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André Daus
Red Team Coaching & Consulting

Privacy Policy

Last Updated: May 25, 2025

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”).

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Table of contents

Controller

André Daus
c/o Block Services
Stuttgarter Str. 106
70736 Fellbach
Germany

E-mail address: kontakt@andredaus.com

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data.
  • Employee Data.
  • Payment Data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Images and/ or video recordings.
  • Audio recordings.
  • Log data.

Special Categories of Data

  • Health Data.
  • Data related to sexual preferences, sex life, and/or sexual orientation.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Prospective customers.
  • Communication partner.
  • Users.
  • Business and contractual partners.
  • Education and course participants.
  • Participants.
  • Persons depicted.
  • Third parties.
  • Customers.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Web Analytics.
  • Targeting.
  • Office and organisational procedures.
  • Conversion tracking.
  • Clicktracking.
  • Affiliate Tracking.
  • Affiliate Tracking.
  • A/B Tests.
  • Organisational and Administrative Procedures.
  • Content Delivery Network (CDN).
  • Feedback.
  • Heatmaps.
  • Polls and Questionnaires.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and usability.
  • Information technology infrastructure.
  • Financial and Payment Management.
  • Public relations.
  • Sales promotion.
  • Business processes and management procedures.
  • Artificial Intelligence (AI).

Automated Individual Decision-Making

  • Credit report.

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.

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: These privacy policy serves both to provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms used in the GDPR are applied. In particular, instead of the terms used in the Swiss FADP such as “processing” of “personal data”, “predominant interest”, and “particularly sensitive personal data”, the terms used in the GDPR, namely “processing” of “personal data”, as well as “legitimate interest” and “special categories of data” are used. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP within its scope of application.

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.

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.

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

Data Processing in Third Countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies (which becomes apparent either from the postal address of the respective provider or when explicitly mentioned in the privacy policy regarding data transfer to third countries), this is always done in accordance with legal requirements.

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 the EU Commission’s adequacy decision of July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the EU Commission’s requirements 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 Contractual Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Contractual 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 Contractual 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, particularly Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

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

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 June 7, 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.

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.

If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.

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.

Further information on processing methods, procedures and services used:

  • 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.

Business services

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

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

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.

  • 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).
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Education and course participants.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; 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:

  • Education and Training Services: We process the data of the participants of our education and training programmes (uniformly referred to as ” students”) in order to provide them with our educational and training services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and educational relationship. The processing also includes the performance evaluation and evaluation of our services and the teachers and instructors.

    As part of our activities, we may also process special categories of data, in particular information on the health of persons undergoing training or further training and data revealing ethnic origin, political opinions, religious or philosophical convictions. To this end, we obtain, if necessary, the express consent of the students to be trained and further educated and process the special categories of data otherwise only if it is necessary for the provision of training services, for purposes of health care, social protection or protection of vital interests of the students to be trained and further educated; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Coaching: We process the data of our clients as well as prospects and other contractors or business partners (collectively referred to as “clients”) in order to provide them with our services. The processes carried out within the framework and for the purposes of coaching include: initiating contact and communication with clients, needs analysis to determine suitable coaching measures, planning and conducting coaching sessions, documenting coaching progress, capturing and managing client-specific information and data, scheduling and organising appointments, providing coaching materials and resources, invoicing and payment management, post-processing and follow-up of coaching sessions, quality assurance and feedback processes.
    The processed data, its nature, scope, purpose, and the necessity of its processing are determined by the underlying contractual relationship with the client.
    Insofar as it is necessary for fulfilling our contract, protecting vital interests or legally required, or if there is consent from the clients, we disclose or transfer the clients’ data in compliance with professional legal requirements to third parties or agents such as authorities, billing centers as well as in the field of IT, office or comparable services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Consulting: We process the data of our clients as well as prospects and other commissioning parties or contractual partners (collectively referred to as “clients”) in order to be able to provide our services to them. The processes that are part of and for the purposes of consulting include: contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, capturing and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, invoicing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the nature, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship with the client.
    If it is necessary for our contract performance, for the protection of vital interests or legally required, or if there is consent from the clients, we disclose or transmit client data in compliance with professional legal requirements to third parties or agents such as authorities, subcontractors or in the field of IT, office or similar services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Consulting: Insofar as it is necessary for our contractual performance or required by law, or if the consent of the customer has been obtained, we disclose or transfer the customer’s data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with the contractual and legal requirements; 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); 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.). Employee Data (Information about employees and other individuals in an employment relationship).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Customers; Third parties; Users (e.g. website visitors, users of online services). Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Security measures; Provision of our online services and usability; Communication; Marketing; Sales promotion; Public relations; Financial and Payment Management. 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: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Further information on processing methods, procedures and services used:

  • 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).
  • 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).
  • Customer Account: Customers can create an account within our online offer (e.g. customer or user account, “customer account” for short). If the registration of a customer account is required, 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).
  • 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).
  • 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).
  • 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).
  • Sales: Procedures required for the planning, implementation, and control of measures for marketing and selling products or services (e.g., customer acquisition, preparation and tracking of offers, order processing, customer consultation and support, sales promotion, product training, sales controlling and analysis, management of distribution channels); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

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); 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). Images and/ or video recordings (e.g. photographs or video recordings of a person).
  • Special categories of personal data: Health Data. Data related to sexual preferences, sex life, and/or sexual orientation.
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners; Communication partner (Recipients of e-mails, letters, etc.); Participants. Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)); Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Conversion tracking (Measurement of the effectiveness of marketing activities); Clicktracking; Affiliate Tracking; A/B Tests; Feedback (e.g. collecting feedback via online form); Heatmaps (“Heatmaps” are mouse movements of the users, which are combined to an overall picture.); Polls and Questionnaires (e.g. surveys with input options, multiple choice questions); Marketing. 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”; 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, booking receipts and invoices (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 1, 4 and 4a of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 Numbers 1 and 4, Paragraph 4 of the German Commercial Code (HGB)).). 6 years – Fiscal Code/Commercial Code (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 3 in conjunction with Paragraph 1 No. 2, 3, 5 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 of the German Commercial Code (HGB)).).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Consent (Article 6 (1) (a) GDPR).
  • Automated individual decision-making: Credit report (Decision based on a credit report).

Further information on processing methods, procedures and services used:

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”).

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). Contact data (e.g. postal and email addresses or phone numbers).
  • Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
  • Purposes of processing: 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:

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: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)); Security measures. Content Delivery Network (CDN).
  • 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).
  • 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.
  • Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
  • 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; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.cloudflare.com; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/).

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).

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: 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.
  • Two-factor Authentication: Two-factor authentication provides an extra layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, in addition to your password, you must perform another authentication measure (e.g. enter a code sent to a mobile device – we will inform you about the procedure we use); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • 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).
  • No obligation to retain data: It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Community Functions

The community functions provided by us allow users to engage in conversations and other forms of interaction with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.). 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: Provision of contractual services and fulfillment of contractual obligations; Security measures. 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: 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:

  • Right to delete content and information: The deletion of posts, content or information provided by users is permissible to the extent necessary after proper consideration if there are concrete indications that they could represent a violation of legal regulations, our provisions or the rights of third parties; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Restricted deletion of posts: Out of consideration for other users, the user’s contributions to conversations remain stored even after termination and account deletion, so that conversations, comments, advice and similar communications do not lose their meaning or become inverted.This ensures that conversations, comments, advice or similar communication between and among users do not lose their meaning or become inverted. User names will be deleted or pseudonymised if they were not already pseudonyms.Users can request the complete deletion of their posts at any time; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Protection of own data: Users decide for themselves what data they disclose about themselves within our online services. For example, when users provide personal information or participate in conversations. We ask users to protect their data and to publish personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect their login credentials in particular and use secure passwords (preferably long and random combinations of characters); 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: 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).

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: 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.); 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).
  • Special categories of personal data: Health Data. Data related to sexual preferences, sex life, and/or sexual orientation.
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability; 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”; 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, booking receipts and invoices (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 1, 4 and 4a of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 Numbers 1 and 4, Paragraph 4 of the German Commercial Code (HGB)).). 6 years – Fiscal Code/Commercial Code (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 3 in conjunction with Paragraph 1 No. 2, 3, 5 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 of the German Commercial Code (HGB)).).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Automated individual decision-making: Credit report (Decision based on a credit report).

Further information on processing methods, procedures and services used:

  • 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).
  • Zoho Desk: Ticket management, customer support across various channels, automation of workflows, knowledge base management, reporting and analysis; Service provider: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.zoho.com; Security measures: IP Masking (Pseudonymization of the IP address); Privacy Policy:https://www.zoho.com/privacy.html; Data Processing Agreement: https://www.zoho.com/gdpr.html. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
  • Zoho CRM: Customer management and process and sales support with personalized customer care with multi-channel communication, i.e. management of customer inquiries from different channels, and analysis and feedback functions; Service provider: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany; Legal Basis:Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.zoho.com/crm/; Privacy Policy: https://www.zoho.com/privacy.html. Basis for third-country transfers: EEA – Standard Contractual Clauses (https://www.zoho.com/privacy/dpa/DPA_zoho_eu.pdf), Switzerland – Standard Contractual Clauses (https://www.zoho.com/privacy/dpa/DPA_zoho_eu.pdf).

Communication via Messenger

We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.

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

In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed. 

However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata). 

Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.

Reservation of reference to other means of communication: For your security, we kindly ask for your understanding that we may not respond to enquiries via messenger for specific reasons. This applies in situations where contract details require heightened confidentiality or a response via messenger does not meet formal requirements. In such cases, we recommend using more appropriate communication channels.

  • 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). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing: Communication. Direct marketing (e.g. by e-mail or postal).
  • 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); 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:

  • Apple iMessage: Send and receive text messages, voice messages, and video calls. Conduct group conversations. Share files, photos, videos, and locations. Secure communication through end-to-end encryption. Synchronise messages across multiple devices; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.apple.com/. Privacy Policy:https://www.apple.com/privacy/privacy-policy/.
  • WhatsApp: Text messages, voice and video calls, sending images, videos and documents, group chat functionality, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road 4, D04 X2K5 Dublin, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers:EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).

Artificial Intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term “AI system” as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.

To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

  • 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).
  • Data subjects: Users (e.g. website visitors, users of online services). Third parties.
  • Purposes of processing: Artificial Intelligence (AI).
  • 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:

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. Participants.
  • Purposes of processing: 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:

Audio Content

We utilise hosting services from service providers to offer our audio content for listening and downloading. In this process, we employ platforms that enable the uploading, storage, and distribution of audio material.

  • 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.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles). 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:

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); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Contract data (e.g. contract object, duration, customer category). Images and/ or video recordings (e.g. photographs or video recordings of a person).
  • Special categories of personal data: Health Data. Data related to sexual preferences, sex life, and/or sexual orientation.
  • Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Users (e.g. website visitors, users of online services); Service recipients and clients. Participants.
  • Purposes of processing: Office and organisational procedures; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)); Provision of our online services and usability; Provision of contractual services and fulfillment of contractual obligations. Communication.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Retention and Deletion”; 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, booking receipts and invoices (Section 147 Paragraph 3 in conjunction with Paragraph 1 No. 1, 4 and 4a of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 Numbers 1 and 4, Paragraph 4 of the German Commercial Code (HGB)).). 6 years – Fiscal Code/Commercial Code (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 3 in conjunction with Paragraph 1 No. 2, 3, 5 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 of the German Commercial Code (HGB)).).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Automated individual decision-making: Credit report (Decision based on a credit report).

Further information on processing methods, procedures and services used:

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.

  • 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). 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.); Users (e.g. website visitors, users of online services). Business and contractual partners.
  • Purposes of processing: Direct marketing (e.g. by e-mail or postal). Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) 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:

  • Measurement of opening rates and click rates: The newsletters contain a so-called “web beacons”, which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • 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 consent, which users can object to at any time; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • Zoho Campaigns: Email distribution and email marketing platform; Service provider: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.zoho.com/campaigns/; Privacy Policy: https://www.zoho.com/privacy.html. Basis for third-country transfers: EEA – Standard Contractual Clauses (https://www.zoho.com/privacy/dpa/DPA_zoho_eu.pdf), Switzerland – Standard Contractual Clauses (https://www.zoho.com/privacy/dpa/DPA_zoho_eu.pdf).
  • Amazon Web Services (AWS): Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://aws.amazon.com/; Privacy Policy: https://aws.amazon.com/privacy/; Data Processing Agreement: https://aws.amazon.com/compliance/gdpr-center/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://aws.amazon.com/en/service-terms/), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://aws.amazon.com/en/service-terms/).

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: 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).

Further information on processing methods, procedures and services used:

  • Zoho Survey: Online surveys and questionnaires; Service provider: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.zoho.com/survey/; Privacy Policy: https://www.zoho.com/privacy.html; Data Processing Agreement: https://www.zoho.com/gdpr.html. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).

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: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles). Targeting (e.g. profiling based on interests and behaviour, use of cookies).
  • 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:

  • PostHog Cloud EU: Web analysis, reach and conversion measurement, which includes information about the use of the online service by users in terms of its functions, content, and duration of use. Additionally, used functions and viewed contents are recorded. Moreover, certain actions such as the conclusion of a contract or an interaction following external advertisements and recommendations are registered (so-called “conversion”); Service provider: PostHog Inc., 261 Market St., #4008, San Francisco, CA 94114, USA; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://posthog.com/; Privacy Policy: https://posthog.com/privacy; Data Processing Agreement: https://posthog.com/privacy; Basis for third-country transfers: EEA – Standard Contractual Clauses (https://posthog.com/privacy (Part of the Data Processing Agreement)), Switzerland – Standard Contractual Clauses (https://posthog.com/privacy (Part of the Data Processing Agreement)). Further Information: Operation on EU servers.
  • ahrefs: SEO analysis and website optimization tool, which includes monitoring and analysis of website performance in search engines. Additionally, backlink quality and quantity, keyword rankings, and content performance are tracked. Moreover, competitor SEO strategies and search engine positioning data are collected to optimize website visibility and search engine performance; Service provider: Ahrefs Pte Ltd, 16 Raffles Quay #33-03 Hong Leong Building Singapore 048581; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://ahrefs.com; Privacy Policy:https://ahrefs.com/legal/privacy-policy; Data Processing Agreement: https://ahrefs.com/legal/data-processing-addendum

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: 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: 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).

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: 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:

  • Instagram: Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of 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. 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; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Pinterest: Social network, allows for the sharing of photos, commenting, favouriting and curating of posts, messaging, subscribing to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/en/privacy-policy.
  • X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://x.com. Privacy Policy: https://x.com/privacy.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy:https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Opt-Out: https://myadcenter.google.com/personalizationoff.

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: 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, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; 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.
  • YouTube-Videos: Within our online services, videos are embedded that are stored on YouTube. The integration of these YouTube videos is carried out via a special domain using the “youtube-nocookie” component in the so-called “enhanced privacy mode”. In “enhanced privacy mode”, only information including your IP address and details about your browser and device can be stored on your device in cookies or by comparable processes until the video starts, which YouTube requires for delivering, controlling, and optimizing video playback. Once you play the videos, additional information for analysing usage behaviour as well as for storage in user profiles and personalisation of content and ads may be processed by YouTube. The storage duration for the cookies can be up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; 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). Further Information: https://support.google.com/youtube/answer/171780?hl=en#zippy=%2Cerweiterten-datenschutzmodus-aktivieren%2Cturn-on-privacy-enhanced-mode.

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); 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).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
  • Purposes of processing: 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). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • AI software (on own server): Use of “artificial intelligence” in the applicable legal sense of the term, i.e., software that is primarily based on specific logic and is essentially autonomous in its ability to understand and produce natural language or other input, output, and data, analyze information, and make predictions; Service provider: Executed on servers and/or computers under our controllership; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Miro: Online whiteboard and collaboration platform; Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite 1100, San Francisco, California 94105, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://miro.com/; Privacy Policy: https://miro.com/legal/privacy-policy/; Data Processing Agreement: https://miro.com/legal/vendor-data-processing-addendum/. Basis for third-country transfers: EEA – Standard Contractual Clauses (https://miro.com/legal/vendor-data-processing-addendum/), Switzerland – Standard Contractual Clauses (https://miro.com/legal/vendor-data-processing-addendum/).
  • Zoho CRM: Customer management and process and sales support with personalized customer care with multi-channel communication, i.e. management of customer inquiries from different channels, and analysis and feedback functions; Service provider: Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany; Legal Basis:Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.zoho.com/crm/; Privacy Policy: https://www.zoho.com/privacy.html. Basis for third-country transfers: EEA – Standard Contractual Clauses (https://www.zoho.com/privacy/dpa/DPA_zoho_eu.pdf), Switzerland – Standard Contractual Clauses (https://www.zoho.com/privacy/dpa/DPA_zoho_eu.pdf).

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.

  • A/B Tests: A/B tests are designed to improve the usability and performance of online services. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. The behaviour of users, e.g. prolonged visits to the site or more frequent interaction with the elements, can then be used to determine which of these sites or elements are more responsive to users’ needs. 
  • 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 
  • Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users’ consent or based on legal authorisation grounds. 
  • Clicktracking: Clicktracking allows users to keep track of their movements within an entire website. Since the results of these tests are more accurate if the interaction of the users can be followed over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the computers of the users for these test purposes. 
  • 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 Delivery Network (CDN): A “Content Delivery Network” (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. 
  • 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. 
  • Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful). 
  • Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention). Such automated decisions are only allowed under Article 22 GDPR if data subjects consent, if they are necessary for the performance of a contract or if national laws allow such decisions. 
  • 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. 
  • Heatmaps: “Heatmaps” are mouse movements of the users, which are combined to an overall picture, with the help of which it can be recognized, for example, which web page elements are preferred and which web page elements users prefer less. 
  • 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.