Privacy Policy – JOST Digital Strategy Consultants

Preamble

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

The terms used are not gender-specific.

Last updated: 27 March 2026

Table of Contents

Controller

Marius Jost, Tsar Asen l-vi No. 54 – Ap. 7, 9002, Varna, Bulgaria

Email address: seo@jostm.com

Imprint: https://jostm.com/imprint/

Overview of Processing Activities

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

Types of Data Processed

  • Inventory data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Image and/or video recordings.
  • Audio recordings.
  • Log data.

Categories of Data Subjects

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

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organizational procedures.
  • Remarketing.
  • Conversion measurement.
  • Organizational and administrative procedures.
  • Content delivery network (CDN).
  • Firewall.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.

Relevant Legal Bases

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

  • Consent (Art. 6(1)(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Relevant legal bases under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (the “Swiss FADP”). Unlike the GDPR, for example, the Swiss FADP does not generally require that a legal basis for the processing of personal data be stated, and the processing of personal data is carried out in good faith, lawfully and proportionately (Art. 6(1) and (2) of the Swiss FADP). In addition, personal data is only obtained by us for a specific purpose that is recognizable to the data subject and is only processed in a manner compatible with that purpose (Art. 6(3) of the Swiss FADP).

Note on the applicability of the GDPR and the Swiss FADP: This privacy policy serves to provide information pursuant to both the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader geographical application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss FADP, namely “processing” of “personal data” (“Bearbeitung” von “Personendaten”), “overriding 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 continues to be determined in accordance with the Swiss FADP within the scope of its applicability.

National data protection regulations in Bulgaria: In Bulgaria, in addition to the data protection regulations of the GDPR, national data protection regulations apply, including the Bulgarian Personal Data Protection Act (PDPA).

Security Measures

In accordance with legal requirements and 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 varying likelihood and severity of risks to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These 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 of, transfer of, securing the availability of and the separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to threats to the data. We also take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

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

Transfer of Personal Data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect 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 persons, bodies or companies (which is recognizable from the postal address of the respective provider or when the privacy policy expressly refers to data transfers to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission of 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should any changes occur within the framework of the DPF, the standard contractual clauses will step in as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of any political or legal changes.

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

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

Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: 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 was recognized as a secure legal framework by an adequacy decision of Switzerland of 15 September 2024. In addition, we have concluded standard data protection clauses with the respective providers, which have been approved by the Swiss 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 forms the primary level of protection, while the standard data protection clauses serve as additional security. Should any changes occur within the framework of the DPF, the standard data protection clauses will step in as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard data protection clauses are in place. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, including international treaties, specific guarantees, standard data protection clauses approved by the FDPIC, or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority of another country.

General Information on Data Storage and Deletion

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

Where multiple retention periods or deletion deadlines apply to a piece of data, the longest period shall always prevail. Data that is no longer retained for its originally intended purpose, but due to legal requirements or other reasons, is processed exclusively for the reasons justifying its retention.

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

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents required to understand them (Section 147(1) No. 1 in conjunction with (3) AO (German Fiscal Code), Section 14b(1) UStG (German VAT Act), Section 257(1) No. 1 in conjunction with (4) HGB (German Commercial Code)).
  • 8 years – Accounting documents, such as invoices and cost receipts (Section 147(1) Nos. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257(1) No. 4 in conjunction with (4) HGB).
  • 6 years – Other business documents: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating cost accounting sheets, calculation documents, price labels, as well as payroll accounting documents insofar as they are not already accounting documents, and cash register receipts (Section 147(1) Nos. 2, 3, 5 in conjunction with (3) AO, Section 257(1) Nos. 2 and 3 in conjunction with (4) 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 experience and standard industry practices, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB (German Civil Code)).

Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices, as well as all required work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
  • 10 years – Data necessary to consider potential compensation claims or similar contractual claims and rights, as well as for processing related inquiries, based on previous business experience and standard industry practices, is stored for the period of the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO). After five years, claims for rent, lease and capital interest as well as other periodic payments, from the supply of foodstuffs, for board and innkeepers’ debts, as well as from craft work, retail sale of goods, medical care, professional work of lawyers, legal agents, attorneys and notaries, and from the employment relationship of employees become time-barred (Art. 128 CO).

Commencement of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, it automatically commences at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the date on which the termination takes effect or the legal relationship otherwise ends.

Rights of Data Subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed, and to obtain access to this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with the legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format, in accordance with the legal requirements, or to request its transmission to another controller.
  • Right to lodge a complaint with a supervisory authority: In accordance with the legal requirements 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 of your habitual residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss FADP:

As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss FADP:

  • Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary for you to assert your rights under this Act and to ensure transparent data processing.
  • Right to data delivery or transfer: You have the right to request the delivery of your personal data that you have disclosed to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively “contractual partners”), for the initiation, performance and settlement of contractual relationships and comparable legal relationships. This also includes pre-contractual measures carried out upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfill our primary and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the handling of warranty claims and other performance disruptions, the processing of revocations, terminations of continuing obligations, reversals, refunds, as well as the handling of other contract-related declarations and inquiries. Both one-off contracts and ongoing contractual relationships are covered.

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

In addition, we process the data to safeguard our rights and to fulfill legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations and, where applicable, obligations to provide evidence and accountability. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners from misuse, threats to data, secrets and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for the performance of the contract or to fulfill legal obligations.

Personal data is only passed on to third parties insofar as this is necessary for the performance of the contract, for the implementation of pre-contractual measures, to safeguard legitimate interests or to fulfill legal obligations. We provide separate information on processing beyond this, in particular for marketing purposes, within the scope of this privacy policy.

We inform contractual partners which data is required in each individual case as part of the data collection, e.g. in online forms by means of appropriate labeling or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations stand in the way of deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific order is deleted after completion of the order and expiry of any retention periods, provided that no further legal or contractual obligations to store the data exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for the implementation of pre-contractual measures and the performance of the respective contractual relationship, as well as Art. 6(1)(c) GDPR for the fulfillment of legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Insofar as the processing is based on Art. 6(1)(f) GDPR, it is carried out to safeguard our legitimate interests in a proper and efficient business organization, the internal administration and documentation of business transactions, the enforcement and defense of legal claims, ensuring IT and data security, the prevention of misuse and fraud, as well as the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in maintaining our entrepreneurial capacity to act.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; prospective customers; business and contractual partners. Education and course participants.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR); legal obligation (Art. 6(1)(1)(c) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Agency services: We process our customers’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).
  • Education and training services: We process the data of participants in our education and training offerings (uniformly referred to as “trainees”) in order to provide our training services to them. The data processed, the nature, scope, purpose and necessity of its processing are determined by the underlying contractual and training relationship. The forms of processing also include performance assessment and the evaluation of our services as well as those of the instructors. In the course of our activities, we may also process special categories of data, in particular information on the health of trainees as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. For this purpose, we obtain, where necessary, the express consent of the trainees and otherwise process the special categories of data only if this is necessary for the provision of the training services, for purposes of health care, social protection or the protection of vital interests of the trainees; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).
  • Coaching: We process the data of our clients as well as prospective customers and other principals or contractual partners (uniformly referred to as “clients”) in order to provide our services to them. The procedures carried out in the context of and for the purposes of coaching include: contacting and communicating with clients, needs analysis to determine suitable coaching measures, planning and conducting coaching sessions, documenting coaching progress, recording and managing client-specific information and data, scheduling and organizing appointments, providing coaching materials and resources, billing and payment management, follow-up of coaching sessions, quality assurance and feedback processes.
    The data processed, the nature, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
    Insofar as it is necessary for the performance of our contract, for the protection of vital interests or required by law, or if the clients have given their consent, we disclose or transfer the clients’ data to third parties or agents, such as authorities, billing offices, or in the areas of IT, office or comparable services, in compliance with professional regulations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).
  • Consulting: We process the data of our clients as well as prospective customers and other principals or contractual partners (uniformly referred to as “clients”) in order to provide our services to them. The procedures involved in the context 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, recording and managing client-specific information and data, scheduling and organizing appointments, providing consulting resources and materials, billing and payment management, follow-up of consulting projects, quality assurance and feedback processes. The data processed, the nature, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship. Insofar as it is necessary for the performance of our contract, for the protection of vital interests or required by law, or if the clients have given their consent, we disclose or transfer the clients’ data to third parties or agents, such as authorities, subcontractors, or in the areas of IT, office or comparable services, in compliance with professional regulations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).
  • Marketing and advertising: We process the data of our customers and principals (hereinafter uniformly referred to as “customers”) in order to offer marketing services such as market research, advertising campaigns, content creation and social media management. The required information is marked as such in the context of the order placement and includes the information needed for service provision and billing as well as contact information for any necessary consultations. Insofar as we gain access to information of end customers, employees or other persons, we process this in accordance with legal and contractual requirements. Procedures required in the context of marketing and advertising measures include the creation of marketing strategies and campaigns, the design of advertising materials and content, the selection of advertising channels and platforms, the implementation of market analyses and target group surveys, as well as the measurement of success and analysis of marketing measures. They also include the management and maintenance of customer and prospect data, the segmentation of target groups, the sending of newsletters and promotional emails, the tracking of online marketing activities, and cooperation with external service providers in the field of marketing and advertising. These procedures serve to develop effective marketing strategies for our customers, to design advertising measures appropriate to target groups, to measure and analyze the success of marketing activities, and to ensure efficient management of customer contacts and information; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • IT services: We process the data of our customers and principals in order to enable them to plan, implement and support IT solutions and related services. The required information is marked as such in the context of the order, project or comparable contract conclusion and includes the information needed for service provision and billing as well as contact information for any necessary consultations. Insofar as we gain access to information of end customers, employees or other persons, we process this in accordance with legal and contractual requirements.
    The processing operations include, among other things, project management and documentation, which cover all phases from the initial requirements analysis to the completion of the project. This includes creating and managing project schedules, budgets and resource allocations. The data processing also supports change management, in which changes in the project workflow are documented and tracked to ensure compliance and transparency. Another process is customer relationship management (CRM), which involves recording and analyzing customer interactions and feedback in order to improve service quality and efficiently address individual customer needs. In addition, the processing includes technical support and troubleshooting, which encompasses the recording and processing of support requests, error corrections and regular maintenance. Furthermore, reporting and performance analysis are carried out, whereby performance indicators are recorded and evaluated in order to assess the effectiveness of the IT solutions provided and to continuously optimize them. All of these processes are designed to ensure a high level of customer satisfaction and compliance with all relevant requirements; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Business Processes and Procedures

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

The data collected serves to fulfill contractual obligations and to make operational processes efficient. This includes the handling of business transactions, the management of customer relationships, the optimization of sales strategies and the assurance of internal invoicing and financial processes. In addition, the data supports the safeguarding of the controller’s rights and promotes administrative tasks as well as the organization of the company.

Personal data may be passed on to third parties insofar as this is necessary to fulfill the stated purposes or legal obligations. After the expiry of statutory retention periods or when the purpose of the processing no longer applies, the data is deleted. This also includes data that must be stored for longer periods due to tax law and statutory documentation obligations.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); log data (e.g. log files concerning logins or the retrieval of data or access times); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; prospective customers; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services). Employees (e.g. staff, applicants, temporary workers and other employees).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR). Legal obligation (Art. 6(1)(1)(c) GDPR).

Further information on processing operations, procedures and services:

  • Contact management and contact maintenance: Procedures 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, performing backups and restores of contact data, training employees in the effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts and the control of payment flows (e.g. creation and verification of bank transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, returned direct debit management, account reconciliation, cash management); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the recording, processing and control of business transactions in the area of accounts payable and accounts receivable (e.g. creation and verification of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, handling of dunning processes, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable accounting); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Financial accounting and taxes: Procedures required for the recording, management and control of finance-related business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, handling of tax matters); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Public relations: Procedures required in the context of public relations and PR work (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media coverage, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Providers and Services Used in the Course of Business

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; prospective customers; business and contractual partners. Employees (e.g. staff, applicants, temporary workers and other employees).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

Payment Procedures

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

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract-, amount- and recipient-related information. This information is required to carry out the transactions. However, the data entered is processed only by the payment service providers and stored with them. This means that we do not receive any account- or credit card-related information, but only information confirming or rejecting 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 verify identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy notices of the payment service providers.

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

Provision of the Online Services and Web Hosting

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

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); log data (e.g. log files concerning logins or the retrieval of data or access times). Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures; content delivery network (CDN). Firewall.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of online services on rented storage 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 called a “web host”); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Collection of access data and log files: Access to our online services is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to prevent server overload (in particular in the event of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure server capacity utilization and stability; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • Email dispatch and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders as well as other information relating to the email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Content delivery network: We use a “content delivery network” (CDN). A CDN is a service that helps deliver content of an online service, in particular large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the Internet; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Hostinger: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Service provider: Hostinger International Ltd, 61 Lordou Vironos Str., 6023 Larnaca, Cyprus; Website: https://www.hostinger.de. Privacy policy: https://www.hostinger.de/legal/datenschutz-bestimmungen.
  • Cloudflare: Content delivery network (CDN) – a service that helps deliver content of an online service, in particular large media files such as graphics or program scripts, 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 bases: Legitimate interests (Art. 6(1)(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: EU/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/).
  • Wordfence: Firewall, security and error detection functions to detect and prevent unauthorized access attempts as well as technical vulnerabilities that could enable such access. For these purposes, cookies and similar storage methods required for this purpose may be used, and security logs may be created during the check and in particular in the event of unauthorized access. In this context, users’ IP addresses, a user identification number and their activities, including the time of access, are processed and stored, compared with the data provided by the provider of the firewall and security function, and transmitted to this provider; Service provider: Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.wordfence.com; Privacy policy: https://www.wordfence.com/privacy-policy/; Basis for third-country transfers: EU/EEA – standard contractual clauses (https://www.wordfence.com/standard-contractual-clauses/), Switzerland – standard contractual clauses (https://www.wordfence.com/standard-contractual-clauses/). Further information: https://www.wordfence.com/help/general-data-protection-regulation/.
  • Google Cloud CDN: Content delivery network (CDN) – a service that helps deliver content of an online service, in particular large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://cloud.google.com/cdn; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), standard contractual clauses (https://cloud.google.com/terms/eu-model-contract-clause), Switzerland – Data Privacy Framework (DPF), standard contractual clauses (https://cloud.google.com/terms/eu-model-contract-clause).
  • Amazon CloudFront: Content delivery network (CDN) – a service that helps deliver content of an online service, in particular large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://aws.amazon.com/de/cloudfront/; Privacy policy: https://aws.amazon.com/privacy/; Data processing agreement: https://aws.amazon.com/de/compliance/gdpr-center/. Basis for third-country transfers: EU/EEA – standard contractual clauses (provided by the service provider), Switzerland – standard contractual clauses (provided by the service provider).

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 various purposes, for example for the functionality, security and convenience of online services and for analyzing visitor flows. We use cookies in accordance with the statutory provisions. Where necessary, we obtain the prior consent of users. If consent is not required, we rely on our legitimate interests. This applies when the storage and reading of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online services. Consent can be revoked at any time. We provide clear information about its scope and which cookies are used.

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

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed 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 visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

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

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Consent (Art. 6(1)(1)(a) GDPR).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution to obtain users’ consent to the use of cookies or to the procedures and providers named within the consent management solution. This procedure serves to obtain, log, manage and revoke consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users’ devices. As part of this procedure, users’ consents are obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option of managing and revoking their consents. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (a so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information is available on the providers of consent management services, the following general information applies: consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, system and device used; Legal bases: Consent (Art. 6(1)(1)(a) GDPR).
  • Complianz: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of notices on data protection and cookies, enabling users to revoke or adjust consents; Service provider: Executed on servers and/or computers under our own data protection responsibility; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/. Further information: An individual user ID, language, types of consent and the time of their submission are stored on the server side and in a cookie on the user’s device.

Processing of Data within the Application (App)

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

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category). Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; provision of our online services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter uniformly referred to as “users”) in order to provide our contractual services to them and on the basis of legitimate interests in order to ensure the security of our application and to develop it further. The required information is marked as such in the context of the usage, order, purchase or comparable contract conclusion and may include the information required for service provision and any billing as well as contact information for any necessary consultations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).
  • Device permissions for access to functions and data: The use of our application or its functionalities may require user permissions for access to certain functions of the devices used or to data stored on the devices or accessible with the help of the devices. By default, these permissions must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user’s device and software. Users can contact us if they require clarification. Please note that refusing or revoking the respective permissions may affect the functionality of our application.
  • Vercel: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity) as well as a development environment; Service provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://vercel.com; Privacy policy: https://vercel.com/legal/privacy-policy; Data processing agreement: https://vercel.com/legal/dpa. Basis for third-country transfers: EU/EEA – standard contractual clauses (https://vercel.com/legal/dpa), Switzerland – standard contractual clauses (https://vercel.com/legal/dpa).

Blogs and Publication Media

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness; security measures. Provision of contractual services and fulfillment of contractual obligations.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies – Within our WordPress blog, graphic emojis (or smilies), i.e. small graphic files that express emotions, obtained from external servers, are used for the purpose of efficiently integrating content elements. The providers of the servers collect users’ IP addresses. This is necessary so that the emoji files can be transmitted to users’ browsers; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Data processing agreement: Provided by the service provider. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider), Switzerland – Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).
  • Akismet anti-spam check: Akismet anti-spam check – We use the “Akismet” service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this period. This information includes the name entered, the email address, the IP address, the comment content, the referrer, details of the browser used and the computer system, and the time of the entry. Users are welcome to use pseudonyms or to refrain from entering a name or email address. They can completely prevent the transmission of data by not using our comment system. That would be a shame, but unfortunately we see no alternatives that work just as effectively; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider), Switzerland – Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).
  • Profile pictures from Gravatar: Profile pictures – We use the Gravatar service within our online services and in particular in the blog. Gravatar is a service where users can register and store profile pictures and their email addresses. When users leave posts or comments with the respective email address on other online presences (especially in blogs), their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the users is transmitted to Gravatar in encrypted form in order to check whether a profile is stored for it. This is the sole purpose of transmitting the email address. It is not used for other purposes, but is deleted afterwards. The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture. By displaying the images, Gravatar learns the user’s IP address, as this is necessary for communication between a browser and an online service.

    If users do not want a user image linked to their email address at Gravatar to appear in the comments, they should use an email address that is not registered with Gravatar for commenting. We also point out that it is possible to use an anonymous email address or no email address at all if users do not wish their own email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our comment system; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Data processing agreement: Provided by the service provider. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider), Switzerland – Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).

  • reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with reCAPTCHA on other websites, possibly cookies, as well as the results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our legitimate interest in protecting our online services from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum (from 02 April 2026). Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), standard contractual clauses (https://cloud.google.com/terms/sccs/eu-c2p (from 02 April 2026)), Switzerland – Data Privacy Framework (DPF), standard contractual clauses (https://cloud.google.com/terms/sccs/eu-c2p (from 02 April 2026)).

Contact and Inquiry Management

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

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness. Office and organizational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us in order to answer and handle the respective matter. This usually includes details such as name, contact information and, where applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • calendly: Online appointment scheduling and appointment management; Service provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://calendly.com/de; Privacy policy: https://calendly.com/privacy; Data processing agreement: https://calendly.com/dpa. Basis for third-country transfers: EU/EEA – standard contractual clauses (https://calendly.com/dpa), Switzerland – standard contractual clauses (https://calendly.com/dpa).

Communication via Messenger

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

You can also contact us via alternative channels, e.g. by telephone or email. Please use the contact options provided to you or the contact options given within our online services.

In the case of end-to-end 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 attached images) is encrypted end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.

However, we additionally point out to our communication partners that, although the messenger providers cannot view the content, they can determine that and when communication partners communicate with us, and technical information about the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata) is processed.

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

Withdrawal, objection and deletion: You can withdraw any consent given at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that any information from the communication partners has been answered, if no reference back to a previous conversation is to be expected and there are no statutory retention obligations preventing deletion.

Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that for certain reasons we may not be able to answer inquiries via messenger. This applies to situations in which, for example, contract details must be treated with particular confidentiality or a response via messenger does not meet formal requirements. In these cases, we recommend that you use more appropriate communication channels.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication. Direct marketing (e.g. by email or post).
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1)(1)(b) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • WhatsApp: A communication service that enables the sending and receiving of text messages, voice messages, images, videos, documents as well as voice and video calls via the Internet. Communication takes place via end-to-end encryption, whereby content is only accessible to the communication partners involved. To provide the service, the platform processes metadata (e.g. telephone numbers, times, device information) and may use this to improve functions, security and service optimization; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal/privacy-policy-eea. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).

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 “conferences”). When selecting the conference platforms and their services, we observe the legal requirements.

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

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

Data protection measures of participants: Please refer to the privacy notices of the conference platforms for details on the processing of your data and choose the security and data protection settings that are optimal for you within the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by notifying flatmates, locking doors and using the function to blur the background where technically possible). Links to conference rooms and access data must not be passed on to unauthorized third parties.

Information on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for 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 processing of meeting results, etc.). In all other respects, users’ data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); audio recordings. Log data (e.g. log files concerning logins or the retrieval of data or access times).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

Audio Content

We use hosting offerings from service providers to offer our audio content for listening and downloading. In doing so, we use platforms that enable the uploading, storage and distribution of audio material.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); profiles with user-related information (creating user profiles). Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

Newsletters and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletters”) exclusively with the consent of the recipients or on the basis of a legal basis. If the contents of the newsletter are specified when registering for it, these contents are decisive for the users’ consent. For registration for our newsletter, providing your email address is normally sufficient. However, in order to provide you with a personalized service, we may ask for your name for a personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.

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

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

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post). Provision of contractual services and fulfillment of contractual obligations.
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Opt-out option: You can cancel receipt of our newsletter at any time, i.e. withdraw 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 given above, preferably email.

Further information on processing operations, procedures and services:

  • Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server, or from the server of a dispatch service provider if we use one, when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information collected is assigned to the individual newsletter recipients and stored in their profiles until deletion. On this basis, user profiles are created in which usage behavior and user characteristics are stored. The measurement of open and click rates, the storage of the measurement results in the users’ profiles and their further processing are carried out on the basis of the users’ consent. A separate withdrawal of consent to the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, the stored profile information will be deleted; Legal bases: Consent (Art. 6(1)(1)(a) GDPR).
  • Prerequisite for the use of free services: Consent to the sending of mailings may be made a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, we ask them to contact us.
  • Mailerlite: Email dispatch and automation services; Service provider: MailerLite Limited, Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.mailerlite.com/; Privacy policy: https://www.mailerlite.com/legal/privacy-policy. Data processing agreement: https://www.mailerlite.com/legal/data-processing-agreement.

Web Analysis, Monitoring and Optimization

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

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

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

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

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

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creating user profiles); remarketing. Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Matomo: Matomo is software used for the purposes of web analysis and reach measurement. In the course of using Matomo, cookies are generated and stored on the user’s device. The user data collected in the course of using Matomo is processed only by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal bases: Consent (Art. 6(1)(1)(a) GDPR). Deletion of data: The cookies have a storage period of a maximum of 13 months.
  • RankMath: Analysis and optimization of meta titles and meta descriptions (texts for search engines), generation of sitemaps (overview of all pages of a website), monitoring of technical SEO errors (problems with discoverability by search engines), management of structured data (additional information for search engines); Service provider: ONE.COM INDIA PRIVATE LIMITED, Office No. 2, 5th Floor, Tower A, Building 9 DLF Cyber City Complex, Phase III, 122002 Gurgaon, India; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://rankmath.com. Privacy policy: https://rankmath.com/de/privacy-policy/.
  • LinkedIn Insight Tag: Code that is loaded when a user visits our online services and tracks the user’s behavior and conversions and stores them in a profile (possible uses: measurement of campaign performance, optimization of ad delivery, building custom and lookalike audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Consent (Art. 6(1)(1)(a) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, cookie policy: https://www.linkedin.com/legal/cookie_policy; Data processing agreement: https://www.linkedin.com/legal/l/dpa; Basis for third-country transfers: EU/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 option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

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

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of users. For these purposes, cookies are generally stored on users’ computers, in which the usage behavior and interests of users are stored. In addition, data may also be stored in the usage profiles irrespective of the devices used by the users (in particular if they are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the latter have access to user data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Instagram: Social network, enables the sharing of photos and videos, commenting on and favoriting posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data of visitors to our Facebook page (“fan page”). This includes, in particular, information about user behavior (e.g. content viewed or interacted with, actions taken) as well as device information (e.g. IP address, operating system, browser type, language settings, cookie data). More details can be found in the Facebook data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the “Page Insights” service, which provide information on how people interact with our page and its content. The basis for this is an agreement with Facebook (“Information about Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (in particular access, deletion, objection, complaint to a supervisory authority) remain unaffected. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for the further processing, including a possible transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. It also includes details about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job function, country, industry, seniority level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
    We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of users (in particular the right of access, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EU/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 option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.
  • Vimeo: Platform for the provision and delivery of video content; Service provider: Vimeo Inc., 555 West 18th Street New York, New York 10011, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://vimeo.com; Privacy policy: https://vimeo.com/legal/privacy; Data processing agreement: https://vimeo.com/legal/enterprise-terms/dpa. Basis for third-country transfers: EU/EEA – standard contractual clauses (https://vimeo.com/legal/enterprise-terms/dpa), Switzerland – standard contractual clauses (https://vimeo.com/legal/enterprise-terms/dpa).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/personalizationoff.

Plug-ins and Embedded Functions and Content

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

The integration always requires that the third-party providers of this content process the IP address of the users, as without the IP address they could not send the content to their browsers. The IP address is therefore necessary for the display of this content or these functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online services, and may also be linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal bases: Consent (Art. 6(1)(1)(a) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • mave.io video player: Integration of a video player; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); hosted in the EU; data processing agreement: https://www.mave.io/terms/; Service provider: mave.io B.V., Westplein 12, 3016 BM Rotterdam, The Netherlands; Website: https://mave.io. Privacy policy: https://www.mave.io/privacy/.

Management, Organization and Auxiliary Tools

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

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

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

  • Types of data processed: Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Contact data (e.g. postal and email addresses or telephone numbers).
  • Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

Changes and Updates

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

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

Definitions of Terms

In this section, you will find an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as staff members, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer’s obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various phases, including establishment, in which the employment contract is concluded, performance, in which the employee carries out their work, and termination, when the employment relationship ends, whether by notice of termination, mutual termination agreement or otherwise. Employee data is all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance evaluations.
  • Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unique assignment and communication.
  • Content delivery network (CDN): A “content delivery network” (CDN) is a service that helps deliver content of an online service, in particular large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the Internet.
  • Firewall: A firewall is a security system that protects a computer network or an individual computer from unwanted network access.
  • Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites were successful.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories containing information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It may include details on file size, creation date, the author of a document and modification histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used for tracking and reviewing operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages and which paths they take to navigate through an application. Usage data may also include frequency of use, time stamps of activities, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any kind of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online service and may include the behavior or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online services can, for example, recognize at what time users visit their websites 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. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online service.
  • Remarketing: “Remarketing” or “retargeting” refers to noting, for advertising purposes, for example, which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, whether collecting, evaluating, storing, transmitting or erasing.
  • Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for electronic commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also contain information on payment status, chargebacks, authorizations and fees.