Privacy policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent in the context of providing our application.

The terms used are not gender-specific.

Status: September 16, 2025

Table of contents

• Preamble
• Person responsible
• Contact data protection officer
• Overview of processing
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• General information on data storage and deletion
• Rights of the data subjects
• Consent to the use of the customer’s or registered person’s data for language examinations and language courses as well as further education and retraining offers
• Business services
• Business processes and procedures
• Use of online platforms for offer and sales purposes
• Providers and services used in the course of business activities
• Payment procedure
• Provision of the online offer and web hosting
• Use of cookies
• Processing of data within the scope of the application (app)
• Registration, login and user account
• Community functions
• Single sign-on login
• Contact and request management
• Communication via Messenger
• Chatbots and chat functions
• Push messages
• Artificial intelligence (AI)
• Video conferences, online meetings, webinars and screen sharing
• Cloud services
• Newsletter and electronic notifications
• Advertising communication via e-mail, post, fax or telephone
• Competitions and contests
• Surveys and interviews
• Web analysis, monitoring and optimization
• Online marketing
• Affiliate programs and affiliate links
• Offer of an affiliate program
• Customer reviews and evaluation process
• Presence in social networks (social media)
• Plug-ins and embedded functions and content
• Processing of data in the context of employment relationships
• Application procedure
• Data protection information for whistleblowers
• Whistleblower systems
• Change and update
• Definitions of terms

Person responsible

IEC – International Education Centers GmbH
Lise-Meitner-Straße 5-9
42119 Wuppertal

Commercial register: HRB 26351 Register court: Amtsgericht Wuppertal

Phone: +49 (0) 202 261 58 77 0
E-mail: dataprivacy@internationaleducationcenters.de

Persons authorized to represent the company: Dipl. Business mathematician Yasemin Sahin

E-mail address: dataprivacy@internationaleducationcenters.de

Phone: +49 (202) 261 58 77 0

Imprint: https://internationaleducationcenters.de/impressum/

Contact data protection officer

RECHTSANWALT DOMINIK J. FISCHER
also a specialist lawyer for information technology law

Contact

Lise-Meitner-Straße 1-3
42119 Wuppertal
Germany


Phone: + 49 202 695 779 00
Fax: + 49 202 695 779 01

E-mail: info@DIREKTKANZLEI.de

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.
• Employee data.
• Payment data.
• Location data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and process data.
• Social data.
• Applicant data.
• Image and/or video recordings.
• Sound recordings.
• Event data (Facebook).
• Log data.
• Performance and behavior data.
• Working time data.
• Salary data.

Special categories of data

• Health data.
• Religious or philosophical beliefs.
• Trade union membership.

Categories of affected persons

• Beneficiaries and clients.
• Employees.
• Interested parties.
• Communication partners.
• Users.
• Applicants.
• Competition and contest participants.
• Members.
• Business and contractual partners.
• Education and course participants.
• Participants.
• Persons depicted.
• Third parties.
• Whistleblowers.
• Customers.

Purposes of the processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Safety measures.
• Direct marketing.
• Reach measurement.
• Tracking.
• Office and organizational procedures.
• Remarketing.
• Conversion measurement.
• Target group formation.
• Affiliate tracking.
• Organizational and administrative procedures.
• Application procedure.
• Organizing competitions and contests.
• Feedback.
• Surveys and questionnaires.
• Marketing.
• Profiles with user-related information.
• Application procedure.
• Provision of our online services and user-friendliness.
• Establishment and implementation of employment relationships.
• Information technology infrastructure.
• Whistleblower protection.
• Financial and payment management.
• Public relations.
• Sales promotion.
• Business processes and business management procedures.
• Artificial intelligence (AI).

Relevant legal bases

Relevant legal bases according to the GDPR: 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. 6 para. 1 sentence 1 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.
• Processing of special categories of personal data relating to health care, employment and social security (Art. 9 para. 2 lit. h) GDPR) – Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, the provision of health or social care or treatment or for the management of health or social care systems and services on the basis of Union or Member State law or on the basis of a contract with a health professional.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.

Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data”, “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

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 through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is truncated (also known as “IP masking”). The last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or make it significantly more difficult to identify a person by their IP address.

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

Transmission of personal data

As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the group of companies: Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to it. This data transfer takes place on the basis of our legitimate business and commercial interests. This includes, for example, improving business processes, ensuring efficient and effective internal communication, optimizing the use of our human and technological resources and enabling us to make informed business decisions. In certain cases, the transfer of data may also be necessary in order to fulfill our contractual obligations, or it may be based on the consent of the data subject or legal permission.

Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which can be recognized by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and define contractual obligations to protect your data.

This dual protection ensures comprehensive protection of your data: The DPF forms the primary layer of protection, while the Standard Contractual Clauses serve as additional security. Should there be any changes to the DPF, the standard contractual clauses act as a reliable fall-back option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.

For the individual service providers, we will inform you whether they are certified in accordance with the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate security measures apply, in particular standard contractual clauses, explicit consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive. We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.

Retention and deletion of data: The following general time limits apply to retention and archiving under German law:

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. Para. 3 AO, § 14b Para. 1 UStG, § 257 Para. 1 No. 1 i.V.m. para. 4 HGB).
• 8 years – Accounting documents, such as invoices and expense receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. para. 4 HGB).
• 6 years – Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents, insofar as they are relevant for taxation, e.g. time sheets, company accounting sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting documents and cash register slips (Section 147 (1) nos. 2, 3, 5 in conjunction with (3) AO). Para. 3 AO, § 257 Para. 1 No. 2 and 3 in conjunction with Para. para. 4 HGB).
• 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on past business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Period begins at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it automatically begins 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 deadline is the date on which the termination or other termination of the legal relationship takes effect.

Rights of the data subjects

Rights of data subjects under the GDPR: 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 Article 6 (1) GDPR. 1 lit. e or f GDPR; this also applies to profiling based on these 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.

Consent to the use of the customer’s or registered person’s data for language examinations and language courses as well as further education and retraining offers

IEC – International Education Centers GmbH collects and uses the personal data of the customer or the registered person provided upon conclusion of the contract in compliance with the applicable data protection regulations. Personal data is used for the purpose of processing the existing contractual relationship with the customer. The customer expressly consents to this collection, processing and use of their personal data. The collection, processing and use of the personal data of the customer or the registered person is carried out in compliance with the Federal Data Protection Act (BDSG) and the Telemedia Act (TMG).

IEC-International Education Centers GmbH requires the name and address of the customer in order to know who the contractual partner is, i.e. to whom the services are to be provided and invoiced;

The name and address of the registered person is required in order to know in whose favor the contract is concluded, i.e. who is participating in the booked service;

The contact details (e-mail address and telephone number) are required for any queries that may arise. They are also used to receive information and news, offers or other marketing measures, provided the customer has consented to this;

The account details are required in order to be able to collect the agreed fees if the customer has issued a SEPA direct debit mandate

The following applies to language examinations and language courses: IEC – International Education Centers GmbH is entitled to store and process the personal data of the examination participant collected during registration for the purpose of processing the examination in compliance with the applicable data protection regulations. The IEC – International Education Centers GmbH reserves the right to use personal data of examination participants for internal purposes (e.g. statistical evaluations). The data will not be passed on to third parties unless they are public authorities or test providers involved in the service used.

These are, for example, BAMF, immigration authorities, test providers such as telc gGmbH, ETS, LTS, g.a.s.t.

The training provider respects the personal rights of the participants. The participant is hereby informed in accordance with §33 of the Federal Data Protection Act that the training provider collects, stores, processes and uses personal data electronically as part of the implementation of the measures. He/she agrees to the automated processing of personal data for the purposes of conducting the course and examination at the competent authority and for subsequent information. The educational institution collects, processes and uses data only in accordance with the relevant data protection regulations to fulfill the purpose of the contract and only to the extent necessary. All employees of the training provider are obliged to maintain data confidentiality.

Privacy policy for the use of the INGE system (BAMF)

As part of our activities as a provider of integration courses in accordance with the Integration Course Ordinance (IntV), we use the INGE-Online IT system of the Federal Office for Migration and Refugees (BAMF) for electronic data transmission and processing.

Responsible body

Responsible for data processing in connection with INGE is: Federal Office for Migration and Refugees (BAMF)

Frankenstrasse 210

90461 Nuremberg

Telephone: 0911 943-0

E-mail: datenschutz@bamf.bund.de

Purpose of data processing

Personal data is processed for the purpose of conducting and managing integration courses. This includes in particular

Collection and transmission of participant data (e.g. name, date of birth, eligibility to participate)

Course organization and documentation

Communication with immigration authorities, test institutes and other bodies involved in the process

Data processing is carried out in accordance with Art. 6 para. 1 lit. c GDPR in conjunction with § 20 IntV.

Type of data processed

In particular, the following data is processed

Master data of the participants

Course dates (e.g. course start, course end, course type)

Test results and certificates of attendance

Forwarding of the data

The data is transmitted exclusively to the bodies involved in the procedure, including

BAMF

Immigration authorities

test institutes

Basic security institutions

Federal Office of Administration

The data will not be passed on to uninvolved third parties.

Security and access

Data is transmitted via secure interfaces in accordance with the technical specifications of the BAMF. For data protection reasons, changes to transmitted data can only be made by the BAMF.

Rights of data subjects

Data subjects have the right to

Information about the stored data (Art. 15 GDPR)

Correction of incorrect data (Art. 16 GDPR)

Erasure, provided there is no legal obligation to retain data (Art. 17 GDPR)

Restriction of processing (Art. 18 GDPR)

Objection to the processing (Art. 21 GDPR)

Inquiries can be addressed directly to the BAMF or to our data protection officers.

As part of our continuing education and retraining measures, we use digital systems in cooperation with the Institute for Vocational Education and Training (IBB) for counseling, course administration and learning support. In particular, this includes the ILIAS learning platform and the Profiles III course planner.

Purpose of data processing

Personal data is processed for the following purposes

Advise participants on available courses and course content

Managing course registrations, course progression and certificates

Provision of digital learning content via ILIAS

Organization and documentation of further education measures via Profiles III

Legal basis

Data processing is carried out in accordance with:

Art. 6 para. 1 lit. b GDPR (fulfillment of contract)

Art. 6 para. 1 lit. f GDPR (legitimate interest in efficient course organization and learning support)

Type of data processed

In particular, the following data is processed

Master data (name, e-mail address, telephone number)

Course data (participation, progress, certificates)

Communication data (messages, forum posts)

Usage data (login times, access to learning content)

Recipients of the data

The data is processed exclusively within the participating organizations (us as the training provider and IBB). Data will only be passed on to third parties if required by law or with the express consent of the data subject.

Storage and deletion

Personal data will only be stored for as long as is necessary for the implementation of the training measure. After completion of the measure, the statutory retention periods apply. Data from ILIAS and Profiles III will be anonymized or deleted in accordance with the respective deletion periods.

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 related measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to inquiries.

We use this data 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 use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business 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. to involve 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, such as 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 four 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 ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Affected persons: Service recipients and clients; interested parties; business and contractual partners. Education and course participants.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Online store, order forms, e-commerce and service fulfillment: 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 provision, 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. 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 consultation; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Education and training services: We process the data of participants in our education and training services (uniformly referred to as “trainees”) in order to be able to provide them with our training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of our instructors. As part of our activities, we may also process special categories of data, in particular information on the health of trainees and students as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. Where necessary, we obtain the express consent of the trainees for this purpose and otherwise only process the special categories of data if it is necessary for the provision of training services, for the purposes of health care, social protection or the protection of vital interests of the trainees; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• LanguageTool: AI-powered grammar and spell checking tool that uses advanced algorithms to analyze texts in different languages and make correction suggestions; Service provider: LanguageTooler GmbH; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://languagetool.org/. Privacy policy: https://languagetool.org/legal/privacy.

Business processes and procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected is used to fulfill contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organization of the company.

Personal data may be passed on to third parties if this is necessary to fulfill the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
• Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; customers; third parties; users (e.g. website visitors, users of online services). Employees (e.g. employees, applicants, temporary staff and other employees).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures; business processes and business management procedures; security measures; provision of our online offer and user-friendliness; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• 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 management and maintenance: Procedures required to organize, maintain and secure contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adapting contact strategies); Legal bases: 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).
• Customer account: Customers can create an account within our online offering (e.g. customer or user account, “customer account” for short). If it is necessary to register a customer account, customers will be informed of this and 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 the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is stored for purposes other than provision in the customer account or must be stored for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer’s responsibility to back up their data when the customer account is terminated; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Wish list: Customers can create a product/wish list. In this case, the products will be stored as part of the fulfillment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Customer loyalty program/ customer card: As part of the customer loyalty program, the controller processes the data of participating customers for the purpose of providing the services offered under this program. For this purpose, the controller stores the information provided by the customers in a customer profile, where necessary and identified as such. Within this profile, information about the use of the customer loyalty program and the use of the associated services and benefits is also processed. This information is only passed on to third parties (e.g. service providers) if this is necessary for the aforementioned purposes. The customer profiles are deleted after participation in the program has ended. The respective data is only archived to the extent that this may be necessary for statutory retention purposes or for the fulfillment of legal (up to eleven years from the end of the year in which it was created in the case of tax information) or contractual claims (up to three years from the end of the year of termination). This is recorded in the list of processing activities; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts and the control of payment flows (e.g. creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. creating and checking incoming and outgoing invoices, monitoring and managing open items, carrying out payment transactions, processing dunning procedures, reconciling accounts in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Financial accounting and taxes: Procedures required for the recording, administration and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of taxes); Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Purchasing: Procedures required for the procurement of goods, raw materials or services (e.g. supplier selection and evaluation, price negotiations, order placement and monitoring, verification and control of deliveries, invoice verification, administration of orders, warehouse management, creation and maintenance of purchasing guidelines); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Guest Wi-Fi: Procedures necessary for the establishment, operation, maintenance and monitoring of a wireless network for guests (e.g. installation and configuration of Wi-Fi access points, creation and management of guest access points, monitoring of the network connection, ensuring network security, troubleshooting connection problems, updating network software, compliance with data protection regulations); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of online platforms for offer and sales purposes

We offer our services on online platforms that are operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms to measure reach and for interest-based marketing.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and duration of visits, clicks, usage intensity and frequency, device types and operating systems used, interactions with content). contract object, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data); data on the use of the website (e.g. IP addresses, time stamps). (e.g. IP addresses, time data, identification numbers, persons involved); employee data (information on employees and other persons in an employment relationship); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Location data (information on the geographical position of a device or person).
• Data subjects: Service recipients and clients; business and contractual partners; users (e.g. website visitors, users of online services); communication partners; third parties. Interested parties.
• Purposes of Processing: Provision of contractual services and fulfillment of contractual obligations; Marketing; Business processes and procedures; Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behavior, use of cookies); Remarketing; Profiles with user-related information (Creating user profiles); Provision of our online services and user-friendliness; Organizational and administrative procedures; Information technology purposes. interest/behavioural profiling, use of cookies); remarketing; profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; organizational and administrative procedures; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); conversion measurement (e.g. access statistics, recognition of returning visitors).); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; communication; office and organizational procedures; artificial intelligence (AI); surveys and questionnaires (e.g. surveys with input options, multiple-choice questions). Security measures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: 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). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

• Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that allows users who use an online service to be added to a pseudonymous remarketing list so that users can be shown ads on other online offers based on their visit to the online service; 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; 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.
• 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 e-mail 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 offer 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 can 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), Standard Contractual Clauses(https://business.safety.google/adsprocessorterms); Opt-Out: Opt-out plugin: 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 Form: Creation and evaluation of online forms, surveys, feedback forms, etc.; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de/intl/de/forms; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://cloud.google.com/terms/eu-model-contract-clause).
• Google Workspace APIs: We use the Google Workspace APIs to provide our services in accordance with the order or contract and for organizational and communication purposes. An API (Application Programming Interface) is an interface that enables applications to communicate with each other and exchange data. The Google Workspace APIs enable access to functions and data from Google services such as Gmail, Calendar, Drive and others. As part of the use of Google Workspace APIs, personal data of our customers, employees or users as well as third parties may be collected, stored and processed if this is necessary for the aforementioned purposes. This may include, for example, emails, calendar entries, files, documents and associated metadata as well as user information such as name, email address and authorizations. The data received and processed via the Google Workspace APIs is not used to develop, improve or train general AI or ML (artificial intelligence or machine learning) models; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://developers.google.com/workspace/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.
• Google Translate: Translation of content and input into other languages; 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://translate.google.com/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://cloud.google.com/terms/eu-model-contract-clause).
• Google Tag Manager (server-side use): Google Tag Manager is an application with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (see also the further information in this privacy policy). The Tag Manager itself (which implements the tags) does not store any user profiles or cookies. The other services are integrated on the server side. This means that user data is not transmitted directly from their end device to the respective service or Google. In particular, the user’s IP address is not transmitted to the other service. Instead, the data is first transmitted to our server, where the user’s data records are assigned to our internal user identification number. The subsequent transmission of the data from our server to the servers of the respective service providers only takes place in this pseudonymized form. The user identification number does not contain any unique data, such as names or email addresses; 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/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://business.safety.google/adsprocessorterms//). Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).
• Google Podcasts: Podcast hosting and statistical analysis of podcast views; 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://music.youtube.com/googlepodcasts. Privacy Policy: https://policies.google.com/privacy.
• Google Search Ads 360: Search management platform that allows agencies and advertisers to manage and target search marketing campaigns across multiple search engines and media channels; 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/search-ads-360/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://business.safety.google/adsprocessorterms/). Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).
• Google Signals (Google Analytics function): Google signals are session data from websites and apps that Google associates with users who have signed in to their Google accounts and enabled ad personalization. This association of data with these logged-in users is used to enable cross-device reporting, cross-device remarketing and cross-device conversion measurement. This includes: Cross-platform reporting – linking data about devices and activity from different sessions using your User ID or Google Signals data, enabling an understanding of user behavior at each step of the conversion process, from first contact to conversion and beyond; Remarketing with Google Analytics – creating remarketing audiences from Google Analytics data and sharing these audiences with linked advertising accounts; Demographics and interests – Google Analytics collects additional information about demographics and interests from users who are logged into their Google accounts and have ad personalization enabled; 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/7532985?hl=de; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://business.safety.google/adsprocessorterms). Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).
• Google Single Sign-On: Authentication services for user logins, provision of single sign-on features, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Possibility of objection (opt-out): Settings for the display of advertisements: https://myadcenter.google.com/.
• Google Sites: Creation of websites and web hosting (provision of storage space and computer capacity); 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://workspace.google.com/products/sites/; Privacy Policy: https://cloud.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.
• Google Looker Studio: Creation of interactive reports and dashboards, linking of different data sources, visualization of data through charts and graphs, real-time data synchronization, sharing of reports with other users, customization of report layouts and designs; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://cloud.google.com/looker-studio?hl=de; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://cloud.google.com/terms/eu-model-contract-clause).
• Google Calendar: Software for the planning and management of appointments, with functions for payment processing, customer management and interfaces for integration with external calendars and online platforms; 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://calendar.google.com; Privacy Policy: https://policies.google.com/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
• Google Hosted Libraries: Google Hosted Libraries is a globally available content delivery network (CDN) for the most popular open source JavaScript libraries. These are used to provide web libraries to optimize website load times, reduce bandwidth usage and improve performance by using shared, public resources; 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://developers.google.com/speed/libraries/. Privacy Policy: https://policies.google.com/privacy.
• Google Gemini API: Interface access (so-called “API”) to AI-based services designed to understand and generate natural language and related inputs, analyze information and make predictions (“AI”, i.e. “Artificial Intelligence”, is to be understood in the applicable legal sense of the term). The provision of the AI Services includes the processing (including collection, storage, organization and structuring) of personal data as part of a natural language based machine learning process; the performance of activities to verify or maintain the quality of the Services; the identification and correction of errors that affect the existing intended functionality and support to ensure the security and integrity of the AI Services; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Privacy Policy: https://cloud.google.com/; Data Processing Agreement: https://business.safety.google/processorterms/?hl=de. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://business.safety.google/processorterms/?hl=de).
• Google Gemini: AI-powered system designed to provide advanced speech and image processing capabilities. It uses machine learning to understand and generate natural language and analyze images, thus offering versatile application possibilities in various areas; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/processorterms/?hl=de. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://business.safety.google/processorterms/?hl=de).
• Microsoft 365 Outlook: Use of email and calendar functions for communication and organization of meetings. Contact data (name, email address), content data (messages, attachments, meeting content) and metadata are processed for purposes and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication and integration with M365. Retention of emails and calendar entries is based on the guidelines defined by the administrator or user; there is no automatic deletion by default. Mailboxes and calendars are usually removed 30 days after retirement. In addition, diagnostic data is collected for product stability and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Microsoft 365 and Microsoft cloud services: Provision of applications, protection of data and IT systems and use of system-generated log, diagnostic and metadata for contract execution by Microsoft. Contact data (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe) and log and metadata are processed. Processing is carried out for the purposes of increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, integration of Microsoft services, IT security and Microsoft business processing. The storage of data is based on the respective documents and company guidelines, up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. In addition, diagnostic data is collected for product stability and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Microsoft Advertising: Online marketing process 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 conversion). However, we only receive anonymous information and no personal information about individual users; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, 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://about.ads.microsoft.com/en-us; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Basis for third country transfers: Data Privacy Framework (DPF). Option to object (opt-out): https://account.microsoft.com/privacy/ad-settings/.
• Microsoft Azure OpenAI Service: Interface access (so-called “API”) to AI-based services designed to understand and generate natural language and related inputs, analyze information and make predictions (“AI”, i.e. “Artificial Intelligence”, is to be understood in the applicable legal sense of the term). The provision of the AI Services includes the processing (including collection, storage, organization and structuring) of personal data as part of a natural language based machine learning process; the performance of activities to verify or maintain the quality of the Services; the identification and correction of errors that affect the existing intended functionality and support to ensure the security and integrity of the AI Services; Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://azure.microsoft.com/de-de/products/ai-services/openai-service; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://azure.microsoft.com/de-de/support/legal/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses(https://azure.microsoft.com/de-de/support/legal/).
• Microsoft Bookings: Online appointment scheduling and appointment management; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365/business/scheduling-and-booking-app; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement. Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
• Microsoft Clarity: Web analytics, reach measurement and analysis of user behavior in terms of usage and interests regarding functions and content as well as their duration of use on the basis of a pseudonymous user identification number and profiling; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://clarity.microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://privacy.microsoft.com/en-us/privacystatement).
• Microsoft Dynamics: Customer relationship management, financial planning and analysis, supply chain operations, business process automation, human resource management and service optimization; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/dynamics-365; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: Provided by the service provider. Basis for third country transfers: Data Privacy Framework (DPF).
• Microsoft EU Data Boundary: Our use of Microsoft cloud services takes place within the framework of the so-called “EU Data Boundary” (also referred to as the “EU Data Boundary”), which ensures that data is stored and processed within the European Union (EU) and the European Free Trade Association (EFTA).
  
  The EU Data Boundary is a defined region where Microsoft commits to store and process customer data and personal data for certain online services (Microsoft 365, Azure, Dynamics 365 and the Power Platform). Companies using these services can ensure that their data remains within the EU/EFTA region. This includes both general customer data and support data that is generated as part of technical services. In many cases, pseudonymized data is also processed within this region.
  
  The EU Data Boundary includes all EU countries as well as the EFTA states (Liechtenstein, Iceland, Norway and Switzerland). Microsoft operates data centers in several of these countries, including Germany, France, Ireland, the Netherlands, Sweden, Spain and Switzerland. Further locations may be added.
  
  Microsoft automatically creates logs as part of its operations to ensure the security and functionality of its services. These logs mainly contain technical information, but may also include personal data in certain cases, e.g. when user actions are documented.
  
  To protect this data, Microsoft uses techniques such as encryption, masking and tokenization (replacing sensitive data with untraceable character strings). This ensures that Microsoft employees only see pseudonymized data and cannot draw any direct conclusions about individual users. There are also strict access rules and deletion periods for this data.
  
  Microsoft has given assurances that data transfers outside the EU will only take place in a few, precisely defined cases. This may be necessary, for example, to implement global cyber security measures or to ensure the functionality of cloud services. These transfers always take place under high security standards such as encryption and pseudonymization.
  
  Further information on the EU Data Boundary and Microsoft’s data protection measures can be found in the Microsoft EU Data Boundary Trust Center: https://www.microsoft.com/en-us/trust-center/privacy/eu-data-boundary.
• Microsoft Forms: Creation of online forms, collection of responses in real time, analysis of results with integrated diagrams. Integration with other Office applications for further data processing. Customizable forms with different question types and answer options as well as export of data; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://forms.office.com/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Microsoft Single Sign-On: Authentication services for user logins, provision of single sign-on features, management of identity information and application integrations; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/security/business/identity-access/azure-active-directory-single-sign-on; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://www.microsoft.com/de-de/trust-center.
• Microsoft Store: App and software sales platform; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/store/b/sale; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF).
• Online courses and online training: We process the data of participants in our online courses and online training courses (uniformly referred to as “participants”) in order to be able to provide them with our course and training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services used and, if part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance assessment and evaluation of our services and those of the course and training instructors. In addition, depending on the equipment and structure of the respective courses or learning content, further processing processes may be implemented, such as attendance tracking to document participation, progress monitoring to measure and analyze learning progress by collecting examination and test results, and analysis of interactions in learning platforms, such as forum posts and task submissions; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Online store, order forms, e-commerce and service fulfillment: 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 provision, 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. 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 consultation; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Providers and services used in the course of business activities

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
• Affected persons: Service recipients and clients; interested parties; business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other employees).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures. Business processes and business management procedures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• DATEV: Software for accounting, communication with tax advisors and authorities and with document storage; Service provider: DATEV eG, Paumgartnerstr. 6 – 14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/; Privacy Policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/. Data processing agreement: Provided by the service provider.

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. full name, residential address, contact information, customer number, etc.); 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. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Affected persons: Service recipients and clients; business and contractual partners; interested parties. Communication partners.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; business processes and business management procedures; communication. Office and organizational procedures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Amazon Payments: Payment services (technical connection of online payment methods); Service provider: Amazon Payments Europe S.C.A. 38 avenue J.F. Kennedy, L-1855 Luxembourg; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://pay.amazon.de/. Privacy Policy: https://pay.amazon.de/help/201212490.
• American Express: Payment services (technical connection of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.americanexpress.com/de/. Privacy Policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/.
• Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
• Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://pay.google.com/intl/de_de/about/. Privacy Policy: https://policies.google.com/privacy.
• Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy Policy: https://www.klarna.com/de/datenschutz.
• Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
• Mollie: Payment services (technical connection of online payment methods); Service provider: Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, Netherlands; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mollie.com/de. Privacy Policy: https://www.mollie.com/de/privacy.
• PayPal: Payment services (technical connection of online payment methods) (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; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
• Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
• Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
• iDEAL: Payment services (technical connection of online payment methods); Service provider: Currence Holding B.V., Beethovenstraat 300 Amsterdam, 1077, Netherlands; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.ideal.nl/. Privacy Policy: https://www.ideal.nl/en/disclaimer-privacy-statement/.
• Microsoft Teams: Use for holding online events, conferences and communication with internal and external participants. Voice transmission, direct messages, group communication and collaboration functions are used; name, business contact details, work profile, participation and content (audio/video, voice, chat, files, voice transcription) are processed for purposes and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and business processing by Microsoft. Audio signals are generally not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is saved according to the guidelines specified by the administrator or user; no automatic deletion is set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata is processed and diagnostic data is collected for product stability, security and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Microsoft Bookings: Online appointment scheduling and appointment management; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365/business/scheduling-and-booking-app; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement. Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
• SOFORT: Payment services (technical connection of online payment methods); Service provider: Sofort GmbH, Theresienhöhe 12, 80339 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.sofort.com/de/. Privacy Policy: https://www.sofort.com/de/datenschutzhinweise/.
• SumUp Payment Services: Payment services (payment links, card terminals and POS systems, transaction management); Service provider: SumUp Limited, Block 8, Harcourt Centre, Charlotte Way, Dublin 2, Ireland D02 K580; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.sumup.com/de-de/. Privacy Policy: https://sumup.de/datenschutzbestimmungen/.
• Przelewy24: Payment services (technical connection of online payment methods); Service provider: PayPro SA, ul. Kanclerska 15, 60-327 Poznan, Poland; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.przelewy24.pl/en. Privacy Policy: https://www.przelewy24.pl/en/information-obligation-gdpr-payer.

Provision of the online offer and web hosting

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

• Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Provision of contractual services and fulfillment of contractual obligations.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of 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 can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
• 1&1 IONOS: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/vereinbarung-zur-auftragsverarbeitung-avv-mit-ionos-abschliessen/.
• Plesk: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Plesk International GmbH, Vordergasse 59, 8200 Schaffhausen, Switzerland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.parallels.com/; Privacy Policy: https://www.plesk.com/legal/#privacy-policy. Data processing agreement: Provided by the service provider.

Use of cookies

The term “cookies” refers to functions that store information on users’ end devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user’s consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope and which cookies are used.

Information on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage 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 log-in status can be saved and 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), they should assume that they are permanent and that they may be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

• Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online services and user-friendliness.
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users’ end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Cookie opt-out: In the footer of our website you will find a link that you can use to change your cookie settings and revoke your consent.
• Cookiebot: Consent management: Process for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies to store, read and process information on users’ end devices and their processing; Service provider: Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/de; Privacy Policy: https://www.cookiebot.com/de/privacy-policy/; Data processing agreement: Provided by the service provider; Additional information: Stored data (on the server of the service provider): The user’s IP number in anonymized form (the last three digits are set to 0), the date and time of consent, browser details, the URL from which the consent was sent, An anonymous, random and encrypted key value. the user’s consent status.

Processing of data within the scope of the application (app)

We process the data of users of our application to the extent necessary to provide users with the application and its functionalities, to monitor its security and to develop it further. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administration or use of the application. Otherwise, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal basis: The processing of data required to provide the functionalities of the application serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); payment data (e.g. bank details, invoices, payment history). Contract data (e.g. subject matter of the contract, term, customer category).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures. Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our application and to be able to develop it further. The required information is identified as such in the context of the conclusion of the usage, order, purchase order or comparable contract and may include the information required for the provision of services and for any billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Device authorizations for access to functions and data: The use of our application or its functionalities may require user authorizations for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these authorizations must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user’s device and software. Users can contact us if they require clarification. We would like to point out that the denial or revocation of the respective authorizations may affect the functionality of our application.
• No location history and no movement profiles: The location data is only used selectively and is not processed to create a location history or a movement profile of the devices used or their users.

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 email about processes that are relevant to their user account, such as technical changes.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Deletion after termination.
• Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Registration with a real name: Due to the nature of our community, we ask users to only use our service using real names. This means that the use of pseudonyms is not permitted; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Deletion of data after termination: If users have terminated their user account, their data will be deleted with regard to the user account, subject to a legal permission, obligation or consent of the users; legal bases: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• 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; legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Community functions

The community functions provided by us allow users to enter into conversations or otherwise exchange information with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and conditions and guidelines as well as the rights of other users and third parties.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services); business and contractual partners. Third parties.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; provision of our online offer and user-friendliness; organizational and administrative procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Business processes and business management procedures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: 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).

Further information on processing operations, procedures and services:

• Protection of personal data: Users decide for themselves what data they disclose about themselves within our online offering. For example, when users provide information about themselves or participate in conversations. We ask users to protect their data and only publish personal data with caution and only to the extent necessary. In particular, we ask users to take special care to protect their access data and to use secure passwords (i.e. in particular, combinations of characters that are as long and random as possible); legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Online courses and online training: We process the data of participants in our online courses and online training courses (uniformly referred to as “participants”) in order to be able to provide them with our course and training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services used and, if part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance assessment and evaluation of our services and those of the course and training instructors. In addition, depending on the equipment and structure of the respective courses or learning content, further processing processes may be implemented, such as attendance tracking to document participation, progress monitoring to measure and analyze learning progress by collecting examination and test results, and analysis of interactions in learning platforms, such as forum posts and task submissions; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Microsoft Teams: Use for holding online events, conferences and communication with internal and external participants. Voice transmission, direct messages, group communication and collaboration functions are used; name, business contact details, work profile, participation and content (audio/video, voice, chat, files, voice transcription) are processed for purposes and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and business processing by Microsoft. Audio signals are generally not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is saved according to the guidelines specified by the administrator or user; no automatic deletion is set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata is processed and diagnostic data is collected for product stability, security and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Microsoft Sharepoint: Support for collaboration through storage and access management for documents, spreadsheets, presentations, etc. Content data (files) and contact data (name, email address) are processed for the purposes of and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, integration with M365 and improved collaboration. Retention is based on the business function of the content; SharePoint pages must be refreshed every 180 days, otherwise content will be deleted. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Single sign-on login

Single sign-on” or “single sign-on registration or authentication” refers to procedures that allow users to log in to a provider of single sign-on procedures (e.g. a social network), including our online offering, with the help of a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via a button.

Authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider under this user ID and an ID that cannot be used by us for other purposes (so-called “user handle”). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected during authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, it can be different data, usually the e-mail address and the user name. The password entered with the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are asked to note that their details stored with us can be automatically compared with their user account with the single sign-on provider, but that this is not always possible or actually takes place. If, for example, users’ email addresses change, they must change them manually in their user account with us.

If agreed with the users, we can use single sign-on registration in the context of or prior to the fulfillment of the contract, insofar as the users have been asked to do so, process it within the scope of consent and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure registration system.

Should users ever decide that they no longer wish to use the link to their user account with the single sign-on provider for the single sign-on procedure, they must cancel this link within their user account with the single sign-on provider. If users wish to delete their data with us, they must cancel their registration with us.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Event data (Facebook) (“Event data” is information that is sent to the provider Meta via Meta pixels (whether via apps or other channels), for example, and relates to people or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations and product purchases. Event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as comments written, login information or contact information such as names, email addresses or telephone numbers. “Event data” is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are deleted).
• Data subjects: Users (e.g. website visitors, users of online services). Service recipients and clients.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; registration procedures. Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Deletion after termination.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Apple Single Sign-On: Authentication services for user logins, provision of single sign-on features, management of identity information and application integrations; Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
• Facebook Single-Sign-On: Authentication service of the Facebook platform; 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/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.facebook.com/legal/EU_data_transfer_addendum).
• Google Single Sign-On: Authentication services for user logins, provision of single sign-on features, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Possibility of objection (opt-out): Settings for the display of advertisements: https://myadcenter.google.com/.
• X Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: X Internet Unlimited 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/privacy,(Settings: https://x.com/personalization); Data processing agreement: https://privacy.x.com/en/for-our-partners/global-dpa. Basis for third country transfers: Standard Contractual Clauses(https://privacy.x.com/en/for-our-partners/global-dpa).
• Amazon Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.amazon.de/ab/sso/info; Privacy Policy: https://aws.amazon.com/de/privacy/. Basis for third country transfers: Data Privacy Framework (DPF).

Contact and request management

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

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Affected persons: Communication partners. Users (e.g. website visitors, users of online services).
• Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

• Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offers; Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).

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: To ensure your security, we ask for your understanding that we may not be able to answer inquiries via Messenger for certain reasons. This applies to situations in which, for example, contract details need to be treated with particular confidentiality or a reply via Messenger does not meet the formal requirements. In these cases, we recommend that you use more suitable communication channels.

• Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Affected persons: Communication partner.
• Purposes of processing: Communication. Direct marketing (e.g. by e-mail or post).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Apple iMessage: Send and receive text messages, voice messages and video calls. Have group conversations. Share files, photos, videos and locations. Secure communication with end-to-end encryption. Synchronize messages across multiple devices; service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
• Instagram: Sending messages via the social network Instagram; 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/.
• Facebook Messenger: Send and receive text messages, make voice and video calls, create group chats, share files and media, transmit location information, synchronize contacts, encrypt messages; 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/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.facebook.com/legal/EU_data_transfer_addendum).
• Microsoft Teams: Use for holding online events, conferences and communication with internal and external participants. Voice transmission, direct messages, group communication and collaboration functions are used; name, business contact details, work profile, participation and content (audio/video, voice, chat, files, voice transcription) are processed for purposes and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and business processing by Microsoft. Audio signals are generally not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is saved according to the guidelines specified by the administrator or user; no automatic deletion is set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata is processed and diagnostic data is collected for product stability, security and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Signal: Signal Messenger with end-to-end encryption; Service provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite 120-223 Mountain View, CA 94041, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://signal.org/de/. Privacy Policy: https://signal.org/legal/.
• Snapchat: Snapchat Messenger with end-to-end encryption; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.snapchat.com/l/de-de; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy; Data processing agreement: https://www.snap.com/de-DE/terms/data-processing-agreement. Basis for third country transfers: Standard Contractual Clauses(https://www.snap.com/de-DE/terms/data-processing-agreement).
• Telegram: Sending and receiving messages, voice calls and video calls; Creating groups and channels; Sharing files and media; Using bots for automation; End-to-end encryption for secret chats; Synchronization across multiple devices; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://telegram.org/. Privacy Policy: https://telegram.org/privacy/de.
• WhatsApp: Text messages, voice and video calls, sending images, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp 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.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third country transfers: Data Privacy Framework (DPF).
• FaceTime: Messenger, video calls, audio calls, group calls, screen sharing, call scheduling, integration with contacts and calendars; Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.

Chatbots and chat functions

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

If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.

We would like to point out to users that the respective platform provider may find out that and when users communicate with our chat services and may collect technical information about the user’s device and, depending on the settings of their device, location information (so-called metadata) for the purpose of optimizing the respective services and for security purposes. The metadata of communication via chat services (i.e. e.g. information on who has communicated with whom) may also be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their provisions, to which we refer for further information.

If users declare their willingness to a chatbot to activate information with regular messages, they have the option to unsubscribe from the information for the future at any time. The chatbot informs users how and with which terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, user data is deleted from the list of message recipients.

We use the aforementioned data to operate our chat services, e.g. to address users personally, to answer their queries, to transmit any requested content and also to improve our chat services (e.g. to “teach” chatbots answers to frequently asked questions or to recognize unanswered queries).

Notes on legal bases: We use the chat services on the basis of consent if we have previously obtained permission from users to process their data in the context of our chat services (this applies to cases in which users are asked for consent, e.g. so that a chatbot can send them regular messages). If we use chat services to answer users’ inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services on the basis of our legitimate interests in optimizing the chat services, their cost-effectiveness and enhancing the positive user experience.

Revocation, objection and deletion: You can revoke your consent or object to the processing of your data in the context of our chat services at any time.

• Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Affected persons: Communication partners.
• Purposes of processing: Communication.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Push messages

With the user’s consent, we can send users so-called “push notifications”. These are messages that are displayed on users’ screens, end devices or browsers, even if our online service is not currently being actively used.

To register for the push messages, users must confirm the request from their browser or end device to receive the push messages. This consent process is documented and saved. The storage is necessary to recognize whether users have agreed to receive the push messages and to be able to prove their consent. For these purposes, a pseudonymous identifier of the browser (so-called “push token”) or the device ID of an end device is stored.

The push notifications may be necessary for the fulfilment of contractual obligations (e.g. technical and organizational information relevant to the use of our online offer) and are otherwise sent on the basis of the user’s consent, unless specifically mentioned below. Users can change the receipt of push messages at any time using the notification settings of their respective browsers or end devices.

• Processed data types: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Location data (information on the geographical position of a device or person).
• Data subjects: Communication partners.
• Purposes of Processing: Communication; Provision of our online services and usability; Web Analytics (e.g. access statistics, recognition of returning visitors). Direct marketing (e.g. by email or post).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Deletion after termination.
• 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:

• Push notifications with advertising content: The push notifications we send may contain advertising information. The advertising push messages are processed on the basis of the user’s consent. If the content of the advertising push messages is specifically described in the consent to receive them, the descriptions are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Location-dependent sending of push notifications: The push notifications sent by us can be displayed depending on the location of the user based on the location data transmitted by the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Analysis and performance measurement: We evaluate push messages statistically and can thus recognize whether and when push messages were displayed and clicked on. This information is used for the technical improvement of our push messages based on the technical data or the target groups and their retrieval behavior or retrieval times. This analysis also includes determining whether the push messages are opened, when they are opened and whether users interact with their content or buttons. For technical reasons, this information can be assigned to the individual push message recipients. However, it is neither our intention nor, if used, that of the push message service provider to observe individual users. Rather, we use the evaluations to recognize the usage habits of our users and to adapt our push messages to them or to send different push messages according to the interests of our users.
  
  The evaluation of the push messages and the measurement of success are based on the express consent of the users, which is given with the consent to receive the push messages. Users can object to the analysis and performance measurement by unsubscribing from the push messages. A separate revocation of the analysis and performance measurement is unfortunately not possible; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Artificial intelligence (AI)

We use artificial intelligence (AI), whereby personal data is processed. The specific purposes and our interest in using AI are set out below. In accordance with the term “AI system” as defined in Article 3 No. 1 of the AI Regulation, we understand AI to mean a machine-based system that is designed to operate autonomously to varying degrees, can be adaptable after its introduction and produces results such as predictions, content, recommendations or decisions from the input received, which can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human control, purpose limitation, data minimization, integrity and confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can be either the consent of the data subject or legal permission.

When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with the applicable provisions. We also observe the obligations incumbent on us when using or operating the purchased AI services. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or legal authorization. We attach particular importance to transparency, fairness and the preservation of human control over AI-supported decision-making processes.

We implement appropriate and robust technical and organizational measures to protect the processed data. These ensure the integrity and confidentiality of the processed data and minimize potential risks. We ensure ongoing compliance with current legal and ethical standards by regularly reviewing AI providers and their services.

• Processed data types: Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services). Third parties.
• Purposes of processing: Artificial intelligence (AI).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.

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 (email 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 communication processes, i.e. entries in chats as well as 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.

Data protection measures for participants: 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 of conference results, 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. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services). Depicted persons.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Google Hangouts / Meet: Conferencing and communication software; 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://hangouts.google.com/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://cloud.google.com/terms/eu-model-contract-clause).
• GoToMeeting: Conference and communication software; Service provider: LogMeIn Ireland Limited, Bloodstone Building Block C 70, Sir John Rogerson’s Quay Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.gotomeeting.com/de-de; Privacy Policy: https://www.logmein.com/legal/privacy; Data processing agreement: https://www.logmein.com/de/legal#other-agreements (Data Processing Addendum). Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses(https://www.logmein.com/de/legal#other-agreements (data processing addendum)).
• Microsoft Teams: Use for holding online events, conferences and communication with internal and external participants. Voice transmission, direct messages, group communication and collaboration functions are used; name, business contact details, work profile, participation and content (audio/video, voice, chat, files, voice transcription) are processed for purposes and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and business processing by Microsoft. Audio signals are generally not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is saved according to the guidelines specified by the administrator or user; no automatic deletion is set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata is processed and diagnostic data is collected for product stability, security and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
• Zoom: Video conferencing, online meetings, webinars, screen sharing, optional recording of meetings, chat function, integration with calendars and other apps; Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://zoom.us; Privacy Policy: https://explore.zoom.us/de/privacy/; Data processing agreement: https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf).

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 storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).

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).

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Interested parties; communication partners. Business and contractual partners.
• Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Microsoft 365 and Microsoft cloud services: Provision of applications, protection of data and IT systems and use of system-generated log, diagnostic and metadata for contract execution by Microsoft. Contact data (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe) and log and metadata are processed. Processing is carried out for the purposes of increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, integration of Microsoft services, IT security and Microsoft business processing. The storage of data is based on the respective documents and company guidelines, up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. In addition, diagnostic data is collected for product stability and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the users. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.

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 potential 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 for this purpose alone.

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.

Contents:

Information about us, our services, promotions and offers.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• 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).
• 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.

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 store the data required to prove the previous authorization for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services); business and contractual partners. Third parties.
• Purposes of Processing: Direct marketing (e.g. by e-mail or postal); Marketing; Sales promotion; Provision of contractual services and performance of contractual obligations; Organizational and administrative procedures; Information technology infrastructure (Operation and provision of information systems and technical equipment (computers, servers, etc.)). Business processes and business management procedures.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Microsoft 365 Outlook: Use of email and calendar functions for communication and organization of meetings. Contact data (name, email address), content data (messages, attachments, meeting content) and metadata are processed for purposes and out of interest in increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication and integration with M365. Retention of emails and calendar entries is based on the guidelines defined by the administrator or user; there is no automatic deletion by default. Mailboxes and calendars are usually removed 30 days after retirement. In addition, diagnostic data is collected for product stability and improvement; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Competitions and contests

We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, execution and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).

If participants’ contributions are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.

If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that inquiries regarding the competition should be directed to us.

Participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because no further queries about the competition are to be expected. In principle, participants’ data will be deleted no later than 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. in order to answer queries about the prizes or to fulfill the prize; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. in order to be able to process warranty claims. Furthermore, participants’ data may be stored for longer, e.g. in the form of reporting on the competition in online and offline media.

If data is also collected for other purposes as part of the competition, its processing and retention period will be based on the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Data subjects: Competition and contest participants.
• Purposes of the processing: Running competitions and contests.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Surveys and interviews

We conduct surveys and interviews in order to collect information for the communicated purpose of the survey or interview. The surveys and questionnaires (hereinafter “surveys”) we conduct 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 to display the survey in the user’s browser or to enable the survey to be resumed with the help of a cookie).

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Persons concerned: Participants. Users (e.g. website visitors, users of online services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Surveys and questionnaires (e.g. surveys with input options, multiple choice questions).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Microsoft Forms: Creation of online forms, collection of responses in real time, analysis of results with integrated diagrams. Integration with other Office applications for further data processing. Customizable forms with different question types and answer options as well as export of data; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://forms.office.com/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

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 visitors to reuse them. It also enables us to understand which areas require 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.

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 end device and then read out. 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, it is also possible to process location data.

In addition, the IP addresses of users are 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 purpose of the respective process.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and 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. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• 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); Tracking (e.g. profiling based on interests and behavior, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Custom Audiences; Marketing. Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• 1&1 IONOS WebAnalytics: Reach measurement and web analytics; Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.ionos.de; Privacy Policy: https://www.ionos.de/terms-gtc/datenschutzerklaerung/; Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/vereinbarung-zur-auftragsverarbeitung-avv-mit-ionos-abschliessen/; Further information: The data is collected either by a pixel or by a log file, without the use of cookies; the IP address of the visitors is transmitted when a page request is sent, anonymized directly after transmission and processed further without personal reference. the data is processed on the basis of an order processing contract.
• 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 e-mail 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 offer 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 can 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. It is not logged, is not accessible and is 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), Standard Contractual Clauses(https://business.safety.google/adsprocessorterms); Opt-Out: Opt-out plugin: 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).

Online marketing

We process personal data for the purpose of online marketing, 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 (the 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 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) for user protection. 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 procedures know the actual identity of the users, but only the information stored in their profiles.

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

In exceptional cases, it is possible to assign clear data to the profiles, primarily if, for example, 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, for example 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 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 data processing is permission. 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.

Information on revocation and objection:

We refer to the data protection notices of the respective providers and the opt-out options provided by 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.

• Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behavior, use of cookies); Custom Audiences; Marketing; Profiles with user-related information (Creating user profiles); Conversion tracking (Measurement of the effectiveness of marketing activities); Remarketing. Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• AdMob: Platform for the display of advertising content in mobile applications; 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://admob.google.com/home/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://business.safety.google/adscontrollerterms/). Further information: Processing by Google as controller: https://business.safety.google/adscontrollerterms/.
• Google Ads and conversion measurement: online marketing process 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.
• Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that allows users who use an online service to be added to a pseudonymous remarketing list so that users can be shown ads on other online offers based on their visit to the online service; 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; 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.

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. 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. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Interested parties. Users (e.g. website visitors, users of online services).
• Purposes of processing: Affiliate tracking.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Offer of an affiliate program

We offer an affiliate program, i.e. commissions or other benefits (collectively referred to as “commission”) for users (referred to as “affiliates”) who refer to our offers and services. The referral is made by means of a link assigned to the respective Affiliate or other methods (e.g. discount codes) that allow us to recognize that the use of our services was based on the referral (collectively referred to as “Affiliate Links”).

In order to be able to track whether the users have used our services on the basis of the affiliate links used by the affiliates, it is necessary for us to know that the users have followed an affiliate link. The assignment of the affiliate links to the respective business transactions or other use of our services 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: The processing of our partners’ data is carried out for the provision of our (pre-)contractual services. Users’ data is processed on the basis of their consent.

• Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times).
• Data subjects: Users (e.g. website visitors, users of online services). Business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Affiliate tracking.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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 data protection notices of the providers 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. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Data subjects: Service recipients and clients; users (e.g. website visitors, users of online services). Business and contractual partners.
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Rating widget: We integrate so-called “rating widgets” into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can, for example, be displayed in the form of a seal or comparable element, sometimes also called a “badge”. Although the corresponding content of the widget is displayed within our online offering, it is retrieved from the servers of the respective widget provider at that moment. Only in this way can the current content always be shown, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offering to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address) that is necessary for the content of the widget to be delivered to the user’s browser. Furthermore, the widget provider receives information that users have visited our website. This information can be stored in a cookie and used by the widget provider to recognize which online offers that participate in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Google Customer Reviews: Service for obtaining and/or presenting customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Additional information: As part of the collection of customer reviews, an identification number and time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer’s e-mail address and their country of residence as well as the review details themselves are processed; Further information on the types of processing and the 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.
• ProvenExpert: Rating platform; Service provider: Expert Systems AG, Quedlinburger Strasse 1, 10589 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.provenexpert.com/de-de/. Privacy Policy: https://www.provenexpert.com/de-de/datenschutzbestimmungen/.
• Trustpilot: Rating platform; Service provider: Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://de.trustpilot.com; Privacy Policy: https://de.legal.trustpilot.com/for-reviewers/end-user-privacy-terms. Data processing agreement: https://de.legal.trustpilot.com/for-businesses/data-processing-agreement.

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 user 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 latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

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 latter have access to the user 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. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Inventory data (e.g. full name, residential address, contact information, customer number, etc.).
• Data subjects: Users (e.g. website visitors, users of online services). Members.
• Purposes of Processing: Communication; Feedback (e.g. collecting feedback via online form); Public relations; Provision of our online services and usability; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Marketing.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

• Instagram: Social network that allows you to share photos and videos, comment on 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/. Basis for third country transfers: Data Privacy Framework (DPF).
• Facebook pages: Profiles within the Facebook social network – The controller, together with Meta Platforms Ireland Limited, is responsible for the collection and transmission of data from visitors to our Facebook page (“fan page”). This includes, in particular, information about user behavior (e.g. content viewed or interacted with, actions performed) and device information (e.g. IP address, operating system, browser type, language settings, cookie data). You can find more information on this in the Facebook data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the “Page Insights” service, which provide information about how people interact with our site and its content. The basis for this is an agreement with Facebook (“Information on Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subjects’ rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore send requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transmission to 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), Standard Contractual Clauses(https://www.facebook.com/legal/EU_data_transfer_addendum).
• Facebook groups: We use the “Groups” function of the Facebook platform to create interest groups within which Facebook users can contact each other or us and exchange information. In doing so, we process personal data of the users of our groups to the extent necessary for the purpose of group use and moderation. Our guidelines within the groups may contain further specifications and information on the use of the respective group. This data includes information on first and last names, as well as published or privately shared content, as well as values on the status of group membership or group-related activities, such as joining or leaving, as well as the time details for the aforementioned data. We also refer to the processing of user data by Facebook itself. 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 “Insights”, to group operators to provide them with insights into how people interact with their groups and with the content associated with them; 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).
• Facebook events: Event profiles within the Facebook social network – We use the “Events” function of the Facebook platform to draw attention to events and dates and to get in touch with users (participants and interested parties) and to exchange information. In doing so, we process personal data of the users of our event pages, insofar as this is necessary for the purpose of the event page and its moderation. This data includes information on first and last names, as well as published or privately shared content, as well as values on the status of participation and the time details for the aforementioned data. We also refer to the processing of user data by Facebook itself. 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 “Insights”, to event providers to give them insights into how people interact with their event pages and with the content associated with them; service providers: 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 visitors’ data used to create the “page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, 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 data protection information: https://www.linkedin.com/legal/privacy-policy.
  We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller 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 the data subjects (i.e. users can, for example, send requests for information or deletion directly to LinkedIn). The rights of users (in particular the right 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 and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal 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), Standard Contractual Clauses(https://legal.linkedin.com/dpa). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Pinterest: Social network that allows you to share photos, comment, favorite and curate posts, send messages, subscribe to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.
• Snapchat: Social network that allows users to share photos and videos, comment on and favourite posts, send messages, subscribe to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.snapchat.com/; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy. Basis for third country transfers: Standard Contractual Clauses(https://www.snap.com/en-US/terms/standard-contractual-clauses).
• Telegram groups: We use the Telegram platform to create interest groups within which Telegram users can get in touch with each other or with us and exchange information; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy; Further information: We process the personal data of group members only to the extent that we can manage the group members, i.e. add, delete, restrict the use of the group and moderate the content. Beyond this, i.e. in particular for the provision of technical functions, the evaluation and provision of anonymous sending statistics for the group operators and the administration of users, Telegram is responsible.
• Telegram channels: We use the Telegram platform to send messages to subscribers of our Telegram channel; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy/de; Further information: We only process the personal data of subscribers to the extent that we can view and delete the subscribers as recipients of the channel. Beyond this, i.e. in particular for the sending of messages, the evaluation and provision of anonymous sending statistics for the channel operators and the administration of subscribers, Telegram is responsible under data protection law.
• Threads: Social network; 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.threads.net/. Privacy Policy: https://help.instagram.com/515230437301944.
• TikTok: Social network, enables the sharing of photos and videos, commenting and favoriting of posts, sending messages, subscribing to accounts; service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy. Basis for third country transfers: Standard Contractual Clauses(https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
• TikTok Business: Social network, allows sharing photos and videos, commenting and favoriting posts, messaging, subscribing to accounts – We and TikTok are jointly responsible for the collection and transmission of event data and the measurement and creation of insights reports (statistics) for profile owners. This event 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 users’ profiles, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok’s privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have concluded a special agreement on joint responsibility with TikTok, which regulates in particular which security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to TikTok). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with TikTok. The agreement on joint responsibility can be found in the “Jurisdiction Specific Terms” of TikTok: https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basis for third country transfers: Standard Contractual Clauses(https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
• X: Social network; Service provider: X Internet Unlimited 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.
• Vimeo: Social network and video platform; 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.
• YouTube: Social network and video platform; 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); Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Option to object (opt-out): https://myadcenter.google.com/personalizationoff.
• Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/. Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
• Social media wall / social media newsroom: A “social media wall” or “social media newsroom” is a compilation of posts from various social networks in which we are mentioned or which contain a hashtag with our name or the name of a campaign. This includes mentions of posts that we publish on social networks as well as posts published by users. The content of the posts is automatically obtained from the respective social networks in accordance with the terms and permissions of the authors, and users can object to the display at any time. The authors are always responsible for the content of the posts. The providers of the respective social networks are responsible for the processing of data in connection with the display of posts and their content. We refer to the information on the respective social networks in the context of this privacy policy. Without prejudice to the rights of the users concerned, we recommend that users (also) contact the respective authors or providers of the respective social networks in the event of requests for information and complaints about contributions that were not made by us in order to remove the contributions at the source or to assert their data protection rights; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Plug-ins 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 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, but may also be 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 data processing is permission. 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. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); location data (information on the geographical position of a device or person). Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of Processing: Provision of our online services and usability; Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behavior, use of cookies); Custom Audiences; Marketing; Provision of contractual services and performance of contractual obligations; Profiles with user-related information (Creating user profiles). Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and can process it for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimization of their offer. – We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and may process it for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of a 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, the user’s browser sends 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.
• Font Awesome (provision on own server): Display of fonts and icons; Service provider: The Font Awesome icons are hosted on our server, no data is transmitted to the provider of Font Awesome; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• 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 user location data; 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).
• Instagram plugins and content: Instagram 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 Instagram. – 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 using Instagram functions (e.g. embedding functions for content) that are executed on our online offer or receives in the context of a transmission 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 Instagram). (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 measurements, 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: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/.
• LinkedIn plugins and content: LinkedIn 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 LinkedIn; 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; Data processing agreement: https://legal.linkedin.com/dpa; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.linkedin.com/legal/l/dpa). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• OpenStreetMap: We integrate the maps of the “OpenStreetMap” service, which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). The user data is used by OpenStreetMap exclusively for the purpose of displaying the map functions and for caching the selected settings. This data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually as part of the settings of their end devices or browsers); service provider: OpenStreetMap Foundation (OSMF); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.openstreetmap.de. Privacy Policy: https://osmfoundation.org/wiki/Privacy_Policy.
• Pinterest plugins and content: Pinterest 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 service within Pinterest; Service provider: Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.
• reCAPTCHA: We integrate the “reCAPTCHA” function in order to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Data processing is carried out on the basis of our legitimate interest in protecting our online offering from abusive automated crawling and spam; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Possibility of objection (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.
• 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). Possibility of objection (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.
• YouTube videos: Videos stored on YouTube are embedded within our online offering. These YouTube videos are integrated via a special domain using the “youtube-nocookie” component in the so-called “extended data protection mode”. In “extended data protection mode”, until the video is started, only information including your IP address and details of the browser and your end device can be stored on your end device in cookies or by means of comparable procedures, which YouTube requires for the output, control and optimization of the video display. As soon as you play the videos, additional information may be processed by YouTube for the analysis of user behaviour and for storage in the user profile and for the personalization of content and ads. The storage period for cookies can be up to two years; 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). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-privacy-enhanced-mode%2Cerweiterten-datenschutzmodus-aktivieren.
• Xing plugins and buttons: Xing plugins and buttons – 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 Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com. Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
• WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offers; Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).

Processing of data in the context of employment relationships

In the context of employment relationships, personal data is processed with the aim of effectively managing the establishment, implementation and termination of such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relations.

Data processing covers various aspects ranging from contract initiation to contract termination. This includes the organization and administration of daily working hours, the administration of access rights and authorizations as well as the handling of personnel development measures and employee appraisals. The processing is also used for payroll and the administration of wage and salary payments, which are critical aspects of contract implementation.

In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data to evaluate and optimize operational processes. Furthermore, data processing includes the disclosure of employee data as part of external communication and publication processes, where this is necessary for operational or legal purposes.

This data is always processed in compliance with the applicable legal framework, whereby the aim is always to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymization or deletion of data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.

• Processed data types: Employee data (information on employees and other persons in an employment relationship); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as information relating to them, such as information on authorship or time of creation); social data (e.g. data collected by social security organizations). content data (e.g. textual or visual messages and contributions and the information relating to them, such as details of authorship or time of creation); social data (data subject to social confidentiality and processed, for example, by social insurance carriers, social welfare providers or pension authorities); log data (e.g. log files relating to logins or the retrieval of data or access times); performance and behavioral data (e.g. performance and behavioral aspects). e.g. performance and behavioral aspects such as performance evaluations, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behavioral assessments); working time data (e.g. start of working hours, end of working hours, actual working hours, target working hours, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, bonuses, premiums). basic salary, bonus payments, premiums, tax class information, supplements for night work/overtime, tax deductions, social security contributions, net amount paid out); image and/or video recordings (e.g. photographs or video recordings of a person); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Special categories of personal data: Health data; Religious or philosophical beliefs. Trade union membership.
• Data subjects: Employees (e.g. employees, applicants, temporary staff and other employees).
• Purposes of processing: Establishment and execution of employment relationships (processing of employee data in the context of the establishment and execution of employment relationships); business processes and business management procedures; provision of contractual services and fulfillment of contractual obligations; public relations; security measures. Office and organizational procedures.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to health care, employment and social security (Art. 9 para. 2 lit. h) GDPR).

Further information on processing operations, procedures and services:

• Working time recording: Procedures for recording employees’ working times include both manual and automated methods, such as the use of time clocks, time recording software or mobile apps. This involves activities such as entering clock-in and clock-out times, break times, overtime and absences. Checking and validating the recorded working times includes comparing them with shift schedules, checking absences and approving overtime by supervisors. Reports and analyses are created on the basis of the recorded working hours in order to provide time sheets, overtime reports and absence statistics for management and the HR department; legal basis: performance of contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Authorization management: Procedures required to define, manage and control access rights and user roles within a system or organization (e.g. creation of authorization profiles, role and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Special categories of personal data: Special categories of personal data are processed in the context of the employment relationship or to fulfill legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data may, for example, be passed on to health insurance companies or processed to assess employees’ ability to work or for occupational health management or for information to the tax office; Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Sources of the processed data: Personal data obtained as part of the employee’s application and/or employment relationship is processed. In addition, if required by law, personal data is collected from other sources. These may be tax authorities for tax-relevant information, the respective health insurance company for information on incapacity for work, third parties such as employment agencies or publicly accessible sources such as professional social networks in the context of application procedures; legal bases: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Purposes of data processing: The personal data of employees are processed primarily for the establishment, implementation and termination of the employment relationship. In addition, the processing of this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to comply with regulatory and supervisory requirements, to optimize electronic data processing processes and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the assertion of legal claims and for defense in legal disputes; Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Transfer of employee data: Employee data is only processed internally by those departments that need it to fulfill operational, contractual and legal obligations.
  Data is only passed on to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller may forward personal data to other recipients if this is necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance funds, pension insurance providers, pension providers and other social insurance providers c) Public authorities, courts (e.g. tax authorities, labor courts, other (e.g. tax authorities, labor courts, other supervisory authorities as part of the fulfillment of reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the event of wage and salary garnishments f) Other bodies to which legally binding declarations must be made.
  In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples of this include information in the sender area of emails or letterhead and the creation of profiles on external platforms; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Transfer of employee data to third countries: The transfer of employee data to third countries, i.e. countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the fulfillment of the employment relationship, is required by law or if employees have given their consent. Employees will be informed separately about the details, if required by law; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Business trips and travel expense accounting: Procedures required for the planning, execution and accounting of business trips (e.g. booking of trips, organization of accommodation and means of transport, administration of travel expense advances, submission and verification of travel expense reports, control and accounting of costs incurred, compliance with travel guidelines, handling of travel expense management); Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Payroll accounting and payroll accounting: Procedures required for the calculation, payment and documentation of wages, salaries and other remuneration of employees (e.g. recording working hours, calculating deductions and bonuses, paying taxes and social security contributions, preparing wage and salary statements, managing payroll accounts, reporting to the tax office and social security institutions); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
• Deletion of employee data: Employee data is deleted in accordance with German law if it is not required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer. The following retention and archiving obligations are observed:
  • General personnel documents – General personnel documents (such as employment contract, reference letter, supplementary agreements) are kept for up to three years after termination of the employment relationship (§ 195 BGB).
    Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 AO, § 257 HGB).
    Information on wages and working hours – Information on wages and working hours for (accident) insured persons with proof of wages is kept for five years (§ 165 I 1, IV 2 SGB VII).
  • Salary lists including lists for special payments – Salary lists including lists for special payments, if an accounting document is available, are kept for ten years (§ 147 AO, § 257 HGB).
  • Payroll lists for interim, final and special payments – Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
  • Employee insurance documents – Employee insurance documents, if accounting documents are available, are kept for ten years (§ 147 AO, § 257 HGB).
  • Contribution statements to social insurance institutions – Contribution statements to social insurance institutions are kept for ten years (§ 165 SGB VII).
    Payroll accounts – Payroll accounts are kept for six years (§ 41 I 9 EStG).
  • Applicant data – Retained for a maximum of six months from receipt of rejection.
  • Working time records (for more than 8 hours on working days) – Retained for two years (Section 16 II Working Hours Act (ArbZG)).
  • Application documents (after online job advertisement) – Are kept for three to a maximum of six months after receipt of the rejection (§ 26
  • Federal Data Protection Act (BDSG) new version, § 15 IV General Equal Treatment Act (AGG)).
  • Certificates of incapacity for work (AU) – Retained for up to five years (Section 6 I of the Equalization of Expenses Act (AAG)).
  • Company pension scheme documents – Retained for 30 years (Section 18a of the Act on the Improvement of Company Pension Schemes (BetrAVG)).
  • Employee sickness data – Retained for twelve months after the start of the illness if the absences do not exceed six weeks in a year.
  • Maternity protection documents – Are kept for two years (§ 27 para. 5 MuSchG).

  Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).

• Personnel file management: Procedures required for the organization, updating and management of employee data and documents (e.g. recording of personnel master data, storage of employment contracts, references and certificates, updating of data in the event of changes, compilation of documents for employee appraisals, archiving of personnel files, compliance with data protection regulations); Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
• Personnel development, performance evaluation and employee appraisals: Procedures required in the area of promoting and developing employees and assessing their performance and in the context of employee appraisals (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, implementation of target agreement and feedback discussions, career planning and talent management, succession planning); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
• Obligation to provide data: The controller shall inform employees that the provision of their data is required. This is generally the case if the data is required for the establishment and performance of the employment relationship or if its collection is required by law. It may also be necessary to provide data if employees assert claims or if employees are entitled to claims. The implementation of these measures or fulfillment of benefits is dependent on the provision of this data (for example, the provision of data for the purpose of receiving wages); Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Publication and disclosure of employee data: Employee data is only published or disclosed to third parties if this is necessary for the performance of work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website or in public registers following consultation or an agreed job description, or if the area of responsibility includes representative functions. This may also be the case if a presentation or communication with the public takes place as part of the performance of duties, such as photographs taken as part of public relations work. Otherwise, employees’ data will only be published with their consent or on the basis of the employer’s legitimate interests, for example in the case of stage or group photos taken as part of a public event; legal basis: performance 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).

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 available, applicants are welcome to submit their applications via our online form, which is encrypted using state-of-the-art technology. Alternatively, it is also possible to send us applications by e-mail. However, we would like to point out that e-mails sent via the Internet are generally not encrypted. Although e-mails are generally encrypted in transit, this is not done on the servers from which they are sent and received. We can therefore accept no responsibility for the security of the application during transmission between the sender and 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 (Art. 9 para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants or communicated by them as part of the application procedure, their processing is carried out so that the controller or the data subject can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard. In the case of the protection of vital interests of applicants or other persons or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services.

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 not successful, 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: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). 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 with regard to a specific position or voluntarily by applicants).
• Data subjects: Applicants.
• Purposes of processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Data protection information for whistleblowers

In this section you will find information on how we handle data from people who provide information (whistleblowers) and from affected and involved parties as part of our whistleblowing procedure. Our aim is to provide an uncomplicated and secure way to report possible misconduct by us, our employees or service providers, especially for actions that violate laws or ethical guidelines. We also ensure that reports are processed and handled appropriately.

Processed data types:

We may collect various data in the course of receiving and processing reports and in the subsequent whistleblower procedure. In particular, this includes the data provided by a whistleblower, such as

• Name, contact details and location of the person providing the information,
• Names and details of possible witnesses or persons affected by the tip-off,
• Names and details of the persons against whom the tip-off is directed,
• Data on the alleged misconduct,
• Other relevant details, if provided by the whistleblower.

We also process the following personal data for the purposes of examining the facts and further proceedings:

• Clear identification of the report,
• Contact details of the person providing the information, if specified,
• Personal data of persons named in the report, if specified,
• Personal data of persons indirectly affected by the fact check, if applicable,
• Personal data of persons from other companies involved (e.g. in the context of legal advice), if relevant,
• Other data related to the facts of the case.

Special categories of personal data:

We may collect special types of personal data in the course of our activities, in particular if these are provided by a whistleblower. These include:

• Health-related data of a person,
• Data relating to a person’s racial or ethnic origin,
• Information about a person’s religious or philosophical beliefs,
• Information about a person’s sexual orientation.

This data is only processed if it is relevant for the processing of the respective report and has been expressly provided by the whistleblower.

Use of our online forms: Please note that it is possible to submit comments anonymously. To ensure the security of your data when using our online forms, we recommend that you access them in the so-called ‘incognito mode’ of your browser. You can open an incognito window as follows: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

When you access our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your end device. This data is temporarily stored in a log file and automatically deleted after 30 days at the latest.

The IP address is processed for technical and administrative purposes to establish a connection to our website. It ensures the security, stability and functionality of the whistleblower form and is an important part of our measures to ensure the confidential submission of information.

The processing of the logged data is based on Article 6(1)(1)(f) GDPR. Our legitimate interest here lies in the need for security and the need to ensure the technical requirements for smooth and trouble-free notification.

Indication of names: You have the option of submitting comments anonymously. However, unless prohibited by national legislation, we recommend that you provide your name and contact details. This enables us to investigate the report more effectively and contact you directly if necessary.

If you provide your name and contact details, your identity will be kept strictly confidential. Exceptions to this confidentiality only exist if we are legally obliged to disclose your identity. This may be necessary to protect or defend our rights or the rights of our employees, customers, suppliers or business partners. Another exception is if it is determined that the allegations were made with malicious intent.

Provision of data to third parties: Data relating to the information provided will only be passed on by us to third parties under certain circumstances. This happens either a) if you have given us your express consent to do so, or b) if there is a legal obligation to pass on the data. Possible third parties include public authorities, government, regulatory or tax authorities if the disclosure is necessary to fulfill a legal or regulatory obligation. We may also engage lawyers and other professional advisors as permitted by law. They are authorized to investigate suspected misconduct and take necessary action following an investigation, such as initiating disciplinary or legal proceedings. In addition, service providers carefully selected and monitored by us may receive data for these purposes (e.g. operators of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection regulations as part of commissioned data processing.

Data retention and deletion: Personal data is only processed for as long as is necessary to fulfill the processing purposes described above. If this data is no longer necessary for the purposes mentioned, it will be deleted. In certain situations, however, the data may be stored for longer in order to comply with legal requirements, as long as this is necessary and proportionate. In such cases, the data will be deleted as soon as it is no longer required for these purposes.

Technical and organizational measures: We have implemented the necessary contractual, technical and organizational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. Incoming reports are processed by authorized persons who are given access to the respective reports and carry out the subsequent review of the facts. Our employees are specially trained and educated in the proper execution of factual checks and are obliged to maintain the strictest confidentiality.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Employee data (information on employees and other persons in an employment relationship); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Affected persons: Employees (e.g. employees, applicants, temporary staff and other employees); third parties. Whistleblowers.
• Purposes of processing: whistleblower protection.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Whistleblower systems

We use external providers as part of our whistleblowing procedure. In doing so, we act within the framework of the legal requirements and ensure that the technical and organizational requirements we adhere to with regard to security measures are also met by the external providers.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Employee data (information on employees and other persons in an employment relationship); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Affected persons: Employees (e.g. employees, applicants, temporary staff and other employees); third parties. Whistleblowers.
• Purposes of processing: whistleblower protection.
• Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us 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 policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• 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
• Employees: Employees are defined as persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is defined by an employment contract or agreement. It involves the employer’s obligation to pay remuneration to the employee while the employee performs work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee performs his or her work activities, and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance appraisals.
• Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
• Contact details: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
• 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.
• Artificial intelligence (AI): The purpose of processing data using artificial intelligence (AI) includes the automated analysis and processing of user data in order to recognize patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of data, the training and application of AI models as well as the continuous review and optimization of the results and is carried out exclusively with the consent of the users or on the basis of legal permission.
• Performance and behavioral data: Performance and behavioral data refers to information related to how individuals perform tasks or behave in a particular context, such as an educational, work or social environment. This data can include metrics such as productivity, efficiency, quality of work, attendance and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes and reactions to different situations. These types of data are often used for performance evaluations, training and development, and decision making within organizations.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
• Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of “profiles with user-related information”, or “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.
• Log data: Log data is information about events or activities that have been logged on a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
• 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, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of their websites 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.
• Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means 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 location-dependent information.
• Tracking: The term “tracking” is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
• 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.
• Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
• Payment data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorizations and fees.
• Target group formation: Target group formation (custom audiences) is the term used 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, “lookalike audiences” (or similar target groups) are when 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.