Privacy Policy

what data we collect and how we process it

Preamble

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

The terms used are not gender-specific.

Last Update: 13. March 2026

Table of contents

Controller

devowl.io GmbH
Tannet 12
94539 Grafling
Germany

Authorised Representatives: Matthias Günter and Jan Karres

E-mail address: [email protected]

Phone: +49 991 20098959

Legal Notice: https://devowl.io/legal-notice/

Relevant legal bases

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – 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.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.
  • Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR) – If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(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 diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.
  • Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR) – processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional.

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

Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as “Swiss DPA”). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).

Reference to the applicability of the GDPR and the Swiss DPA: This privacy policy is intended to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). Where references are made to concepts such as the processing of personal data, legitimate interests, or special categories of data, these references are to be understood in accordance with the applicable data protection laws. Within the scope of application of the Swiss FADP, the legal interpretation of these terms is determined exclusively by Swiss law.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security 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 access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ 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 that is transferred between the website or app and the user’s browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being securely and encryptedly transmitted.

Transmission of Personal Data

In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.

International data transfers

For affected persons from Switzerland – Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DPA). If the Federal Council has not determined an adequate level of protection (list of states: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by Switzerland’s adequacy decision of September 15, 2024. Additionally, we have concluded Standard Data Protection Clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Data Protection Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Data Protection Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we will inform you whether they are certified under the DPF and if Standard Data Protection Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce’s website at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate safeguards apply, including international agreements, specific guarantees, FDPIC-approved Standard Data Protection Clauses, or internal company data protection regulations previously recognized by the FDPIC or a competent data protection authority of another country.

Under Art. 16 of the Swiss DPA, exceptions can be made for the disclosure of data abroad if certain conditions are met, including the consent of the affected person, contract execution, public interest, protection of life or physical integrity, publicly made data, or data from a legally provided register. Such disclosures always comply with the legal requirements.

We will inform you which of our service providers are certified under the Data Privacy Framework as part of our privacy notices.

Data Processing in Third Countries: If we transfer personal data to recipients outside the EU/EEA or Switzerland or have it processed there (e.g. by using service providers), this is done exclusively in accordance with the applicable data protection regulations (GDPR or Swiss DSG).

For transfers to third countries, we use adequacy decisions (e.g. the Data Privacy Framework (DPF) for certified companies), where available. If no adequacy decision exists, we use appropriate safeguards, in particular standard contractual clauses (SCC) and, where necessary, supplementary technical and organisational measures. In exceptional cases, a transfer may also be made on the basis of express consent or due to legal requirements.

Whether a provider is certified under the DPF and/or which safeguards (e.g. SCC) are used is described in the respective sections on the services. Further information and a list of DPF-certified companies is provided by the US Department of Commerce. Information on adequacy decisions and third-country transfers can also be found in the information provided by the European Commission. For Switzerland, the Federal Council publishes a list of countries with adequate protection; otherwise, appropriate safeguards (e.g. standard data protection clauses recognised/approved by the FDPIC) are used.

General Information on Data Retention and Deletion

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

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

Our privacy notices contain additional information on the retention and deletion of data specifically applicable to certain processing processes.

In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.

Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.

Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:

  • 10 Years – Fiscal Code/Commercial Code – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 8 years – Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB))
  • 6 Years – Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 3 Years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).

Data Retention and Deletion: The following general retention and archiving periods apply under Swiss law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
  • 10 years – Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries based on previous business experiences and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Articles 127, 130 OR). Claims for rent, lease, and interest on capital, as well as other periodic services, for the delivery of food, for board and lodging, for innkeeper debts, as well as for craftsmanship, small-scale sales of goods, medical care, professional services by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees, expire after five years (Article 128 OR).

Rights of Data Subjects

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

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data 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 data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the law 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 where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of the data subjects under the Swiss DPA:

As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

  • Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.

License activation and telemetry data

We offer software products that can or must be activated with a license key. In any case, a license must be activated to access the license server license.devowl.io and the download server assets.devowl.io . A license key may constitute personal data and, like telemetry data, may be processed in various contexts to ensure the availability and security of our products and our customers, e.g., during plug-in activation or deactivation. Our products are largely personalized for security reasons, which is why it is also possible to draw conclusions about the company or the person concerned from parts of the product, such as the source code or the issued templates. In various contexts of the ordering process and the use of our products, further data, in particular the IP address, can and must be processed, e.g. during license activation or deactivation. From the license server, the products can obtain and store the following information:

  • Verification of the license key and lawful use of the software Updates for products (with verification that the product is compatible with the requesting software environment)
  • Announcements about this or other vendor’s products (e.g., notices of serious security breaches or discount promotions)
  • Telemetry data about the software user’s usage patterns (excluding specific non-public content or personal data created with the software)
  • Language pack ZIP files, which hold translation files (.po, .mo files) for the plugin to keep the ZIP file as small as possible.

In addition, if a license is successfully activated, the Real Cookie Banner product may receive and store the following information from rcb.devowl.io:

  • Download of service templates and service logos (only with active license)
  • Download of content blocker templates (only with active license)
  • Download of Global Vendor List (GVL) to use TCF standard (only when feature is active)
  • Geo-restriction database (only when feature is active)

When activating a license and checking for a new software version, the following data must always be transmitted and stored, if known, to ensure the functionality of the license server:

  • Version of the operating system
  • Browser version
  • Host name of the e.g. website in which the software is used
  • WordPress version
  • WordPress language
  • PHP version.

The above data is used to provide updates to the software that are compatible with the requesting software environment. Allocation of licenses for support cases to provide customers with professional information. In addition, the transfer of telemetry data can be optionally agreed to. Telemetry data is data that reflects the usage behavior of the software user, whereby sensitive data (e.g. access data or non-public content of a website) is never transmitted. Telemetry data is used to improve the software and help us better identify missing features for future releases.

The following products may collect telemetry data as described below:

Real Cookie Banner

    • Number of created service groups
    • Number of created services
    • Number of created content blockers
    • Name and identifier of public visible services
    • Name and identifier of public visible content blockers
    • Hostname (but not full URL) of external URLs found by the service scanner including the number of subpages on which this external URL was found
    • Number of documented consents in the last 30 days
    • Number of documented consents by clicked button in the last 30 days
    • Number of documented consents by kind of consent (e.g. given by user or implicit given by geographic position of the website visitor) in the last 30 days
    • Active plugins in WordPress installation
    • Active themes in WordPress installation
    • “Load services after consent via” setting value
    • “Automatically accept all services for bots” setting value
    • “Respect ‘Do Not Track’” setting value
    • “Consent for data processing in unsecure third countries” setting value
    • “Age notice for consent” setting value
    • “Naming of all services in first view” setting value
    • “Transparency and Consent Framework (TCF) Compatibility” setting value
    • “Consent Forwarding” setting value
    • Type of “accept all“-buttons/links
    • Type of “continue without consent”-buttons/links
    • Type of “individual privacy preferences”-buttons/links
    • “Geo-restriction“-setting value

“Google Consent Mode”-setting value

“Banner-less consent”-setting value

Count of essential services

Count of non-essential services with the legal basis “Consent”

Count of non-essential services with the legal basis “Legitimate interest”

Count of non-essential services with the legal basis “Consent”, which are referenced in at least one active visual content blocker

Count of non-essential services with the legal basis “Legitimate interest”, which are referenced in at least one active visual content blocker

Real Media Library

  • No telemetry data is collected yet.

Real Physical Media

  • No telemetry data is collected yet.

Real Category Management

  • No telemetry data is collected yet.

Real Thumbnail Generator

  • No telemetry data is collected yet.

You can stop the collection of the data mentioned in this section at any time by disabling the license in the software you are using.

Business services

We process personal data of our contractual and business partners, such as Customers, Clients, Prospective Customers, Suppliers and other cooperation partners (collectively referred to as “Contractual Partners”), for the initiation, execution and settlement of contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures carried out at the request of the parties and communication related to the respective contractual relationship.

Processing serves in particular to fulfil our primary and secondary contractual obligations. This includes providing the agreed services, any update and information obligations, handling warranty claims and other service disruptions, processing revocations, terminations of continuing obligations, reversals, refunds as well as handling other contract-related statements and enquiries. Both one-off contracts and ongoing contractual relationships are covered.

In particular, we process master data such as name, address and where applicable company name; contact details such as email address and telephone number; contract and service data such as subject matter of the contract, duration of the contract, order or transaction number; usage and performance data; payment and billing data; as well as communication content and histories. Where necessary, we also process data disclosed or transmitted to us in connection with carrying out an assignment.

Furthermore, we process the data to safeguard our rights and to comply with legal obligations. This particularly includes commercial law and tax law retention requirements, documentation obligations as well as possible duties of proof or accountability. Processing may also take place on the basis of our legitimate interests in proper business management, internal administration, risk control and IT security as well as in protecting our business operations and Contractual Partners against misuse or threats to data, secrets or other legal assets. This may include involving external Service Providers such as IT- and telecommunications providers, transport- or logistics companies, payment service providers, banks, tax advisors or legal advisors or other vicarious agents insofar as this is required for executing contracts or fulfilling legal obligations.

Personal data will only be passed on to third parties if this is necessary for fulfilling a contract or conducting pre-contractual measures; safeguarding legitimate interests; or complying with statutory obligations. We will inform you separately within this privacy policy about any further processing activities—particularly those undertaken for marketing purposes.

Which specific data is required in each case will be communicated to Contractual Partners during collection—for example by appropriate labelling in online forms or during personal contact.

Data will be deleted once it is no longer required for these purposes provided there are no statutory retention requirements preventing deletion. Statutory retention periods—particularly under commercial- or tax law—may require longer storage periods. Data transmitted in connection with a specific assignment will be deleted after completion of that assignment and expiration of any applicable retention period unless further statutory or contractual storage obligations exist.

  • Processed data types: Inventory data (For example, the 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 phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Software and Platform Services: We process the data of our users, registered and any test users (hereinafter uniformly referred to as “users”) in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to develop it further. The required details are identified as such within the context of the conclusion of the agreement, order or comparable contract and include the details required for the provision of services and invoicing as well as contact information in order to be able to hold any further consultations. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Online shop, order forms, e-commerce and fulfilment of services: We process our customers’ data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and provision, delivery, or execution. If necessary for the execution of an order, we employ service providers, particularly postal services, freight carriers, and shipping companies to carry out delivery or execution for our customers. For processing payment transactions, we use the services of banks and payment service providers. The necessary information is marked as such within the ordering or comparable acquisition process and includes the details required for delivery or provision and billing as well as contact information to facilitate any necessary consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Business processes and operations

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

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.

  • Processed data types: Inventory data (For example, the 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 phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.). Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Customer Account: Customers need to create an account within our online offer (e.g. customer or user account, “customer account” for short). If the registration of a customer account is required, customers will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent registration and use of the customer account, we store the IP addresses of the contractual partners along with the access times, in order to be able to prove the 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 retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the customers’ responsibility to back up their data when terminating the customer Account. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the prevention of misuse and fraud, as well as in ensuring IT security and the verifiability of account actions (e.g. logging of accesses).
  • Customer Management and Customer Relationship Management (CRM): Processes required in the context of customer management and Customer Relationship Management (CRM) include customer acquisition in compliance with data protection regulations, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, management of CRM systems, secure account management, customer segmentation and targeting. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in efficient customer service, maintaining a traceable transaction history, quality assurance, and legal enforcement/defence.
  • Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the efficient management and updating of contact details, ensuring data integrity (e.g. backups) and traceable communication.
  • General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in secure and efficient payment processing, fraud prevention, internal control and the verifiability of payment transactions.
  • Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in proper and efficient accounting, receivables management, internal control and the verifiability of business transactions.
  • Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in proper internal financial management, the preparation of business analyses, and verifiability and audit security.

Use of online platforms for listing and sales purposes

We offer our services on online platforms operated by other service providers. In addition to our privacy policy, the privacy policies of the respective platforms apply. This is particularly true with regard to the payment process and the methods used on the platforms for performance measuring and behaviour-related marketing.

  • Processed data types: Inventory data (For example, the 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 phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Marketing. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Envato Market: Online platform for quotation and sales purposes; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR)
    Our legitimate interest lies in the use of an efficient sales channel via an online platform and the secure and economical processing of orders; Service provider: Envato Pty Ltd (ABN 11 119 159 741) 1. Floor, 121 King Street Melbourne, 3000, Australia; Website: https://envato.com/. Privacy Policy: https://envato.com/privacy/.
  • Paddle Payments: Processing of payments, handling of subscriptions, provision of analytics and reports for sellers, management of buyer inquiries and refunds; Legal Basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: Provided by the service provider; Data Processing Agreement: Provided by the service provider
    Our legitimate interest lies in efficient and secure payment processing, fraud prevention and the management of payment defaults/chargebacks; Service provider: Paddle Payments Limited, The Academy, 42 Pearse Street, Dublin, D02 YX88, Ireland; Website: https://www.paddle.com/. Privacy Policy: https://www.paddle.com/legal/privacy.

Providers and services used in the course of business

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

  • Processed data types: Inventory data (For example, the 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 phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • BuchhaltungsButler: Software for accounting, communication with tax advisors as well as authorities and including document storage; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in efficient, proper accounting, including document management, as well as the traceability and internal control of business transactions; Service provider: BuchhaltungsButler GmbH, Spreestraße 5, 15913 Märkische Heide, Germany; Website: https://www.buchhaltungsbutler.de/. Privacy Policy: https://www.buchhaltungsbutler.de/datenschutzbestimmungen/.

Payment Procedure

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively referred to as “payment service providers”). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, ensuring that the data entered is protected from unauthorized access during transmission.

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the 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 terms and conditions and data protection information of the payment service providers.

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

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Paddle Payments (Payment): Payment services (technical connection of online payment methods); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR); Standard contractual clauses: Provided by the service provider; Data processing agreement: Provided by the service provider; Service provider: Paddle Payments Limited, The Academy, 42 Pearse Street, Dublin, D02 YX88, Ireland; Website: https://www.paddle.com/. Privacy Policy: https://www.paddle.com/legal/privacy.
  • Stripe: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://stripe.com/de; Privacy Policy: https://stripe.com/en-de/privacy. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
  • PayPal: Payment-Service-Provider (technical integration of online-payment-methods) (e.g. PayPal, PayPal Plus, Braintree, 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 a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.paypal.com. Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.

Provision of online services and web hosting

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

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and usability. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web hoster”). Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the secure and efficient operation and stable provision of our online services (hosting), including error analysis and misuse prevention.
  • Content-Delivery-Network: We use a so-called “Content Delivery Network” (CDN) from Cloudflare. A CDN is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet. Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the high-performance and fail-safe delivery of our online offering and protection against attacks (e.g. DDoS) and misuse.
  • Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called “server log files”. Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user’s operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
    Our legitimate interest lies in ensuring IT security and stability, analysing errors, and investigating and tracking abusive or security-related access.
  • MaxMind (self-hosted): geolocation and fraud prevention services, helping businesses identify user locations and detect fraudulent activities for enhanced security; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the prevention of fraud and abuse, as well as the protection of our systems and user accounts through plausibility checks and risk assessment of access attempts. Website: https://www.maxmind.com.
  • Cloudflare: Content-Delivery-Network (CDN) – service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://www.cloudflare.com/cloudflare-customer-scc/; Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/
    Our legitimate interest lies in the secure, fast and reliable delivery of our online services and the protection of our infrastructure against attacks and misuse; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Website: https://www.cloudflare.com. Privacy Policy: https://www.cloudflare.com/privacypolicy/.
  • New Relic: Server monitoring und error detection; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: Provided by the service provider; Retention period: The aggregated data are deleted after three months, the pseudonymised data after seven days.
    Our legitimate interest lies in monitoring and optimising the stability, availability and performance of our online offering, as well as in the rapid detection and correction of errors; Service provider: New Relic, Inc. Attn: Legal Department 188 Spear Street, Suite 1200 San Francisco, CA 94105, USA; Website: https://newrelic.com. Privacy Policy: https://newrelic.com/termsandconditions/privacy.
  • Demo/sandbox environment (test instances): We provide interested parties and users with an optional demo or sandbox environment in which our products can be tested in a temporary test instance. Personal data is processed to the extent necessary for the provision, security and operation of the test instance.
    Legal basis: Legitimate interests (Art. 6(1)(f) GDPR)
    Our legitimate interest lies in providing a secure testing environment (demo/sandbox) and protecting the test instances against misuse and ensuring stable operation.
  • Algolia (Website-Suche / Suchindexierung): We use the Algolia service to provide the search function on our website. For this purpose, content from our website is transferred to a search index so that visitors can find content more quickly. When you use the search function, your search queries and technical access data are processed in order to deliver search results and ensure the stability and security of the search function.
    Please do not enter any personal data in the search field if possible. However, if search queries or other content do contain personal data (e.g. names, email addresses or ticket/order numbers), this data will be processed accordingly as part of the search query.
    Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR)
    Our legitimate interest lies in providing a user-friendly, fast website search function and ensuring the stability, security and prevention of misuse of the search function; Service provider: Algolia SAS, 55 Rue d’Amsterdam, 75008 Paris, France; Website: https://www.algolia.com/. Privacy Policy: https://www.algolia.com/policies/privacy.
  • netcup: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.netcup.de/; Privacy Policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php. Data Processing Agreement: https://www.netcup-wiki.de/wiki/Zusatzvereinbarung_zur_Auftragsverarbeitung.
  • Scaleway: Cloud hosting, provision of virtual servers and dedicated servers, storage of data in the cloud, Content Delivery Network (CDN) services, management and scaling of applications, network services including load balancing and DNS management; Service provider: SCALEWAY SAS BP, 8 rue de la Ville l’Evêque, 75008 Paris, France; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.scaleway.com/; Privacy Policy: https://www.scaleway.com/en/privacy-policy/. Data Processing Agreement: https://www.scaleway.com/en/contracts/.
  • Elestio: Automated provisioning and management of cloud servers, continuous integration and deployment (CI/CD), monitoring of server performance, data backup and recovery, application scaling, management of security updates and patches; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Data Processing Agreement: https://docs.elest.io/books/legal-compliance/page/elestio-data-processing-agreement; Service provider: Elestio Limited, 66 Fitzwilliam Square, Dublin 2 D02 AT27, Ireland; Website: https://elest.io/. Privacy Policy: https://docs.elest.io/books/legal-compliance/page/privacy-policies.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read it from them. Cookies can also be used for different purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.

Information on legal data protection bases: Whether we process personal data using cookies depends on users’ consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as outlined in this section and in the context of the respective services and procedures.

Storage duration: The following types of cookies are distinguished based on their storage duration:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user revisits a website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that these are permanent and may have a storage duration of up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to the processing according to legal regulations, including through the privacy settings of their browser.

  • Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Real Cookie Banner: Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users’ devices as well as their processing; Legal Basis: Compliance with a legal obligation (Art. 6(1)(c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the legally compliant collection, management and documentation of consents, as well as in the technical provision of a functional consent management system (including proof and implementation of revocations/objections); Service provider: Executed on servers and/or computers under our controllership. Website: https://devowl.io/de/wordpress-real-cookie-banner/.

Registration, Login and User Account

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).

Within the scope of using 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 the user’s protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users may be informed by e-mail of information relevant to their user account, such as technical changes.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”. Deletion after termination.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Registration with a real name: Due to the nature of our community, we ask users to use our services only with their real names. This means that the use of pseudonyms is not permitted; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Users’ profiles are public: The users’ profiles are not publicly visible or accessible.
  • Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Gravatar Profile Pictures: We use the Gravatar service within our customer centre. Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (especially in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the only purpose of transmitting the email address and it will not be used for other purposes, but deleted thereafter.
    The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer authors of contributions and comments the opportunity to personalize their contributions with a profile picture.
    By displaying the images, Gravatar knows the IP address of the user, as this is necessary for communication between a browser and an online service.
    If users do not want a user image linked to their e-mail address to appear in the comments at Gravatar, they should use an e-mail address which is not stored at Gravatar for commenting. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: Provided by the service provider; Data Processing Agreement: Provided by the service provider; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Website: https://automattic.com. Privacy Policy: https://automattic.com/privacy.
  • VG Word / Scalable Central measurement method: VG Word / Scalable Central measurement method – We use the METIS access counting of VG WORT to measure accesses to online texts that we provide to you through our service. We do this so that the likelihood of copying these texts can be captured. The likelihood of a text being copied forms the basis of a lawful distribution of remunerations according to the Copyright Act (UrhG) by VG WORT to the authors and publishers of these texts. For this purpose, a “counting mark” is integrated into the source code of the respective online text as part of the METIS access counting. This counting mark is a unique ID assigned to this particular text and ensures that when a text marked in this way is visited, an access to this text can be counted. Furthermore, as part of the METIS access counting, a client ID is formed. With the help of this client ID and a session cookie, it can be recognized whether the text has already been accessed by this user within a browser session or not. This is to prevent unlawful multiple counts of this text in the determination of its likelihood of copying. No individual users are identified at any time. Your identity always remains protected. You will not receive any advertising through the system; Legal Basis: Consent (Article 6 (1) (a) GDPR); Service provider: Verwertungsgesellschaft WORT (VG WORT), Untere Weidenstraße 5, 81543 Munich, Germany; Website: https://www.vgwort.de. Privacy Policy: https://www.vgwort.de/datenschutz.html.

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Slack: Team communication and collaboration, real-time messaging, file and document sharing, integration with third-party tools, video and voice calls, channels for topic-specific discussions, search function for messages and files; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://slack.com/intl/de-de/terms-of-service/data-processing; Data Processing Agreement: https://slack.com/intl/de-de/terms-of-service/data-processing; Further Information: Security measures: https://slack.com/intl/en-gb/security-practices
    Our legitimate interest lies in efficient, traceable internal communication and collaboration (including file/information exchange) as well as in ensuring IT security and preventing misuse; Service provider: Slack Technologies Limited, Salesforce Tower, 60 R801, North Dock, Dublin, Ireland; Website: https://slack.com/. Privacy Policy: https://slack.com/legal.
  • Sipgate: Internet-based communication platform that enables calls to be made, text messages or faxes to be sent, and other communication procedures to be carried out; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the reliable, efficient execution of business telephone/fax communication and in ensuring system security, quality assurance and the prevention of misuse/spam; Service provider: sipgate GmbH, Gladbacher Str. 74, 40219 Düsseldorf, Germany; Website: https://www.sipgate.de/. Privacy Policy: https://www.sipgate.de/datenschutz.
  • Reamaze: Reamaze is a comprehensive customer service and support platform. Reamaze offers numerous uses, including multi-channel support (email, live chat, social media), ticketing systems, automations for common requests, real-time customer interactions, integration with third-party tools (such as Shopify, Slack, and other CRM systems), customer feedback tools, analytics and reporting capabilities, and customizable self-service portals for customers.Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1) (b) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR)
    Data processing agreement: https://www.reamaze.com/dpa
    Our legitimate interest lies in the efficient, structured processing of support and service requests (ticketing/multi-channel), quality assurance in customer service, as well as the traceability of processes and prevention of misuse; Service provider: Legal, Office of the Data Privacy Officer, Reamaze c/o WeWork, Friesenplatz 4, 50672 Köln, Germany; Website: https://www.reamaze.com/. Privacy Policy: https://www.godaddy.com/legal/agreements/privacy-policy.
  • Amazon Web Services (AWS) SES: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space, computing capacities for email delivery); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://aws.amazon.com/en/service-terms/; Data Processing Agreement: https://aws.amazon.com/compliance/gdpr-center/
    Our legitimate interest lies in the secure, scalable and reliable sending of emails (including deliverability/error analysis) as well as in preventing misuse (e.g. spam) and ensuring system stability; Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg; Website: https://aws.amazon.com/. Privacy Policy: https://aws.amazon.com/privacy/.
  • E-mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the secure and efficient operation of our email infrastructure (sending, receiving, storage), including spam/malware detection, error diagnosis and ensuring availability and IT security; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Security information: https://cloud.google.com/security/privacy; Standard contractual clauses (guaranteeing data protection when processing in third countries): https://cloud.google.com/terms/data-processing-terms; Website: https://www.google.com/gmail/about/. Privacy Policy: https://www.google.com/policies/privacy.
  • Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the efficient processing and allocation of enquiries, as well as in protecting our systems against misuse (e.g. spam) and ensuring technical stability.

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 using the Conference Platforms and their services, we comply with the legal requirements.

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

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

Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.

Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users’ data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing 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 (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings. Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Persons depicted.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Communication. Office and organisational procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Meet: Conference and communication software; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR), Contract fulfilment and pre-contractual enquiries (Art. 6 (1) (b) GDPR); Standard Contractual Clauses: https://cloud.google.com/terms/eu-model-contract-clause; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum
    Our legitimate interest lies in the efficient and secure execution of online meetings for communication with customers/partners, as well as in ensuring stability, quality and protection against misuse; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Website: https://meet.google.com/. Privacy Policy: https://policies.google.com/privacy.
  • Gather: Virtual spaces for online collaboration, video and text communication, integration of third-party applications, customisation of avatars and environments, hosting of virtual events; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR), Contract fulfilment and pre-contractual enquiries (Art. 6 (1) (b) GDPR); Standard Contractual Clauses: https://www.gather.town/dpa; Data Processing Agreement: https://www.gather.town/dpa
    Our legitimate interest lies in efficient online collaboration and communication, as well as in the secure and stable provision of the platform and the prevention of misuse; Service provider: Gather Presence, Inc., 2261 Market St. #4095, San Francisco, CA, 94114, USA; Website: https://www.gather.town. Privacy Policy: https://www.gather.town/privacy-policy.

Cloud Services

We use Internet-accessible software services (so-called “cloud services”, also referred to as “Software as a Service”) provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider’s servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

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

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.). Business and contractual partners.
  • Purposes of processing and legitimate interests: Office and organisational procedures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Workspace: Cloud storage, cloud infrastructure services and cloud-based application software such as Gmail (E-Mail), Google Drive (file storage), Google Docs/Sheets, Google Forms and Google Meet (video conferences); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://cloud.google.com/terms/eu-model-contract-clause; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Further Information: https://cloud.google.com/privacy
    Our legitimate interest lies in the efficient and secure operation of central work and collaboration processes (e.g. email, documents, file storage), including IT security, availability, backup and organisational purposes; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Website: https://workspace.google.com/. Privacy Policy: https://policies.google.com/privacy.

Newsletter and Electronic Communications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users’ consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to demonstrate previously given consent. The processing of these data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed. In case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.

Contents:

Information about us, our services, promotions and offers as well as news about WordPress and related topics.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Direct marketing (e.g. by e-mail or postal).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • 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 cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing methods, procedures and services used:

  • Amazon Web Services (AWS) SES: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space, computing capacities for email delivery); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://aws.amazon.com/en/service-terms/; Data Processing Agreement: https://aws.amazon.com/compliance/gdpr-center/
    Our legitimate interest lies in the secure, scalable and reliable sending of emails (including deliverability/error analysis) as well as in preventing misuse (e.g. spam) and ensuring system stability; Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg; Website: https://aws.amazon.com/. Privacy Policy: https://aws.amazon.com/privacy/.
  • Mailster (Self-hosted): Mailster is a WordPress plugin for creating and managing email newsletters. The service offers numerous capabilities, including drag-and-drop editors for newsletter designs, automated email campaigns, detailed analytics and reporting, real-time statistics on open rates and click-through rates, and segmentation of recipients. Mailster makes it easy to manage subscribers and offers extensive functions for personalizing and optimizing email marketing campaigns.Legal bases: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR)
    Our legitimate interest lies in the efficient technical implementation and administration of the newsletter dispatch (including process and system operation) as well as in the traceability of dispatch processes and system security. Website: https://mailster.co/.
  • Measurement of opening rates and click rates: The newsletters contain what is known as a “web beacon”, i.e. a one-pixel file that is retrieved from our server, or the server of our Service Provider if we use a mailing service, when the newsletter is opened. During this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of retrieval are collected. This information is used to improve our newsletters technically based on the technical data or to analyse target groups and their reading behaviour according to their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The collected information is assigned to individual newsletter recipients and stored in their profiles until deletion. On this basis, user profiles are created in which usage behaviour and user characteristics are stored. The measurement of open and click rates, as well as the storage of measurement results in users’ profiles and further processing thereof, takes place on the basis of users’ consent. It is unfortunately not possible to separately withdraw consent for performance measurement; in this case, the entire newsletter subscription must be cancelled or objected to. In such cases, the stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • Zoho Mail: E-mail hosting (provision of server and computer capacity for the purpose of sending and receiving e-mails with security features (anti-spam and anti-virus filters); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Further Information: https://www.zoho.com/gdpr.html
    Our legitimate interest lies in secure and reliable email operation, including spam/malware filtering, ensuring availability, technical error analysis and IT security; Service provider: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany; Website: https://www.zoho.com/mail/. Privacy Policy: https://www.zoho.com/privacy.html.
  • Smartlead: Platform for email management/automation; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); we use Smartlead as a processor. Smartlead provides a Data Processing Addendum (DPA), https://www.smartlead.ai/dpa; the DPA also includes Standard Contractual Clauses (SCCs) as an appropriate safeguard for transfers to third countries.
    Our legitimate interest lies in the efficient organisation and automation of email communication (e.g. workflows/campaign management) as well as in quality assurance (deliverability/error analysis) and traceability of communication processes; Service provider: 521 PRODUCTS PTY LTD (ACN 645 593 835), 18 Tallow Place, Glenwood NSW 2768, Australia; Website: https://www.smartlead.ai/. Privacy Policy: https://www.smartlead.ai/privacy-policy.

Commercial communication by E-Mail, Postal Mail, Fax or Telephone

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

The recipients have the right to withdraw their consent at any time or to object to the advertising communication at any time free of charge using the contact options mentioned above.

After revocation or objection, we store the data required to prove the past authorization to contact or send up to three years from 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. Based on the legitimate interest to permanently observe the revocation, respectively objection of the users, we further store the data necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Direct marketing (e.g. by e-mail or postal); Marketing. Sales promotion.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Order process reminder emails: When users cancel an order process, we can send them a notice of the cancellation and remind them to continue. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight or forgetting. The dispatch is based on the legitimate interest, which the user can object to at any time. The legitimate interest here is that we assume that the customer should be reminded that he has not concluded a contract (if the cancellation was not intentional) and to give the customer the opportunity to remind him once of the uncompleted order process; legal basis: legitimate interest (Art. 6 (1) (f) GDPR)
    Our legitimate interest lies in the unique, user-friendly reminder of an abandoned order process in order to reduce false cancellations and enable the completion of a process initiated by the user. at the same time, this serves the economic operation of our online offering.

Sweepstakes and Contests

We process the personal data of participants in We process personal data of participants in competitions, contents, raffles, prize-draws or sweepstakes (hereinafter referred to as “competitions”) only in compliance with the relevant data protection regulations and if the processing is contractually necessary 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 by possible recording of IP addresses when submitting entries to the competition.

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

If the competitions take place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective online platforms also apply. In such 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 we must be contacted with regard to the competitions.

The data of the participants will be deleted as soon as the competition has ended and the data is no longer required to inform the winners or because questions about the competition can be expected. In general, the data of the participants will be deleted at the latest 6 months after the end of the competition. Winners’ data can be retained for a longer period of time, e.g. in order to answer questions about the prizes or to fulfil the prizes; 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, the participants’ data may be stored for longer, e.g. in the form of coverage of the competition in online and offline media.

Insofar as data was collected for other purposes as part of the competition, its processing and storage period shall be governed by the privacy information for this use (e.g. in the case of registration for a newsletter as part of a competition).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Participants in sweepstakes and competitions.
  • Purposes of processing and legitimate interests: Conducting sweepstakes and contests.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Surveys and Questionnaires

We conduct surveys and interviews to gather information for the survey purpose communicated in each case. The surveys and questionnaires (“surveys”) carried out by us are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address to display the survey in the user’s browser or to enable a resumption of the survey with the aid of a cookie).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Participants.
  • Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Polls and Questionnaires (e.g. surveys with input options, multiple choice questions).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Web Analysis, Monitoring and Optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the visitor flows of our online services and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age or gender. Through reach analysis, we can, for example, identify when our online services or their functions and content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas need optimization.

In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online services or their components.

Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these purposes, and information can be stored in and later retrieved from a browser or device. The data collected includes, in particular, visited websites and elements used on them, as well as technical information such as the browser used, the computer system, and information about usage times. If users have given consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

Additionally, users’ IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the respective procedures.

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

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Web Analytics (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (Creating user profiles).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention 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 (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Matomo: Matomo is software used for web analysis and reach measurement purposes. When using Matomo, cookies may be generated and stored on the user’s device with their consent, and heat maps, session recordings and A/B tests may be carried out. If consent is not given, Matomo is used without cookies and returning users are recognised using a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours. With “digital fingerprinting”, user movements within our online offering are recorded with the help of pseudonymised IP addresses in combination with user browser settings in such a way that it is not possible to draw conclusions about the identity of individual users. The user data collected in the context of using Matomo is only processed by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR);
    Our legitimate interest lies in measuring the reach and optimising our online offering in line with demand (including error analysis and improving user-friendliness) in order to provide content and functions efficiently and in a recipient-friendly manner. Website: https://matomo.org/.

Affiliate-Programms und Affiliate-Links

Within our online services, we include so-called affiliate links or other references (which for example may include search forms, widgets or discount codes) to the offers and services of third parties (collectively referred to as “affiliate links”). When users follow affiliate links or subsequently take advantage of offers, we may receive commission or other benefits (collectively referred to as “commission”) from these third parties.

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

For the purposes of the aforementioned affiliate link assignment, the affiliate links may be supplemented by certain values that may be a component of the link or otherwise stored, for example, in a cookie. The values may include in particular the source website (referrer), 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.

Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Prospective customers. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Affiliate Tracking.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Affiliate Program

We offer an affiliate program, i.e. we offer commissions or other benefits (collectively referred to as “Commission”) to users (collectively referred to as “Affiliates”) who refer to our offers and services. The reference is made through a link associated with the Affiliate or other methods (e.g., discount codes) that allow us to recognize that the use of our services was based on the reference (collectively referred to as “Affiliate Links”).

In order to track whether users have perceived our services based on affiliate links used by affiliates, it is necessary for us to know that users have followed an affiliate link. The assignment of affiliate links to the respective business transactions or other use of our services serves solely the purpose of Commission billing and will be cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned affiliate link assignment, the affiliate links may be supplemented by certain values that may be a component of the link or otherwise stored, for example, in a cookie. The values may include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective service, the type of link used, the type of service and an online identifier of the user.

Information on legal basis: The processing of the data of our partners is carried out for the provision of our (pre)contractual services. The users’ data is processed on the basis of their consent.

  • Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Data subjects: Users (e.g. website visitors, users of online services). Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Affiliate Tracking.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Affiliate Tracking: Our own affiliate tracking as part of the use of our online platform for offering and sales purposes enables us to pay commissions to bloggers or YouTubers, for example, for redirecting traffic to our website when a purchase has been successfully completed. The tracking is used for billing purposes and no adjustments are made to the content or prices on our website. If you agree, cookies are used to remember which partner and which partner link you used to access our website.
    Legal basis: Consent (Art. 6 (1) (a) GDPR).

Customer Reviews and Ratings

We participate in review and rating procedures to evaluate, optimise and advertise our performance. If users rate us via the participating rating platforms or methods or otherwise provide feedback, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective provider.

In order to ensure that the evaluators have actually made use of our services, we transmit, with the consent of the customer, the necessary data relating to the customer and the service or products used to the respective rating platform (this includes the name, e-mail address, order number or article number). This data is used solely to verify the authenticity of the user.

  • Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Marketing.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • WordPress.org: Website-platform with ratings
    Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR)
    Our legitimate interest lies in the transparent presentation and quality assurance of our services/products through a public rating and feedback system, as well as in improving our offering based on user feedback; Service provider: WordPress.org, 660 4TH St San Francisco, CA, 94107, USA; Website: https://wordpress.org/. Privacy Policy: https://wordpress.org/about/privacy/.

Profiles 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 entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data, which is used to create “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. It also includes details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as profile details of users, such as job function, country, industry, seniority, company size, and employment status. LinkedIn can also be used for general networking purposes. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
    We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum,” https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must comply with and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of users (particularly the right to information, deletion, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by our agreements with LinkedIn. The joint responsibility is limited to the collection of data and its transmission to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly concerning the transfer of data to the parent company LinkedIn Corporation in the USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://legal.linkedin.com/dpa; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
    Our legitimate interest lies in public relations and communication via a professional network, as well as in the statistical evaluation of reach/interactions (insights) in order to optimise content for specific target groups and improve our external image; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com. Privacy Policy: https://www.linkedin.com/legal/privacy-policy.
  • YouTube: Social network and video platform; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR), Consent (Art. 6(1)(a) GDPR); Opt-Out: https://myadcenter.google.com/personalizationoff
    Our legitimate interest lies in public relations work through the provision of video content and in optimising our communication and reach in order to provide information about our services in a manner appropriate to the target group; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://policies.google.com/privacy.

Plugins and embedded functions and content

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

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: 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 behaviour, use of cookies); Affiliate Tracking. Marketing.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention 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 (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • YouTube videos: Video contents; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.
  • Cloudflare Turnstile: Automated detection and prevention of bot activities. Provision of a CAPTCHA-like service that operates without user input. Improvement of user experience by minimising interruptions for genuine users. Collection and analysis of data to distinguish between human and automated access to web services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Standard Contractual Clauses: https://www.cloudflare.com/cloudflare-customer-scc/; Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/
    Our legitimate interest lies in defending against bot traffic, spam and abusive access, securing forms/interactions and ensuring the availability, integrity and security of our systems; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Website: https://www.cloudflare.com/products/turnstile/. Privacy Policy: https://www.cloudflare.com/privacypolicy/.

Management, Organization and Utilities

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

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

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Office and organisational procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Corporate Benefits: Provision of employee benefits and fringe benefits for employees (so-called corporate benefits); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in increasing our attractiveness as an employer and in employee retention and motivation by providing voluntary additional benefits; Service provider: corporate benefits Germany GmbH, Schiffbauerdamm 40, 10117 Berlin, Germany; Website: https://www.corporate-benefits.eu/. Privacy Policy: https://www.corporate-benefits.eu/privacy-policy.
  • ClickUp: Project management – organization and administration of teams, groups, workflows, projects and processes; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Data Processing Agreement: https://clickup.com/terms/dpa
    Our legitimate interest lies in the efficient organisation and management of projects, tasks and workflows (including documentation and collaboration) as well as in ensuring internal traceability and organisational security; Service provider: Mango Technologies, Inc., 580 Howard St, Suite 101, San Francisco, California 94105, USA; Website: https://clickup.com/. Privacy Policy: https://clickup.com/privacy.

Processing of data in the context of employment relationships

In the context of employment relationships, the processing of personal data aims to effectively manage the establishment, execution, and termination of such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.

The data processing covers various aspects ranging from contract initiation to termination. Included are the organization and management of daily working hours, management of access rights and permissions, as well as handling personnel development measures and staff appraisals. The processing also serves payroll accounting and management of wage and salary payments, which represent critical aspects of contract execution.

Additionally, the data processing considers legitimate interests of the responsible employer, such as ensuring workplace safety or capturing performance data for evaluating and optimizing operational processes. Moreover, the data processing includes disclosing employee data in external communication and publication processes where necessary for operational or legal purposes.

The processing of this data always takes place with due regard for the applicable legal frameworks, aiming always to create and maintain a fair and efficient working environment. This also includes considering the privacy of affected employees, anonymizing or deleting data after fulfilling the processing purpose or according to legal retention periods.

  • Processed data types: Employee Data (Information about employees and other individuals in an employment relationship); Payment Data (e.g. bank details, invoices, payment history). Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
  • Purposes of processing and legitimate interests: Establishment and execution of employment relationships (Processing of employee data in the context of the establishment and execution of employment relationships). Business processes and management procedures.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR).

Further information on processing methods, procedures and services used:

  • Time Recording: Processes for recording employees’ working hours include both manual and automated methods, such as the use of punch clocks, time tracking software, or mobile apps. Activities involved include entering clock-in and clock-out times, break times, overtime, and absences. To verify and validate the recorded working hours, they are compared with deployment or shift schedules, checked for absences, and approved for overtime by supervisors. Reports and analyses are generated based on the recorded working hours to provide work time records, overtime reports, and absence statistics for management and the human resources department. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the efficient organisation and traceability of working hours (e.g. for planning, billing, internal control) as well as in the prevention of misuse and ensuring correct time data.
  • Authorization Management: Procedures required for the definition, management, and control of access rights and user roles within a system or an organisation (e.g., creation of authorisation 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: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in protecting our IT systems and data through role- and access-based access controls, preventing unauthorised use, and fulfilling internal security and verification requirements.
  • Special categories of personal data (employment relationship): Special categories of personal data are processed in the context of employment relationships or to fulfil legal obligations. The processed special categories of personal data include information concerning the health, trade union membership, or religious affiliation of employees. This data may be transferred to health insurance companies or processed for assessing the employees’ work capacity, for corporate health management, or for declarations to the tax authorities. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR, Art. 9 (2) (b) GDPR), Legal obligation (Art. 6 (1) (c) GDPR), Processing of special categories of personal data relating to health, professional life and social security (Art. 9 (2) (h) GDPR).
  • Sources of Processed Data: Personal data received during the application process and/or employment relationship will be processed. Furthermore, where required by law, personal data will be collected from other sources. These may include financial authorities for tax-related information, the respective health insurance company for information on work incapacity, third parties such as employment agencies, or publicly accessible sources like professional social networks in the context of application procedures. Legal Basis: Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the efficient execution of HR processes (e.g. comparison/validation of information, administrative processing) as well as in the prevention of abuse and fraud and legal defence, where necessary.
  • Purposes of Data Processing: The personal data of employees are primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, the processing of this data is necessary to fulfil legal obligations in the field of tax and social security law. In addition to these primary purposes, the data of employees are also used to meet regulatory and supervisory requirements, to optimise processes of electronic data processing, and to compile company-internal or cross-company data, possibly including statistical data. Moreover, the data of employees may be processed for the assertion of legal claims and defense in legal disputes. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in optimising and ensuring proper business operations (including internal IT and process organisation), information security, and the assertion or defence of legal claims.
  • Transmission of Employee Data: The data of employees is processed internally only by those departments that require it to fulfil operational, contractual, and legal obligations. The transfer of data to external recipients only occurs if it is legally required, or if the affected employees have given their consent. Possible scenarios for this can include requests for information from authorities or in the case of asset formation benefits. Furthermore, the controller may transfer personal data to further recipients as far as this is necessary for fulfilling his contractual and legal obligations as an employer. These recipients can include: a) banks b) health insurance companies, pension insurance institutions, providers of old-age provisions and other social insurance carriers c) authorities, courts (e.g., tax authorities, labour courts, further supervisory authorities within the framework of fulfilling reporting and information obligations) d) tax and legal advisors e) third-party debtors in the case of wage and salary garnishments f) other entities to which legally obligatory declarations must be made.
    In addition, data can be transferred to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples include details in the sender area of emails or letterheads as well as creating profiles on external platforms. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in efficient external communication and cooperation (e.g. contact persons/senders in correspondence), the involvement of necessary service providers, and the protection and defence of legal interests.
  • Business Travel and Travel Expense Settlement: Procedures required for planning, executing, and accounting for business trips (e.g., booking of travel, organizing accommodations and transportation, managing travel expense advances, submitting and reviewing travel expense reports, controlling and recording incurred costs, compliance with travel policies, handling of the travel expense management). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in the efficient organisation, execution and billing of business trips, cost control, the prevention and investigation of misuse (e.g. implausible expense claims) and the traceability of expenses.
  • Payroll and wage accounting: Procedures required for calculating, disbursing, and documenting wages, salaries, and other remuneration for employees (e.g., recording of working hours, calculation of deductions and surcharges, remittance of taxes and social security contributions, preparation of payroll statements, management of wage accounts, reporting to the tax authorities and social security institutions); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR).
  • Deletion of Employee Data: Employment data will be deleted under German law when it is no longer required for the purpose for which it was collected, unless there is a legal obligation to retain or archive it, or it needs to be kept for the interests of the employer. The following retention and archiving obligations are observed:
    • General personnel records – General personnel records (such as employment contracts, references, supplementary agreements) are retained for up to three years after the termination of the employment relationship (§ 195 German Civil Code (BGB)).
      Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
      Information on wages and working hours – Information on wages and working hours for (accident) insured with wage proof are kept for five years (§ 165 I 1, IV 2 Social Code Book VII (SGB VII)).
    • Payrolls including lists for special payments – Payrolls including lists for special payments, if a booking receipt is available, are kept for ten years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
    • Wage lists for interim, final, and special payments – Wage lists for interim, final, and special payments are kept for six years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
    • Documents on employee insurance – Documents on employee insurance, if booking receipts are available, are kept for ten years (§ 147 Tax Code (AO), § 257 Commercial Code (HGB)).
    • Contribution statements to social security institutions – Contribution statements to social security institutions are kept for ten years (§ 165 Social Code Book VII (SGB VII)). Wage accounts – Wage accounts are kept for six years (§ 41 I 9 Income Tax Act (EStG)).
    • Applicant data – Kept for a maximum of six months from the receipt of rejection.
    • Working time records (for more than 8 hours on workdays) – Kept for two years (§ 16 II Working Time Act (ArbZG)).
    • Application documents (following online job advertisement) – Kept for three to a maximum of six months from the receipt of rejection (§ 26 Federal Data Protection Act (BDSG) n.F., § 15 IV General Act on Equal Treatment (AGG)).
    • Certificates of incapacity for work (AU) – Kept for up to five years (§ 6 I Act on the Compensation of Expenses (AAG)).
    • Documents on company pension schemes – Kept for 30 years (§ 18a Act to Improve Occupational Pensions (BetrAVG)).
    • Sickness data of employees – Kept for twelve months from the start of the illness, if the absence in a year does not exceed six weeks.
    • Documents on maternity protection – Kept for two years (§ 27 para. 5 Maternity Protection Act (MuSchG)).

    . Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR).

  • Personnel file management: Procedures required for the organisation, updating, and management of employee data and records (e.g., recording of basic personnel data, retention of employment contracts, certificates and attestations, updating data upon changes, compilation of documents for employee discussions, archiving of personnel files, compliance with data protection regulations). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR)
    Our legitimate interest lies in orderly, traceable personnel management (e.g. documentation of agreements and measures), internal organisation and the assertion or defence of legal claims.
  • Personnel development, performance evaluation, and staff appraisals: Procedures required in the area of employee promotion and development, as well as in assessing their performance and during employee discussions (e.g., needs analysis for further training, planning and implementation of training measures, creation of performance evaluations, conducting goal-setting and feedback discussions, career planning and talent management, succession planning). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR), Healthcare, occupational and social security processing of special categories of personal data (Article 9 (2)(h) GDPR)
    Our legitimate interest lies in the promotion and further development of employees, quality assurance in service provision, as well as in transparent personnel decisions (e.g. deployment/career planning) and the documentation of measures.
  • Obligation to Provide Data: The person in charge informs the employees that the provision of their data is required. This is generally the case when the data are necessary for the establishment and execution of the employment relationship, or when their collection is mandated by law. The provision of data may also be required when employees assert claims or are entitled to claims. The implementation of these measures or fulfilment of services depends on the provision of such data (for example, providing data for the receipt of wages). Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies in ensuring the smooth and secure running of the employment relationship (e.g. wage payments, communication, IT access) and in avoiding organisational disruptions.
  • Publication and Disclosure of Employee Data: The data of employees will only be published or disclosed to third parties if it is necessary for the performance of work tasks according to the employment contract. This applies, for example, when employees are named as contact persons in correspondences, on the website, or in public registers following an agreement or specified job description, or if their field of work includes representative functions. Similarly, this may occur if representation or communication with the public takes place as part of performing these tasks, such as image recordings during public relations activities. Otherwise, employee data is published only with their consent or based on the legitimate interests of the employer, for example, in the case of stage or group photographs taken during a public event. Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR)
    Our legitimate interest lies – where necessary and appropriate – in efficient internal and external accessibility (e.g. contact person function), the presentation of operational responsibilities and public relations work (e.g. team presentation), insofar as this serves business operations.

Job Application Process

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 information contained therein.

In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.

Where available, applicants are welcome to submit their applications via our online form, which is securely encrypted to the latest standards. Alternatively, applications can also be sent to us by email. However, we kindly remind you that emails are not inherently encrypted over the Internet. While emails are usually encrypted in transit, they are not encrypted on the servers from which they are sent and received. Therefore, we cannot assume responsibility for the security of the application during its transmission from the sender to our server.

Processing of special categories of data: To the extent that special categories of personal data (Article 9(1) GDPR, e.g., health data, such as disability status or ethnic origin) are requested from applicants or communicated by them during the application process, their processing is carried out so that the controller or the data subject can exercise rights arising from employment law and the law of social security and social protection, in the case of protection of vital interests of the applicants or other persons, or for purposes of preventive or occupational medicine, for the assessment of the employee’s work ability, for medical diagnosis, for the provision or treatment in the health or social sector, or for the management of systems and services in the health or social sector.

Ereasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. 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, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, the deletion will take place at the latest after the expiry of a period of six months, so that we can answer any follow-up questions regarding the application and comply with our duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Admission to a talent pool – Admission to a talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
  • Data subjects: Job applicants.
  • Purposes of processing and legitimate interests: Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”.
  • Legal Basis: Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • LinkedIn Recruiter: Job search and application related services within the LinkedIn platform; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Data Processing Agreement: https://www.linkedin.com/legal/l/dpa
    Our legitimate interest lies in efficient recruitment, identifying and approaching suitable candidates via professional networks, and optimising and documenting our application and selection processes (including traceability and quality assurance); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com. Privacy Policy: https://www.linkedin.com/legal/privacy-policy.

Changes and Updates

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • Affiliate Tracking: Affiliate tracking logs links that the linking websites use to refer users to websites with products or other offers. The owners of the respective linked 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). To this end, it is necessary for providers to be able to track whether users who are interested in certain offers subsequently follow 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), time, an online identification of the owner of the website on which the affiliate link was located, an online identification of the respective offer, an online identifier of the user, as well as tracking specific values such as advertising media ID, partner ID and categorizations
  • Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
  • Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
  • Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
  • Controller: “Controller” means 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.
  • Employees: As employees, individuals are those who are engaged in an employment relationship, whether as staff, employees, or in similar positions. Employment refers to a legal relationship between an employer and an employee, established through an employment contract or agreement. It entails the obligation of the employer to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various stages, including establishment, where the employment contract is concluded, execution, where the employee carries out their work activities, and termination, when the employment relationship ends, whether through termination, mutual agreement, or otherwise. Employee data encompasses all information pertaining to these individuals within the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and banking information, working hours, holiday entitlements, health data, and performance assessments.
  • Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
  • Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
  • Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
  • Payment Data: Payment data comprise all information necessary for processing 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 account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
  • Personal Data: “personal data” means any information relating to an identified or identifiable natural person (“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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Targeting: “Tracking” is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
  • Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.

Participation of Real Cookie Banner in the “Transparency & Consent Framework” (TCF)

We participate in the TCF with our product Real Cookie Banner as a consent management platform with the identification number 367 and adhere to its specifications and guidelines. The TCF is a standard developed by IAB Europe that serves to standardise the storage of consent for cookies and data processing, as well as the relevant settings, and to transmit this information to participating providers so that they can take the decisions of the individuals concerned into account. Typically, a consent signal (“TC string”) is generated for this purpose. However, we do not use the TCF on this website and no TC string is created or transmitted to advertising/analysis partners.