Meta Pixel, we also want to ensure that our Meta Ads correspond to the potential interests of users and do not appear annoying. Furthermore, with the help of the Meta Pixel, we can track the effectiveness of Meta Ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta Ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: User event data, i.e., behavioral and interest information, is processed for the purposes of targeted advertising and audience creation on the basis of the joint controller agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Google Ad Manager: We use the “Google Ad Manager” service to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Ad Manager is characterized by displaying ads in real-time based on presumed user interests. This allows us to show ads for our online offering to users who might have a potential interest in our offering or who had previously shown interest in it, as well as to measure the success of the ads; 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://marketingplatform.google.com; Privacy Policy: https://policies.google.com/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 for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third-country data transfers: https://business.safety.google/adsprocessorterms.
Google Ads and Conversion Measurement: Online marketing procedure for the purpose of placing content and ads 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 ads. In addition, we measure the conversion of the ads, i.e., whether users have taken them as an opportunity to interact with the ads 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://policies.google.com/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 data transfers: https://business.safety.google/adscontrollerterms.

Please delete the section on online marketing if you do not use any online marketing tools on your website. Adjust the list of services and providers as needed. Please note that the use of marketing services on the website generally requires a cookie opt-in.

Presences on Social Networks (Social Media)

We maintain online presences within social networks and, in this context, process user data to communicate with active users there or to offer information about us.

We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and resulting interests. These user profiles can in turn be used to display advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are generally stored on users’ computers, in which user behavior and interests are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective processing forms and objection options (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Also, in the case of information requests and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. Should you still need assistance, you can contact us.

Types of Data Processed: Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., entries in online forms), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data Subjects: Users (e.g., website visitors, users of online services).
Purposes of Processing: Contact inquiries and communication, tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
Legal Bases: Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Services and Service Providers Used:

Instagram: Social network, enables sharing photos and videos, commenting on and favoring posts, sending messages, subscribing to profiles and pages; 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/; Basis for third-country transfers: Data Privacy Framework (DPF).
Facebook Pages: Profiles within the Facebook social network – Together with Meta Platforms Ireland Limited, we are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called “Fanpage”). This data includes information about the types of content users view or interact with, or actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights,” to page operators so they can gain insights into how people interact with their pages and associated content. We have entered into a special agreement with Facebook (“Page Insights Information,” https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates what security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct inquiries or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Page Insights Information” (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA; 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.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third-country transfers: Data Privacy Framework (DPF).
LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of data from visitors, which is created for the purpose of generating “Page Insights” (statistics) for our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or actions they take, as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from the users’ profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Privacy 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 special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum (the “Addendum”)”, https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates what security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct inquiries or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which particularly concerns the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: 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); Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Website: https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy; Further information: Pinterest Data Sharing Addendum (APPENDIX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
TikTok: Social network / Video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy.
X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: 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, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Opt-out option: https://adssettings.google.com/authenticated; Basis for third-country transfers: Data Privacy Framework.
Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Adjust the list of social networks as needed.

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos or social media buttons, as well as posts (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only 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 referred to as “web beacons”) for statistical or marketing purposes. Through the “pixel tags”, information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in cookies on the users’ device and may include, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as 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 based on our legitimate interests (i.e., 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., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (information about the geographical position of a device or person), content data (e.g., entries in online forms), inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers).
Affected persons: Users (e.g., website visitors, users of online services), communication partners.
Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g., interest-based/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, management and response to inquiries.
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Services and service providers used:

Facebook Plugins and Content: Facebook Social Plugins and content – This may include, for example, content such as images, videos, or texts and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt, as part of a transfer (but not the further processing), of “Event Data” that Facebook collects via the Facebook Social Plugins (and content embedding functions) executed on our online offering, or receives as part of a transfer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have entered into a special agreement with Facebook (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum), which specifically regulates what security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct inquiries or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), then this processing does not take place within the framework of 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 information, 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: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third-country transfers: Data Privacy Framework (DPF).
Google Fonts (obtained from Google Server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and consideration of possible licensing restrictions. The IP address of the user is communicated to the font provider so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the font provider in the USA – When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with Google Fonts’ Cascading Style Sheets (CSS) and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analyzed. The Google Fonts Web API logs details of 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 that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that 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 an aggregated report on top integrations based on the number of font requests can be generated. According to Google’s own information, Google does not use any of the information collected by Google Fonts to create profiles of end-users or to serve targeted ads; 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://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
Google Maps: We integrate the maps of the service “Google Maps” from the provider Google. The processed data may include, in particular, users’ IP addresses and location data; 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://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF).
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://policies.google.com/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 displaying ad overlays: https://myadcenter.google.com/personalizationoff.
Vimeo Video Player: Integration of a video player; Service provider: Vimeo Inc., Attention: Legal Department, 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/privacy; Data Processing Agreement: https://vimeo.com/enterpriseterms/dpa; Basis for third-country transfers: Standard Contractual Clauses (https://vimeo.com/enterpriseterms/dpa).

Please delete the section on plugins and embedded functions and content if you do not use any plugins or embedded functions and content on your website. Otherwise, adjust the list of services and providers as needed.

Deletion of Data

The data we process will be deleted in accordance with legal requirements as soon as the consents for processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased or it is no longer required for the purpose).

If data is not deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons, or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data may also be provided within the individual privacy notices of this Privacy Policy.

Amendment and Update of the Privacy Policy

We ask you to regularly inform yourself about the content of our Privacy Policy. We will adapt the Privacy Policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information of companies and organizations in this Privacy Policy, please note that addresses may change over time and we ask you to verify the information before contacting them.

Rights of the Data Subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data 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 to withdraw consent: You have the right to withdraw given consents at any time.
Right of access: You have the right to request confirmation as to whether data concerning you is being processed, and to access information about this data, as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: You have the right, in accordance with legal requirements, to demand the completion of data concerning you or the correction of inaccurate data concerning you.
Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be deleted without undue delay, or alternatively, in accordance with legal requirements, to demand a restriction of the processing of the data.
Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
Right to lodge a complaint with a supervisory authority: You also have the right, in accordance with legal requirements, 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 GDPR.

Definitions

In this section, you will find an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to aid understanding. The terms are sorted alphabetically.

Visit Action Evaluation: “Visit action evaluation” (English “Conversion Tracking”) refers to a process by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the ads we placed on other websites were successful).
Creditworthiness Information: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online loan application, or an online application process without any human intervention. Such automated decisions are only permissible under Art. 22 GDPR if data subjects consent, if they are necessary for the fulfillment of a contract, or if national laws permit these decisions.
Cross-Device Tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest information is collected across devices in so-called profiles by assigning an online identifier to the users. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). The online identifier is usually not linked to clear data such as names, postal addresses, or email addresses by most providers.
IP Masking: “IP masking” refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer serve to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing.
Interest-based and behavioral marketing: Interest- and/or behavioral marketing refers to the most accurate possible predetermination of potential user interests in advertisements and other content. This is done based on information about their past behavior (e.g., visiting and staying on certain websites, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
Conversion Measurement: Conversion measurement is a process by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the ads we placed on other websites were successful.
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.
Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) to analyze, evaluate or predict them (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach Measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
Remarketing: “Remarketing” or “Retargeting” refers to, for example, noting for advertising purposes which products a user was interested in on a website, in order to remind the user of these products on other websites, e.g., in advertisements.”
Location Data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, Wi-Fi, or similar technical intermediaries and location determination functions. 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 location-dependent information.
Tracking: “Tracking” refers to the ability to trace user behavior across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of tracking technologies with regard to the online offerings used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
Controller: A “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: “Processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission, or deletion.
Audience Building: Audience building (or “Custom Audiences”) refers to the determination of target groups 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 where they viewed the products.” Lookalike Audiences” (or similar audiences) refers to displaying content deemed suitable to users whose profiles or interests presumably match those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of building Custom Audiences and Lookalike Audiences.

Privacy Policy

Introduction

Table of Contents

Controller

Contact Data Protection Officer

Overview of Processing Activities

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Automated Decisions in Individual Cases

Relevant Legal Bases

Security Measures

Transfer and Disclosure of Personal Data

Data Processing in Third Countries

Use of Cookies

Commercial and Business Services

Payment Service Providers

Credit Check

Provision of Online Offering and Web Hosting

Contact

Newsletters and Electronic Notifications

Web Analysis, Monitoring, and Optimization

Online Marketing

Presences on Social Networks (Social Media)

Plugins and Embedded Functions and Content

Deletion of Data

Amendment and Update of the Privacy Policy

Rights of the Data Subjects

Definitions