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

Privacy Policy

Introduction

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

The terms used are not gender-specific.

State: XX.XX.20XX

Please indicate the state of the privacy policy.

Contents overview

Responsible person

First name, last name / Company
Street, house no.
ZIP code, city
Country

E-mail address: your e-mail address

Phone: Your phone number (optional)

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

Notes: Please use the designation „owner“ and not „managing director“ for sole proprietors.

Contact Data Protection Officer

First name, last name / Company
Street, house no.
Zip code, City
Country

Note: Only the e-mail address is mandatory, the other information is optional. Data protection officers must only be specified if they have been appointed. An appointment is according to § 38 BDSG-New already necessary from 20 employees who process personal data (for which practically already an e-mail box is sufficient).

Overview of processing

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

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

Types of data processed

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

Categories of data subjects

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

Purposes of processing

Assessment of creditworthiness and creditworthiness.
Providing our online services and user experience.
Visit action evaluation.
Office and organization procedures.
Cross-device tracking (cross-device processing of user data for marketing purposes).
Direct marketing (e.g., via email or postal mail).
Interest-based and behavioral marketing.
Contact requests and communication.
Conversion measurement (measuring the effectiveness of marketing efforts).
Profiling (creating user profiles).
Remarketing.
Range measurement (e.g. access statistics, recognition of returning visitors).
Security measures.
Tracking (e.g. interest / behavioral profiling, use of cookies).
Provision of contractual services and customer service.
Managing and responding to requests.
Targeting (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions on a case-by-case basis

Credit information (decision based on a credit check).

Relevant legal bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
Contractual performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Rightful interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – Processing is necessary for the purposes of protecting the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security measures

We take appropriate technical and organizational measures in accordance with the law, taking into account the state of the art, the costs of implementation 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, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, ensuring availability and their separation. Furthermore, we have established procedures to ensure the exercise of data subjects‘ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

Note: Remove the reference to encryption if your offer is not encrypted. However, a delivery of the website via https is to be considered mandatory.

Transmission and disclosure of personal data

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

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

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

Within the framework of the so-called „Data Privacy Framework“ (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. We inform you in the context of the data protection information which service providers we use are certified under the Data Privacy Framework.

Use of cookies

Cookies are small text files, or other memory tags, that store information on terminal devices and read information from terminal devices. E.g. to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or used functions of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the user with a telemedia service (i.e. our online offer) expressly requested by them. The revocable consent will be clearly communicated to the users and will contain the information about the respective cookie usage.

Notes on legal bases under data protection law: On which legal basis under data protection law we process users‘ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a 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. For what purposes the cookies are processed by us, we clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Storage period: In terms of storage period, the following types of cookies are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile app).
Permanent cookies:Permanent cookies remain stored even after the terminal 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. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

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

Processing of cookie data based on consent: We use a cookie consent management procedure, in the context of 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 and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side 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: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers) as well as the browser, system and end device used.

Cookie settings/ Cookie Opposition options:

If you use a cookie consent banner (which is recommended), you can enter at this point the possibility to call it (eg link or a so-called [shortcode], which is automatically converted by your software into a button / link).

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

As a cookie opt-in according to the ECJ is usually necessary when using marketing tools frequently used in e-commerce (e.g. Google Analytics or Meta Pixel), this option is preselected.

That is, until users have given their consent, you do not use cookies (and do not use third-party services within your websites, which themselves in turn use cookies). Permissible is at most the use of necessary cookies that are expected by users, such as a shopping cart function in the online store or local reach measurement with the tool Matomo.

Commercial and business services

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

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

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 legal 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). If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect. 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, in short „customer account“). If 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. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the 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 responsibility of customers to back up their data when their customer account is terminated.

Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.

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

Shop and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related 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 to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable acquisition process and includes the information needed for delivery, or provision and billing, as well as contact information, so that any consultation can be held.

Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
People concerned: Interested parties, business and contractual partners, customers.
Purposes of processing: Providing contractual services and customer service, contact requests and communications, office and organizational procedures, managing and responding to requests, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creating user profiles).
Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para 1 p. 1 lit. c. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

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

Payment Service Provider

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers for this purpose 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 the 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 with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.

For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We refer to these likewise for the purpose of further information and assertion of revocation, information and other data subject rights.

Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
People concerned: customers, prospective customers.
Purposes of processing: Provision of contractual services and customer service.
Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Services used and service providers:

PayPal: Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

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

Credit check

Insofar as we enter into advance performance or comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical methods of service companies specializing in this (credit agencies) to protect the legitimate interests.

We process the information received from the credit agencies on the statistical probability of a payment default within the framework of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or other advance performance in the event of a negative result of the credit check.

In accordance with Art. 22 GDPR, the decision as to whether we provide advance performance is made solely on the basis of an automated decision in the individual case, which is made by our software on the basis of the information from the credit agency.

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

Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject of contract, term, customer category).
People concerned: customers, prospects.
Purposes of processing: Assessment of creditworthiness and creditworthiness.
Legal basis: Consent (Art. 6 para 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para 1 p. 1 lit. f. GDPR).
Automated decisions in individual cases: credit information (decision based on a credit check).

Services used and service providers:

Verband der Vereine Creditreform e.V.: credit agency; service provider: Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss, Germany; website: https://www.creditreform.de/; Privacy policy: https://www.creditreform.de/datenschutz.

Note: Remove the credit check passage if you do not perform a credit check. Check and modify the list of service providers if necessary. Checking a customer’s creditworthiness is allowed if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). No payment default threatens, on the other hand, if the customer chooses, for example, the prepayment option or makes the payment via third-party providers, such as Paypal.

It should also be noted that obtaining an automatic credit report is an „Automated decisions in individual cases“ according to Art. 22 GDPR, i.e. a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary, is not yet conclusively clarified, but is often represented as a given, including by the author of this sample.

If you want to exclude any risk, however, you should obtain consent. Consent is also necessary if the credit report is already then used to decide at all whether the option „on account“ should be displayed. This is because it could have been that the customer would have opted for prepayment or Paypal anyway and the credit check would not have been necessary. Such consent could read, for example, as follows:

I agree that a credit check is carried out in order to decide in an automated procedure (Art. 22 GDPR) whether the option of purchase on account is offered. For more information on the credit check, the credit agencies used and the procedure, as well as the objection options, please refer to our [link]Privacy Policy[/link].

Provision of online services and web hosting

In order to provide our Online Offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the Online Offer 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 offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Email sending and hosting: The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each 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, 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 on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability.

Types of data processed: 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).
People Concerned: users (e.g., website visitors, users of online services).
Legal basis: Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Note: If not already done: Please ask the respective web hosts for a so-called „order processing contract“ (or „Data Processing Agreement“). This is required by law, because the hoster collects personal data of website visitors for you.

Contact

When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the requesting persons is processed to the extent necessary to respond to the contact requests and any requested action.

The response to the contact requests in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of legitimate interests in responding to the requests.

Types of data processed: 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).
People concerned: communication partners, interested parties.
Purposes of processing: contact requests and communication, management and response to requests.
Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Services used and service providers:

Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated 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.
Help Scout: Management of contact requests and communications; service provider: Help Scout Inc, 131 Tremont St, Boston, MA 02111-1338, USA; website: https://www.helpscout.net; privacy policy: https://www.helpscout.net/company/legal/privacy/; Basis third country transfer: standard contractual clauses (https://www.helpscout.com/company/legal/dpa/); order processing contract: https://www.helpscout.com/company/legal/dpa/.

Note: If third-party CRM systems are used, their providers should be mentioned. Adjust this information or remove the specified service provider. Furthermore, order processing contracts (or „Data Processing Agreement“) must be concluded with the providers. If the providers process the users‘ data in a third country, special guarantees must be in place (e.g., standard contractual clauses).

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter „newsletter“) only with the consent of the recipients or a legal permission. If, in the context of a registration for the newsletter, its contents are specifically circumscribed, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double-Opt-In-Procedure: The registration for our newsletter takes place in principle in a so-called double-opt-in procedure. That is, you will receive an e-mail after registration, in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data will be 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. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the dispatch of e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases: The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

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

Types of data processed: 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).
People concerned: communication partners.
Purposes of processing: Direct marketing (eg by e-mail or postal).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
Opposition (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent, or object to further receipt. A link to cancel the newsletter you will find either at the end of each newsletter or can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Services used and service providers:

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 or its server, if we use a mailing service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are 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 and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used 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 and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user’s consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);
CleverReach: email marketing platform; service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; website: https://www.cleverreach.com/de; Privacy policy: https://www.cleverreach.com/de/datenschutz/; Order processing agreement: concluded with provider.
Mailchimp: email sending and email marketing platform; service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Order processing contract: https://mailchimp.com/legal/; Basis for third country transfers: Data Privacy Framework, standard contractual clauses (included in the order processing contract); Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Please delete the Newsletter passage if you do not send newsletters. Otherwise, adjust the list of services and providers, as well as the information on the content of the newsletter and performance measurement if necessary.

Web analytics, monitoring and optimization

Web analytics (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 recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

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

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

The IP addresses of users are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users‘ 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 refer you to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
People Concerned: users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavior-based profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

etracker: Web analytics/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy policy: https://www.etracker.com/datenschutz/; Order processing agreement: https://www.etracker.com/av-vertrag/.
Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city’s inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF); Opt-Out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff; Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).

Google as recipient of consent: The consent given by users in the context of a consent dialog (also known as „cookie opt-in/consent“, ‚cookie banner‘, etc.) serves several purposes. On the one hand, it serves to fulfill our obligation to obtain consent to the storage and reading of information on and from the user’s end device (in accordance with ePrivacy guidelines). Secondly, it covers the processing of users‘ personal data in accordance with data protection regulations. In addition, this consent also applies to Google, as the company is obliged under the Digital Markets Act to obtain consent for personalized services. We therefore share the status of the consents given by users with Google. Our consent management software informs Google whether consent has been granted or not. The aim is to ensure that the consents given or not given by users are taken into account when using Google Analytics and when integrating functions and external services. In this way, user consents and their revocation can be dynamically adjusted in the context of Google Analytics and other Google services in our online offering and depending on the user selection; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de; Privacy Policy: https://policies.google.com/privacy.
Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further details in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; order processing agreement:
https://business.safety.google/adsprocessorterms; Basis for third country transfers: Data Privacy Framework, Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which the recognition of returning users is done with the help of a so-called „digital fingerprint“, which is stored anonymously and changed every 24 hours; In the „digital fingerprint“, user movements within our online offer are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings so that conclusions about the identity of individual users are not possible. User data collected through the use of Matomo is processed only by us and is not shared with third parties; website: https://matomo.org/.
Matomo: Matomo is software used for web analytics and reach measurement purposes. As part of the use of Matomo, cookies are generated and stored on the end device of the user. The user data collected as part of the use of Matomo is only processed by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Deletion of data: The cookies have a maximum storage period of 13 months.

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

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or display of promotional and other content (collectively, „content“) based on potential user interests 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 to 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. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

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

Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users with the aforementioned data. We ask to note that users may make additional arrangements with the providers, e.g., by giving consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a 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 will be stored for a period of two years.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical position of a device or a person).
People concerned: users (e.g. website visitors, users of online services), interested parties.
Purposes of processing: Tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g.. e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes)
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
Opposition (Opt-Out): We refer to the data protection notices of the respective providers and the objection options given to the providers (so-called „Opt-Out“). If no explicit opt-out option has been specified, there is on the one hand the possibility that you disable cookies in the settings of your browser. However, this may restrict functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered in summary 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) Inter-territory: https://optout.aboutads.info.

Services used and service providers:

Meta pixel 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 via interfaces in apps), Meta is able to determine the visitors of our online offer as a target group for the display of advertisements (so-called „meta ads“). Accordingly, we use the meta pixel to display the meta ads placed by us only to such users on Meta platforms and within the services of the partners cooperating with Meta (so-called „audience network“ https://www. facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer 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 Meta (so-called „Custom Audiences“). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a meta ad (so-called „conversion measurement“); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience targeting on the basis of the joint controllership agreement („Controller Addendum“, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.
Google Ad Manager: We use the „Google Ad Manager“ service to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for our online offering to users who may have a potential interest in our offering or have previously shown an interest in it, and to measure the success of the ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; where Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
Google Ads and conversion measurement: Online marketing procedures for the purpose of placing content and ads within the service provider’s advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Please delete the passage online marketing if you do not use online marketing tools on your website. Adjust the list of services and providers as needed. Please keep in mind that the use of marketing services on the website usually requires a cookie opt-in.

Presence on social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with 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 the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage 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 usually stored on the users‘ computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements 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 also point out that these can be asserted most effectively with the providers. Only the providers have access to the users‘ data and can take appropriate measures and provide information directly. If you still need help, then you can contact us.

Types of data processed: 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).
People Concerned: users (e.g., website visitors, users of online services).
Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

Instagram: Social network, allows you to share photos and videos, comment and favorite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/; Principle for third country transfers: Data Privacy Framework (DPF).
Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called „fan page“). This data includes information about the types of content users view or interact with, or the actions they take (see under „Things you and others do and provide“ in the Facebook Data Policy: https://www.facebook. com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under „Device information“ in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under „How do we use this information?“, Facebook also collects and uses information to provide analytics services, known as „Page Insights“, for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook („Information on Page Insights“, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the „Information on Page Insights“ (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: Data Privacy Framework (DPF).
LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors that are created for the purpose of creating the „page insights“ (statistics) of our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user’s profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland („Page Insights Joint Controller Addendum (the ‘Addendum’)“, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which in particular concerns the transmission of the data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF); Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Pinterest: Social network; Service provider: Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA; website: https://www.pinterest.com; Privacy Policy: https://about.pinterest.com/de/privacy-policy; Additional Information: Pinterest Data Sharing Appendix (APPENDIX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
TikTok: Social network/video platform; Service provider: musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy.
X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com; Privacy Policy: https://x.com/de/privacy.
YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy; Option to object (opt-out): https://adssettings.google.com/authenticated; Basis third country transfer: Data Privacy Framework.
Xing: Social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Adjust the list of social networks as needed.

Plugins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functionality. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. The „pixel tags“ 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 be linked to such information from other sources.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
People concerned: users (e.g. website visitors, users of online services), communication partners.
Purposes of processing: Provision of our online offer and user experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, management and response to requests.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services used and service providers:

Facebook plugins and content: Facebook social plugins and content – This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook. com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of „event data“ that Facebook collects or receives in the context of a transmission by means of the Facebook social plugins (and content embedding functions) that are executed on our online offer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via the Facebook social plugins). (e.g. addressing users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook („Addendum for data controllers“, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement („Data Processing Terms“, https://www.facebook.com/legal/terms/dataprocessing) the „Data Security Terms“ (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses („Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: Data Privacy Framework (DPF).
Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA – When visiting our online offer, users‘ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts „Analytics“ page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to place targeted ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

Google Maps: We integrate the maps of the „Google Maps“ service of the provider Google. The processed data may include, in particular, IP addresses and location data of the users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF).
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Opt-out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Vimeo video player: Integration of a video player; service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://vimeo.com; Privacy Policy: https://vimeo.com/privacy; Data processing agreement: https://vimeo.com/enterpriseterms/dpa; Basis for third country transfers: Standard Contractual Clauses (https://vimeo.com/enterpriseterms/dpa).

Please delete the passage plugins and embedded functions as well as content if you do not use plugins or embedded functions as well as content within your website. Otherwise, adjust the list of services and providers if necessary.

Deletion of data

The data processed by us will be deleted in accordance with legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (for example, if the purpose of processing this data has ceased to apply or it is not necessary for the purpose).

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

Further information on the deletion of personal data can further be provided in the context of the individual data protection notices of this privacy policy.

Change and update privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy statement as soon as the changes in the data processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the persons concerned

As a data subject, you are entitled to various rights under the GDPR, arising in particular from Articles 15 to 21 of the GDPR:

Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
Right of revocation for consents: You have the right to revoke granted consents at any time.
Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: You have the right, in accordance with the law, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: You have, in accordance with the law, the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with the law, to request restriction of the processing of the data.
Right to data portability: You have the right to receive data relating to you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
Complaint to supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

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 defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

Visit action evaluation: „Visit action evaluation“ (English „conversion tracking“) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users‘ devices 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 have placed on other websites have been successful).
Credit information: Automated decisions are based on automatic data processing without human intervention (for example, in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. Such automated decisions are only allowed under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract, or if national laws allow such decisions.
Cross-device tracking: Cross-device tracking is a form of tracking in which users‘ behavioral and interest information is collected across devices in so-called profiles by assigning users to an online identifier. This allows user information to be analyzed for marketing purposes, irrespective of the browsers or devices used (e.g. cell phones or desktop computers). For most providers, the online identifier is not linked to clear data, such as names, postal addresses or e-mail addresses.
IP masking: „IP masking“ is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
Interest-based and behavioral marketing: We speak of interest-based and/or behavioral marketing when potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (eg visiting certain websites and stay on them, buying behavior or interaction with other users), which are stored in a so-called profile. Cookies are usually used for these purposes.
Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users‘ devices 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 have placed on other websites have been successful.
Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (eg. e.g. cookie) or to one or more particular characteristics that are an expression of that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.
Profiling: „Profiling“ is any form of automated processing of personal data that consists of using such personal data to analyze, evaluate or, in order to predict (e.g., the interests in certain content or the use of certain services), certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people). 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.
Range measurement: Range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include the behavior or interests of visitors in certain information, such as content of web pages. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. 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 offering.
Remarketing: One speaks of „remarketing“ or „retargeting“ when, for example, for advertising purposes, it is noted which products a user has been interested in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
Location data: Location data is created when a mobile device (or other device with the technical requirements of a location determination) connects to a radio cell, a WLAN or similar technical mediators and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
Tracking: One speaks of „tracking“ when the behavior of users can be traced across several online offers. As a rule, with regard to the online offers used, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: A „controller“ is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: „Processing“ means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
Target group formation: One speaks of target group formation (or „Custom Audiences“) when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on the interest of a user 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 he viewed the products. In turn, we speak of „lookalike audiences“ (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. For purposes of the formation of Custom Audiences and Lookalike Audiences are usually used cookies and web beacons.

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Privacy Policy

Introduction

Contents overview

Responsible person

Contact Data Protection Officer

Overview of processing

Types of data processed

Categories of data subjects

Purposes of processing

Automated decisions on a case-by-case basis

Relevant legal bases

Security measures

Transmission and disclosure of personal data

Data processing in third countries

Use of cookies

Commercial and business services

Payment Service Provider

Credit check

Provision of online services and web hosting

Contact

Newsletters and electronic notifications

Web analytics, monitoring and optimization

Online marketing

Presence on social networks (social media)

Plugins and embedded functions and content

Deletion of data

Change and update privacy policy

Rights of the persons concerned

Definitions of terms

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