Privacy policy

Introduction

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

The terms used are not gender-specific.

Status: May 6, 2024

Person responsible

Magma Coaching S.L.
Calle Amacas 17a
38916 Echedo, Santa Cruz de Tenerife
Spain

Represented by the managing directors and shareholders:
Christina Teuthorn-Mohr and Karsten Mohr

Commercial Register of Valverde, Tomo 16 , Folio 145, Sección 8, Hoja IH 402

E-mail: info(at)magma-coaching.com
Website: www.magma-coaching.com

Overview of processing

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

Types of data processed

  • Inventory data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.
  • Applicant data.
  • Contact information (Facebook).
  • Event data (Facebook).

Special categories of data

  • Health data.
  • Data relating to sex life or sexual orientation.
  • Religious or philosophical beliefs.
  • Data revealing racial or ethnic origin.

Categories of affected persons

  • Customers.
  • Employees.
  • Interested parties.
  • Communication partners.
  • users.
  • Applicants.
  • Business and contractual partners.

Purposes of the processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Range measurement.
  • Office and organizational procedures.
  • Remarketing.
  • Conversion measurement.
  • Target group formation.
  • Affiliate tracking.
  • Managing and responding to inquiries.
  • Application process.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Target group formation.
  • Provision of our online services and user-friendliness.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labor law and social security and social protection law and fulfill their obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, health or social care or treatment or for the management of health or social care systems and services in accordance with Art. 9 para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

Note on data transfer to the USA and other third countries

Among other things, we also use tools from companies based in the USA or other third countries that are not secure under data protection law. We would like to point out that these countries cannot guarantee a level of data protection comparable to that in the EU.

Due to the “EU-US Data Privacy Framework”, the USA is considered a safe third country if the recipient of the data based in the USA is certified under the EU-US Data Privacy Framework or other suitable guarantees (e.g. standard contractual clauses of the EU Commission) are in place. Where possible, we try to use tools from EU providers and, if this is not possible, at least select server locations within the EU if this option is provided by the tool providers.

Security measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Use of cookies

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

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offering). The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is their declared consent (Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TTDSG). Consent can be revoked at any time. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 GDPR (further information on objection can be found in this data protection declaration). Users can also declare their objection using their browser settings.

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users 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 declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for 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.
  • BorlabsCookie: Cookie consent management;
    Service provider: Borlabs GmbH, Hamburger Str. 11, 22083 Hamburg, Germany; Website: https://de.borlabs.io/borlabs-cookie/; Further information: An individual user ID, language and types of consent and the time they were given are stored on the server and in the cookie on the user’s device.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.

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

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 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, generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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

Customer account

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

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the customer’s responsibility to back up their data when the customer account is terminated.

Store and e-commerce

We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultations.

Coaching

We process the data of our customers, interested parties and other clients or contractual partners in order to be able to provide our services to them. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship.

As part of our activities, we may also process special categories of personal data (Art. 9 GDPR), in particular information on health, possibly with reference to their sex life or sexual orientation, as well as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. We obtain express consent for this or otherwise only process the special categories of data if another legal basis permits this.

If it is necessary for the fulfillment of our contract, for the protection of vital interests or by law, or if consent has been given, we disclose or transfer the data to third parties or agents, such as authorities, billing offices and in the area of IT, office or comparable services, in compliance with the legal requirements.

Consulting

We process the data of our customers, interested parties and other clients or contractual partners in order to be able to provide them with our consulting services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship.

If it is necessary for the fulfillment of our contract, for the protection of vital interests or by law, or if consent has been given, we disclose or transfer the data to third parties or agents, such as authorities, subcontractors or in the area of IT, office or comparable services, in compliance with the legal requirements.

Artistic and literary achievements

We process the data of our clients in order to enable them to select, purchase or commission the selected services or works and associated activities as well as their payment and delivery or execution or provision.

The required information is identified as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for delivery and invoicing as well as contact information in order to be able to hold any consultations.

Management consultancy

We process the data of our customers, interested parties and other clients or contractual partners in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and business relationship.

If it is necessary for the fulfillment of our contract or required by law, or if consent has been given, we disclose or transfer the data to third parties or agents, such as authorities, courts or in the area of IT, office or comparable services, in compliance with the legal requirements.

Events and functions

We process the data of participants in the events, functions and similar activities offered or organized by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and take advantage of the services or promotions associated with participation.

If we process health-related data, religious, political or other special categories of data in this context, this is done in the context of disclosure (e.g. for themed events or for health care, security or with the consent of the data subjects).

The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with legal and contractual requirements.

Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

Special categories of personal data: Health data (Art. 9 para. 1 GDPR); data concerning sex life or sexual orientation (Art. 9 para. 1 GDPR); religious or philosophical beliefs (Art. 9 para. 1 GDPR); data revealing racial or ethnic origin.

Data subjects: Customers; interested parties; business and contractual partners.

Purposes of Processing: Provision of contractual services and customer support; Security measures; Contact requests and communication; Office and organizational procedures; Managing and responding to inquiries.

Legal basis: Fulfilment 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); Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR).

Payment procedure

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively “payment service providers”).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.

Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Contact data (e.g. email, telephone numbers).

Persons affected: Customers; interested parties.

Purposes of processing: Provision of contractual services and customer service.

Legal basis: 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).

Further information on processing operations, procedures and services:

Provision of the online offer and web hosting

In order 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 as part of the provision of the hosting service may include all information relating to the users of our online service that is generated during use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

  • Processed data types: Content data (e.g. entries in online forms); usage data (e.g. websites visited, 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: Provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

  • 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). The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
    The server log files 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, on the other hand, to ensure the utilization of the servers and their stability;  Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Hetzner Online GmbH: Web hosting; Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, represented by Martin Hetzner, Stephan Konvickova, Günther Müller; registered in the Ansbach commercial register, HRB 6089;  Website: https://www.hetzner.com;
    Privacy policy: https://www.hetzner.com/de/legal/privacy-policy.

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular the login information (user name, password and an e-mail address).

As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by e-mail about processes that are relevant to their user account, such as technical changes.

  • Processed data types: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and customer support; Security measures; Managing and responding to inquiries.
  • Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

  • Registration with pseudonyms: Users may use pseudonyms as usernames instead of real names.
  • Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation or user consent.
  • No obligation to retain data: It is the responsibility of users to back up their data if they terminate their contract before it ends. We are entitled to irretrievably delete all user data stored during the term of the contract.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, 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: Provision of contractual services and customer support; Feedback (e.g. collecting feedback via online form); Security measures; Provision of our online services and usability; Managing and responding to inquiries.
  • Legal basis: 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).

Further information on processing operations, procedures and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
    Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies in order to avoid multiple votes. The personal information provided as part of the comments and contributions, any contact and website information as well as the content information will be permanently stored by us until the user objects.
  • Akismet anti-spam check: Akismet anti-spam check – We use the “Akismet” service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this period. This information includes the name entered, the email address, the IP address, the comment content, the referrer, details of the browser used and the computer system and the time of the entry.
    Users are welcome to use pseudonyms or not enter their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a shame, but unfortunately we do not see any alternatives that work just as effectively;  Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; (certified under the EU-U.S. Data Privacy Framework);
    Website: https://automattic.com; Privacy policy: https://automattic.com/privacy
  • Profile pictures from Gravatar: Profile pictures – We use the “Gravatar” service within our online offer and in particular in the blog.
    Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave posts or comments on other online presences (especially in blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of transmitting the e-mail address. It will not be used for any other purpose and will be deleted afterwards. Gravatar is used on the basis of our legitimate interest, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture. By displaying the images, Gravatar learns the IP address of the users, as this is necessary for communication between a browser and an online service.
    If users do not want a user image linked to their email address at Gravatar to appear in the comments, they should use an email address that is not stored at Gravatar to comment. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system;  Service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; (certified under the EU-U.S. Data Privacy Framework, see https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000CbqcAAC&status=Active); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
  • UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd, 11, Barringer Way, St Neots, Cambs, PE19 1LW, UK; Website: https://updraftplus.com/; Privacy Policy: https://updraftplus.com/data-protection-and-privacy-centre/.
  • Wordfence: Firewall and security and error detection functions; Service provider: Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA; Website: https://www.wordfence.com; Privacy Policy: https://www.wordfence.com/privacy-policy/; Data transfer to the USA is based on standard contractual clauses of the EU Commission, see: https://www.wordfence.com/standard-contractual-clauses/.

Contact and inquiry management

When contacting us (e.g. by contact form, email, telephone or via social media) and as part of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact requests and any requested measures.

The response to contact inquiries and the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to inquiries and maintaining user or business relationships.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; provision of contractual services and customer service.
  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR).

Further information on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, email or other communication channels, we process the data provided to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations.

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your options to object.

You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.

However, we would also like to point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and process technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).

Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to Messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.

Reservation of reference to other communication channels: Finally, we would like to point out that we reserve the right not to answer inquiries via Messenger for reasons of your security. This is the case if, for example, internal contractual information requires special confidentiality or a reply via Messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Content data (e.g. entries in online forms).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Video conferences, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the participants’ personal data listed below. The scope of the processing depends on which data is required in the context of a specific conference (e.g. specification of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, the conference platforms may also process participants’ data for security purposes or service optimization. The processed data includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ end devices, their operating system, the browser and its technical and language settings, information on the content of the communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be communicated transparently to the participants in advance and they will be asked for their consent where necessary.

Participants’ data protection measures: Please refer to the conference platforms’ data protection notices for details on the processing of your data by the conference platforms and select the optimum security and data protection settings for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and, if technically possible, using the function to make the background unrecognizable). Links to the conference rooms and access data must not be passed on to unauthorized third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; contact requests and communication; office and organizational procedures.
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Application procedure

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.

In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for the position. On request, we will be happy to provide additional information on what details are required.

If provided, applicants can send us their applications using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.

Applicants are welcome to contact us about how to submit their application or send us their application by post.

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure so that the person responsible or the person concerned can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for the provision of health or social care or treatment or for the management of health or social care systems and services in accordance with Art. 9 para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicant, the deletion will take place after a period of six months at the latest, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax regulations.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.

  • Processed data types: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
  • Persons concerned: Applicants.
  • Purposes of processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. Cloud service providers also process usage data and metadata that they use for security purposes and to optimize their services.

If we use cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on users’ devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).

Notes on legal bases: If we ask for consent to the use of cloud services, the legal basis for processing is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient and secure administrative and collaboration processes)

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Newsletter and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order 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 by the mailing service provider are also logged.

Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: The newsletter is sent on the basis of the recipient’s consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in efficient and secure dispatch. The registration process is recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law.

Contents:

Information about us, our services, promotions and offers.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Meta/communication data (e.g. device information, IP addresses); Usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: direct marketing (e.g. by email or post); provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing operations, procedures and services:

  • Measurement of opening and click rates: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.
    This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
    The measurement of opening rates and click rates as well as the storage of the measurement results in the profiles of the users and their further processing are based on the consent of the users.
    A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted.
  • Prerequisite for the use of free services: Consent to the sending of mailings may be made a condition for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.
  • ActiveCampaign: Email marketing platform; Service provider: ActiveCampaign, Inc, 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA; Website: https://www.activecampaign.com; Privacy Policy: https://www.activecampaign.com/privacy-policy/; Data transfer to the USA is based on standard contractual clauses of the EU Commission, see: https://www.activecampaign.com/legal/newscc.
  • Zapier: Import of e-mail addresses to the shipping service providers used from other platforms or other sources; service provider: Zapier, Inc., 548 Market St, San Francisco, California 94104-5401, USA; (certified under the EU-U.S. Data Privacy Framework, see https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000TNk2AAG&status=Active);
    Website: https://zapier.com; Privacy Policy: https:// zapier.com/privacy

Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Surveys and interviews

The surveys and questionnaires we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the survey to be resumed with the help of a temporary cookie (session cookie)) or if users have given their consent.

Notes on legal bases: If we ask participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of participants’ data is based on our legitimate interests in conducting an objective survey.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Web analysis, monitoring and optimization

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

In addition to web analysis, we may also use test procedures, e.g. to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read out from it. The information collected includes, in particular, websites visited and the elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

  • Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
  • Processed data types: Usage data (e.g. websites visited, 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: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Online marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

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

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

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

In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Event data (Facebook) (“event data” is data that can be transmitted by us to Facebook via Facebook pixels (via apps or in other ways), for example, and relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.).The event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account); contact information (Facebook) (“contact information” is data that (clearly) identifies data subjects, such as names, e-mail addresses and telephone numbers, which are sent to Facebook, e.g. via Facebook pixel or upload for matching purposes for the purpose of creating custom audiences; after matching for the purpose of creating target groups, the contact information is deleted); usage data (e.g. websites visited, 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: remarketing; conversion measurement (measurement of the effectiveness of marketing measures); target group formation; target group formation (determination of target groups relevant for marketing purposes or other output of content); marketing; profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the opt-out options specified for the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are summarized for the respective areas:
    a) Europe:  https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territory: https://optout.aboutads.info.

Further information on processing operations, procedures and services:

  • Meta pixels and target group formation (custom audiences): With the help of the meta pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for Meta to determine the visitors of our online offer as a target group for the display of ads (so-called “Facebook ads”). Accordingly, we use the meta pixel to display the Facebook ads placed by us only to such users on Facebook and within the services of the partners cooperating with Facebook (so-called “audience network”).  https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of the meta pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”);  Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Meta Platforms, Inc, 1 Meta Way, Menlo Park, California 94025-1453 (certified under the EU-U.S. Data Privacy Framework see https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000GnywAAC&status=Active and https://www.facebook.com/privacy/policies/data_privacy_framework);Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy
    The “Facebook-EU Data Transfer Addendum”(https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of order processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the “Facebook Platform Terms of Use”(https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook in the context of ad placement; Further information: The “Data Processing Terms”(https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf of companies in order to provide reports and analyses; Furthermore, the “Addendum for Controllers” applies as an agreement on joint controllership (Art. 26 para. 1 sentence 3 GDPR), which is decisive in the case of the independent processing of event data by Facebook for the purposes of targeting and improving and securing Facebook products.
  • Extended matching for the meta pixel: In addition to the processing of event data in the context of the use of the meta pixel (or comparable functions, e.g. in apps), contact information (data identifying individual persons, such as names, e-mail addresses and telephone numbers) is also collected by Meta within our online offering or transmitted to Meta. The processing of contact information is used to create target groups (so-called “custom audiences”) for the display of content and advertising information based on the presumed interests of users. The collection, transmission and comparison with data available at Meta is not carried out in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, when storing passwords). After the comparison for the purpose of creating target groups, the contact information is deleted. The contact information is processed on the basis of an order processing contract with Meta Platforms Ireland Limited (“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 the transfer of data to the USA, the “Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum. Further information on the processing of contact information can be found in the “Terms of Use for Facebook Business Tools”,  https://www.facebook.com/legal/technology_terms.
  • LinkedIn: Insights tag / conversion measurement; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland; parent company: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; Data transfer to the USA is based on standard contractual clauses of the EU Commission, see: https://www.linkedin.com/legal/l/eu-sccs Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie-Policy: https://www.linkedin.com/legal/cookie_policy; Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Order processing contract: https://legal.linkedin.com/dpa.

Affiliate programs and affiliate links

We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as “affiliate links”) in our online offer. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as “commission”).

In order to be able to track whether the users have taken up the offers of an affiliate link used by us, it is necessary for the respective third-party providers to learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves the sole purpose of commission settlement and is canceled as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented by certain values that are part of the link or can be stored elsewhere, e.g. in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, 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: Affiliate tracking.
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Customer reviews and evaluation process

We participate in review and rating procedures in order to evaluate, optimize and advertise our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers’ data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer’s consent. This data is used solely to verify the authenticity of the user.

  • Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers; users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Presence in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user 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 description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, 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 requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Plugins and embedded functions and content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

  • Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. content data (e.g. entries in online forms); event data (Facebook) (“event data” is data that can be transmitted by us to Meta, e.g. via Meta pixels (via apps or in other ways) and relates to persons or their actions; the data includes, for example The data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Meta after a maximum of two years, the target groups formed from them with the deletion of our Meta account).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; provision of contractual services and customer service; profiles with user-related information (creation of user profiles); marketing.
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Management, organization and support tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

  • Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
  • Processed data types: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services).
  • Purposes of Processing: Contact requests and communication; Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Office and organizational procedures.
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR); Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Further information on processing operations, procedures and services:

Rights of the data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
  • Complaint to a supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are listed in alphabetical order.

  • Affiliate tracking: As part of affiliate tracking, links that the linking websites use to refer users to websites with product or other offers are logged. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as advertising material ID, partner ID and categorizations
  • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them to better adapt the content of the website to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: The term “remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) if the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
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