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 especially on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as "online offer").

The terms used are not gender-specific.

Effective date: August 12, 2024

Table of Contents

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the affected individuals.

Types of Data Processed

  • Inventory data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of Data Subjects

  • Communication partners.
  • Users.

Purposes of Processing

  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Relevant Legal Bases

Relevant Legal Bases under the GDPR: The following provides 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 domicile. If more specific legal bases apply in individual cases, we will inform you of them in the privacy policy.

  • Consent (Art. 6(1) Sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6(1) Sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Art. 6(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 data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific regulations 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 the transfer as well as automated decision-making in individual cases, including profiling. In addition, the data protection laws of the individual federal states may apply.

Third Countries (outside the EU and Switzerland): The data protection regulations in the country of residence of the controller apply in addition to or alongside the data protection regulations of the GDPR. These regulations may contain specific provisions that go beyond or deviate from the requirements of the GDPR. This includes, among other things, regulations on the protection against the misuse of personal data, regulations on the right of access and erasure, the right to object, the processing of special categories of personal data, processing for other purposes, transfer, and automated decision-making, including profiling.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the different likelihoods of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

These measures include, in particular, securing the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the related access, input, transfer, securing of availability, and separation. We have also implemented procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. Furthermore, we take the protection of personal data into account in the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.

Transfer of Personal Data

As part of our processing of personal data, it may occur that this data is transferred to other entities, companies, legally independent organizational units, or individuals, or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT duties or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

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 scope of the use of services provided by third parties or the disclosure or transfer of data to other persons, entities, or companies, this only occurs in compliance with the legal requirements. If the data protection level in the third country has been recognized by an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the data protection level is otherwise ensured, particularly through standard contractual clauses (Art. 46(2) lit. c) GDPR), explicit consent, or in the case of contractual or legally required transfer (Art. 49(1) GDPR). Furthermore, we will inform you of the basis for the third country transfer in the individual provider's details, whereby adequacy decisions take precedence. Information on third-country transfers and existing adequacy decisions can be found in the EU Commission's information offer: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as secure by adequacy decision dated 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 notices about which service providers we use that are certified under the Data Privacy Framework.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or there are no further legal grounds for processing. This applies to cases where the original purpose for processing ceases to exist or the data is no longer needed. Exceptions to this rule exist when legal obligations or special interests require a longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal enforcement or protection of the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on data retention and deletion that apply specifically to certain processing operations.

If multiple retention periods or deletion deadlines are indicated for a piece of data, the longest period is always decisive.

If a deadline 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 deadline occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the deadline is the effective date of termination or other termination of the legal relationship.

Data that is no longer required for the originally intended purpose but is retained due to legal requirements or other reasons will only be processed for the reasons that justify its retention.

Additional notes on processing operations, procedures, and services:

  • Retention and deletion of data: The following general deadlines apply for retention and archiving under German law:
    • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the working instructions and other organizational documents required to understand them, booking records, and invoices (§ 147(3) in conjunction with (1) no. 1, 4, and 4a AO, § 14b(1) UStG, § 257(1) no. 1 and 4, (4) HGB).
    • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents relevant for taxation, such as time sheets, business accounting sheets, calculation documents, price lists, but also payroll documents unless they are already booking records and cash register strips (§ 147(3) in conjunction with (1) no. 2, 3, 5 AO, § 257(1) no. 2 and 3, (4) HGB).
    • 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as related inquiries, based on past business experience and common industry practices, will be retained for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

Rights of Data Subjects under the GDPR: As a data subject, you have various rights under the GDPR, which in particular arise from Articles 15 to 21 of the GDPR:

  • Right to Object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, including profiling to the extent that it is related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw any consent given at any time.
  • Right of Access: You have the right to request confirmation as to whether data concerning you is being processed, and to obtain information about this data and further information and a copy of the data in accordance with legal requirements.
  • Right to Rectification: You have the right to request the completion or correction of inaccurate data concerning you in accordance with legal requirements.
  • Right to Erasure and Restriction of Processing: You have the right, in accordance with legal requirements, to request the immediate deletion of data concerning you, or alternatively, to request the restriction of processing of the data in accordance with legal requirements.
  • Right to Data Portability: You have the right to receive the data concerning you that you have provided to us, in a structured, commonly used, and machine-readable format, and to request its transmission to another controller, in accordance with legal requirements.
  • Complaint to Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you believe that the processing of personal data concerning you violates the GDPR.

Provision of the Online Offer and Web Hosting

We process the data of users to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the contents and functions of our online services to the user's browser or device.

  • Processed Data Types: Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types used, and operating systems, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Log data (e.g., log files concerning logins or data retrieval or access times).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).). Security measures.
  • Retention and Deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR).

Additional notes on processing operations, procedures, and services:

  • Provision of Online Offer on Rented Storage Space: We use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also referred to as "web host") for the provision of our online offer; Legal Bases: Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR).
  • Collection of Access Data and Log Files: Access to our online offer is logged in the form of so-called "server log files". Server log files may include the address and name of the retrieved websites and files, the date and time of retrieval, the amount of data transferred, a message about successful retrieval, browser type and version, the operating system of the user, the referrer URL (the previously visited page), and typically IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the stability of the servers; Legal Bases: Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR). Deletion of Data: Logfile 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 is fully resolved.

Use of Cookies

Cookies are small text files or other storage notes that store information on end devices and can be read from them. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed content, or used functions of an online offer. Cookies can also be used for various purposes, such as ensuring the functionality, security, and comfort of online offers, 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 it is not required by law. Consent is particularly not required if the storage and reading of information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e., our online offer) that they have expressly requested. The revocable consent is clearly communicated to them and contains information about the specific use of cookies.

Notes on Legal Bases under Data Protection Law: The legal basis on which we process users' personal data using cookies depends on whether we ask them for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed using cookies is based on our legitimate interests (e.g., in the economic operation of our online offer and improving its usability) or, if this is necessary to fulfill our contractual obligations, when the use of cookies is required to meet our contractual obligations. We clarify the purposes for which cookies are used in this privacy policy or within the framework of our consent and processing processes.

Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:

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

General Notes on Revocation and Objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to processing in accordance with legal requirements, including through the privacy settings of their browser.

  • Processed Data Types: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Legal Bases: Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR). Consent (Art. 6(1) Sentence 1 lit. a) GDPR).

Additional notes on processing operations, procedures, and services:

  • Processing of Cookie Data Based on Consent: We use a consent management solution to obtain users' consent for the use of cookies or the procedures and providers mentioned in the consent management solution. This procedure serves to obtain, record, manage, and revoke consents, particularly concerning the use of cookies and comparable technologies that are used to store, read, and process information on users' end devices. As part of this procedure, users' consents for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. Consent declarations are stored to avoid repeated inquiries and to provide proof of consent according to legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to associate the consent with a specific user or their device. Unless specific information about the providers of consent management services is available, the following general notes apply: The storage duration of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, the details of the scope of consent (e.g., concerning categories of cookies and/or service providers), as well as information about the browser, system, and the device used; Legal Bases: Consent (Art. 6(1) Sentence 1 lit. a) GDPR).

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, phone, or via social media) and within the scope of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested actions.

  • Processed Data Types: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or pictorial messages and contributions as well as the information related to them, such as authorship details or time of creation); Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types used, and operating systems, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Communication partners.
  • Purposes of Processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Retention and Deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6(1) Sentence 1 lit. b) GDPR).

Additional notes on processing operations, procedures, and services:

  • Contact Form: When contacting us via our contact form, email, or other communication channels, we process the personal data transmitted to us to respond and handle the respective concern. This typically includes details such as name, contact information, and any other information provided that is necessary for appropriate handling. We use this data solely for the specified purpose of contact and communication; Legal Bases: Contract fulfillment and pre-contractual inquiries (Art. 6(1) Sentence 1 lit. b) GDPR), Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR).

Chatbots and Chat Functions

We offer online chats and chatbot functions as a means of communication (collectively referred to as "chat services"). A chat is an online conversation conducted with some degree of immediacy. A chatbot is software that answers users' questions or informs them via messages. If you use our chat functions, we may process your personal data.

If you use our chat services within an online platform, your identification number within the respective platform will also be stored. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes to provide evidence of these as required by law.

We inform users that the respective platform provider may become aware that and when users communicate with our chat services, as well as technical information about the users' devices used, and depending on the settings of their devices, location information (so-called metadata) for the purpose of optimizing their respective services and for security purposes. The metadata of communication via chat services (i.e., for example, the information about who communicated with whom) may also be used by the respective platform providers in accordance with their terms, to which we refer for further information, for marketing purposes or to display personalized advertising to users.

If users agree to receive information with regular messages from a chatbot, they have the option to unsubscribe from future messages at any time. The chatbot will inform users on how and with which terms they can unsubscribe from messages. When users unsubscribe from chatbot messages, their data will be deleted from the directory of message recipients.

The aforementioned information is used to operate our chat services, e.g., to address users personally, to respond to their inquiries, to deliver any requested content, and to improve our chat services (e.g., to "teach" chatbots to answer frequently asked questions).

  • Processed Data Types: Contact data (e.g., postal and email addresses or); Content data (e.g., textual or pictorial messages and contributions as well as the information related to them, such as authorship details). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types used, and operating systems, interactions with content).
  • Data Subjects: Communication partners.
  • Purposes of Processing: Communication.
  • Retention and Deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Consent (Art. 6(1) Sentence 1 lit. a) GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6(1) Sentence 1 lit. b) GDPR). Legitimate interests (Art. 6(1) Sentence 1 lit. f) GDPR).

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes in our data processing make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or another individual notification becomes necessary.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we 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. If the terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Inventory Data: Inventory data includes essential information necessary for the identification and management of contracting parties, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), birthdates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling clear assignment and communication.
  • Content Data: Content data includes information generated during the creation, processing, and publication of content of all kinds. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not only limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
  • Contact Data: Contact data is essential information that enables communication with individuals or organizations. This includes phone numbers, postal addresses, and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.
  • Meta, Communication, and Procedural Data: Meta, communication, and procedural data are categories that 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 file size details, creation dates, document authors, and modification histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the involved persons, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction logs, and activities, as well as audit logs used for tracking and verifying operations.
  • Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data covers a wide range of information that shows how users engage with applications, which features they prefer, how long they stay on certain pages, and the paths they navigate through an application. Usage data may also include the frequency of use, activity timestamps, 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 "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.
  • Log Data: Log data refers to 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 usage or operation of a system. Log data is often used to analyze system problems, monitor security, or create performance reports.
  • Controller: The "controller" is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether it is collecting, evaluating, storing, transmitting, or deleting it.

Created with the free Privacy Policy Generator by Dr. Thomas Schwenke