Data protection

Privacy Policy 

Preamble

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

kompreno is incorporated in Germany, this document has been translated from German into English. In the event of any conflict, ambiguity, or discrepancy between the two language versions, the German version shall prevail and be solely authoritative. 

The terms used are not gender-specific. 

As of 20 December 2025 

Table of contents

Responsible party

Jochen Adler
Im Singes 17
63225 Langen, Deutschland

E-Mail-Adresse: office@kompreno.eu

Overview of processing

The following overview summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects. 

Types of data processed

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

Categories of data subjects

  • Service recipients and clients. 
  • Employees. 
  • Prospective customers. 
  • Communication partners. 
  • Users. 
  • Business and contractual partners. 
  • People depicted. 
  • Third parties. 

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations. 
  • Communication. 
  • Security measures. 
  • Direct marketing. 
  • Reach measurement. 
  • Tracking. 
  • Office and organisational procedures. 
  • Target group formation. 
  • Organisational and administrative procedures. 
  • Feedback. 
  • Marketing. 
  • Profiles with user-related information. 
  • Registration procedures. 
  • Provision of our online services and user-friendliness. 
  • Information technology infrastructure. 
  • Finance and payment management. 
  • Public relations. 
  • Sales promotion. 
  • Business processes and business management procedures. 
  • Artificial intelligence (AI). 

Relevant legal bases according to 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 registered office. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy. 

  • Consent (Art. 6(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 enquiries (Art. 6(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 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject. 
  • Legitimate interests (Art. 6(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. 

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

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

Security measures

In accordance with legal requirements, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. 

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability and separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and responses are made to data threats. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings. 

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorised access. 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 unauthorised access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted. 

Transfer of personal data

As part of our processing of personal data, it may happen that this data is transferred or disclosed to other bodies, companies, legally independent organisational 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 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 the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements. 

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

This double 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 changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes. 

We will inform you whether individual service providers 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 US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). 

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

General information on data storage and deletion

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

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

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

If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention. 

Storage and deletion of data: The following general periods apply to storage and archiving under German law: 

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet and the work instructions and other organisational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB). 
  • 8 years – Accounting documents, such as invoices and expense receipts (Section 147 (1) No. 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: commercial or business letters received, copies of commercial or business letters sent, other documents relevant to taxation, e.g. hourly wage slips, operating accounts, calculation documents, price tags, but also payroll documents, unless they are 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 damage claims or similar contractual claims and rights, as well as to process related enquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB). 

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

Rights of data subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the 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 the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing. 
  • Right to withdraw consent: You have the right to withdraw your consent at any time. 
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements. 
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you. 
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data. 
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller. 
  • Complaint to supervisory authority: In accordance with 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 in which you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR. 

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as ‘contractual partners’), within the framework of contractual and comparable legal relationships and associated measures and with regard to communication with contractual partners (or pre-contractually), for example to respond to enquiries. 

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

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person. 

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for archiving purposes for legal reasons (e.g. for tax purposes, usually ten years) . We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order. 

  • 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; interested parties. Business and contractual partners. 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures. Business processes and business management procedures. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, processes and services: 

  • Provision of software and platform services: We process the data of our users, registered users and any test users (hereinafter collectively referred to as ‘users’) in order to be able to provide them with our contractual services and, on the basis of legitimate interests, to ensure the security of our services and to be able to further develop them. The required information is marked as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for service provision and billing as well as contact information for any necessary consultations; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). 

Business processes and procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, patients or business partners and other third parties – is processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships.  

This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management. 

The data collected is used to fulfil contractual obligations and to design operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the safeguarding of internal invoicing and financial processes. 

In addition, the data supports the protection of the rights of the controller and facilitates administrative tasks and the organisation of the company. Personal data may be passed on to third parties if this is necessary to fulfil the aforementioned purposes or legal obligations. 

The data will be deleted after the expiry of the statutory retention periods or when the purpose of the processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements. 

  • 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. text or image 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 relating to logins or the retrieval of data or access times). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). 
  • Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services). Employees (e.g. employees, applicants, temporary staff and other staff). 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational 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 equipment (computers, servers, etc.)). 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR). Legal obligation (Art. 6(1)(c) GDPR). 

Further information on processing operations, procedures and services: 

  • Contact management and contact maintenance: Procedures necessary for the organisation, maintenance and securing of contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adjusting contact strategies); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR). 
  • General payment transactions: Procedures necessary for the execution of payment transactions, monitoring of bank accounts and control of payment flows (e.g. creation and verification of transfers, processing of direct debits, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(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, processing of reminders, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable) ; Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR). 
  • Financial accounting and taxes: Procedures required for the recording, management and control of financially relevant business transactions and for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of reminders, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(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 identification, 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 programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 
  • Public relations: Processes required in the context of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and company websites, corporate branding support); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Providers and services used in the course of business activities

In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (hereinafter referred to as ‘services’) 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 organisation. 

  • 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. text or image 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); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). 
  • Data subjects: Service recipients and clients; interested parties; business and contractual partners. Communication partners. 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and business management procedures; direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors). 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). 

Further information on processing procedures, methods and services: 

  • HubSpot CRM: management of customer contacts, tracking of sales activities, automation of marketing campaigns, analysis of sales data, creation and management of email campaigns, integration with other tools and platforms, management of customer support enquiries, AI-assisted content generation, personalised email creation, predictive sales forecasts, automatic workflow descriptions and AI chatbots for customer interaction; Service provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central Guild Street, Dublin 1, Ireland; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR) ; Website:https://www.hubspot.de/pa/crm; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Data processing agreement: https://legal.hubspot.com/dpa. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.hubspot.com/dpa). 
  • Brevo: Email delivery and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider. 

Payment procedures

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

The data processed by the payment service providers includes inventory data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. This information is required in order to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. 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. For more information, please refer to the terms and conditions and privacy policy of the payment service providers. 

Payment transactions are subject to the terms and conditions and data protection information of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects. 

  • 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, usage intensity and frequency, 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. Prospective customers. 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Business processes and business management procedures. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, methods and services: 

  • Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://stripe.com; Privacy policy:https://stripe.com/de/privacy. Basis for third country transfers: Data Privacy Framework (DPF). 

Provision of 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 end device. 

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); Log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and 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: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing operations, procedures and services: 

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a ‘web host’). Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called ‘server log files’. Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server utilisation and stability. Legal basis:Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that must be retained for evidentiary purposes is excluded 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 further information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of emails between the sender and the recipient on our server; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 
  • Host Europe: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Host Europe GmbH, Hansestrasse 111, 51149 Cologne, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hosteurope.de; Privacy policy:http://www.hosteurope.de/AGB/Datenschutzerklaerung/. Data processing agreement:https://www.hosteurope.de/Dokumente/. 
  • WP Fastest Cache: Caching and load optimisation – functions that serve to store certain website content so that it can be loaded more quickly when accessed repeatedly. This reduces loading times and improves the user experience; Service provider: WP Fastest Cache; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.wpfastestcache.com/. Further information: Operation within our own hosting environment. 
  • Microsoft Azure: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity) ; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:https://azure.microsoft.com; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://azure.microsoft.com/de-de/support/legal/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://azure.microsoft.com/en-us/support/legal/). 

Use of cookies

The term ‘cookies’ refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security and convenience of online services and to analyse visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance where necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval 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 offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used. 

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

Storage period: With regard to the storage period, a distinction is made between the following types of cookies: 

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application). 
  • Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the log-in status can be stored and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about 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 their consent at any time and also object to the processing in accordance with the legal requirements, including by means of their browser’s privacy settings. 

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

Further information on processing procedures, processes and services: 

  • Processing of cookie data on the basis of consent: We use a consent management solution that obtains users’ consent to the use of cookies or to the procedures and providers specified in the consent management solution. This procedure is used to obtain, log, managing and revoking consent, in particular with regard to the use of cookies and similar technologies that are used to store, read and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers specified in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information is available about 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 and stored together with the time of consent, details of the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, system and end device used. Legal basis: Consent (Art. 6(1)(a) GDPR) . 
  • Cookie Consent Manager CCM19: 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 their consents; Service provider:Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn, Germany; Website:https://www.ccm19.de/; Privacy policy: https://www.ccm19.de/datenschutzerklaerung.html. Further information:A pseudonymous user ID with the consent status is stored. 

Processing of data within the application (app)

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

Legal basis: The processing of data required for the provision of the application’s functionalities serves to fulfil contractual obligations. This also applies if the provision of the functions requires authorisation from the users (e.g. approval of 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 the purpose of optimising 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 length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved). 
  • Data subjects: Users (e.g. website visitors, users of online services). 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures. Provision of our online services and user-friendliness. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’ . 
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, processes and services: 

  • Device permissions for accessing functions and data: The use of our application or its functionalities may require users to grant permissions to access certain functions of the devices used or to access 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 device and software used by the user. Users can contact us if they require further explanation. Please note that refusing or revoking the respective permissions may affect the functionality of our application. 
  • No location history and no movement profiles: Location data is only used selectively and is not processed to create a location history or movement profile of the devices used or their users. 

Purchasing applications via app stores

Our application is available for purchase via special online platforms operated by other service providers (so-called ‘app stores’). In this context, the privacy policies of the respective app stores apply in addition to our privacy policy. This applies in particular with regard to the procedures used on the platforms for reach measurement and interest-based marketing, as well as any costs incurred. 

  • 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) ; usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). 
  • Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services). 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Provision of our online offering and user-friendliness. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’ . 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing, procedures and services: 

Registration, login and user account

Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The data processed includes, in particular, login information (user name, password and email address). 

When using our registration and login functions and the user account, we store the IP address and the time of the respective user action. Storage is based on our legitimate interests and those of the users in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so. 

Users can be informed by email about processes that are relevant to their user account, such as technical changes. 

  • 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. text or image 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, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times). 
  • Data subjects: Users (e.g. website visitors, users of online services) . 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; organisational and administrative procedures. Provision of our online services and user-friendliness. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Deletion after termination. 
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, methods and services: 

  • Registration with real name: Due to the nature of our community, we ask users to only use our services under their real names. This means that the use of pseudonyms is not permitted. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). 
  • Two-factor authentication: Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. To do this, you must perform an additional authentication measure (e.g. enter a code sent to a mobile device) in addition to your password. We will inform you about the procedure we use; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). 
  • Deletion of data after termination: When users terminate their user account, their data relating to the user account will be deleted, subject to legal permission, obligation or consent of the users; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). 
  • No obligation to retain data: It is the responsibility of users to back up their data before the end of the contract upon termination. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR). 

Single sign-on registration

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

Authentication takes place directly with the respective single sign-on provider. As part of this authentication process, we receive a user ID with the information that the user is logged in with this user ID at the respective single sign-on provider and an ID that cannot be used by us for other purposes (known as a ‘user handle’). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, the data releases selected during authentication and the data that users have selected in the privacy or other settings of their user account with the single sign-on provider. , the data sharing options selected during authentication, and the data that users have shared in the privacy or other settings of their user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, this may be different data, but it is usually the email address and user name. The password entered with the single sign-on provider as part of the single sign-on process is neither visible to us nor stored by us. 

Users are asked to note that the information we store about them can be automatically synchronised with their user account with the single sign-on provider, but that this is not always possible or actually done. If, for example, users’ email addresses change, they must change them manually in their user account with us. 

We may use single sign-on registration, if agreed with users, as part of or prior to the fulfilment of the contract, provided that users have been asked to consent to this, and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure login system. 

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and 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: Provision of contractual services and fulfilment of contractual obligations; security measures; registration procedures. Provision of our online services and user-friendliness. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Deletion after termination. 
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, methods and services: 

  • OpenID Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: OpenID Foundation, 2400 Camino Ramon, Suite 375, San Ramon, CA 94583, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://openid.net; Privacy policy:https://openid.net/policies/. Basis for third country transfers: Data Privacy Framework (DPF). 

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the details of the enquirers are processed to the extent necessary to respond to the contact enquiries and any requested measures. 

  • 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. text or image 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, types of devices 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: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness; direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors). 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR). 

Further information on processing procedures, methods and services: 

  • Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data you provide in order to respond to and process your enquiry. This usually includes information such as your name, contact details and, if necessary, other information that you provide to us and that is necessary for the appropriate processing of your enquiry. We use this data exclusively for the stated purpose of establishing contact and communication; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). 
  • HubSpot CRM: management of customer contacts, tracking of sales activities, automation of marketing campaigns, analysis of sales data, creation and management of email campaigns, integration with other tools and platforms, management of customer support enquiries, AI-assisted content generation, personalised email creation, predictive sales forecasts, automatic workflow descriptions and AI chatbots for customer interaction; Service provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central Guild Street, Dublin 1, Ireland; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.hubspot.de/pa/crm; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Data processing agreement: https://legal.hubspot.com/dpa. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.hubspot.com/dpa). 
  • Brevo: Email delivery and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider. 

Communication via messenger

We use messengers for communication purposes and therefore ask you to note the following information on the functionality of messengers, encryption, the use of communication metadata and your options for objecting. 

You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options provided to you or those specified within our online offering. 

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted. 

However, we also point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners are communicating with us, as well as technical information about the communication partners’ device and, depending on the settings of their device, location information (so-called metadata). 

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. Furthermore, if we do not ask for consent and they, for example, contact us on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of our communication partners’ needs for communication via Messenger. Furthermore, we would like to point out that we will not initially forward the contact details provided to us to the Messenger without your consent. 

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any questions from the communication partners, if no reference to a previous conversation is to be expected and the deletion is not prevented by any legal retention obligations. 

Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that we may not be able to respond to enquiries via Messenger for certain reasons. This applies to situations in which, for example, contract details must be treated as particularly confidential or a response via messenger does not meet formal requirements. In such cases, we recommend that you use more suitable communication channels. 

  • Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers) ; content data (e.g. text or image 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, usage intensity and frequency, 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: Communication. Direct marketing (e.g. by email or post). 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Consent (Art. 6(1)(a) GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, methods and services: 

  • Microsoft Teams: Used to conduct online events, conferences and communication with internal and external participants. Voice transmission, direct messaging, group communication and collaboration functions are used; name, business contact details, work profile, participation and content (audio/video, voice, chat, files, voice transcription) for the purposes of and in the interests of increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and Microsoft business processing. Audio signals are not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is stored according to the policies set by the administrator or user; automatic deletion is not set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata are processed, and diagnostic data on product stability, security and improvement is collected; service provider:Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis:Legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.microsoft.com/de-de/microsoft-365; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA). 

Artificial intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are set out below. In accordance with the term ‘AI system’ as defined in Article 3(1) of the AI Regulation, we understand AI to mean a machine-based system which is designed for varying degrees of autonomous operation, can be adaptable after its introduction, and produces results such as predictions, content, recommendations or decisions from the inputs received, which may influence physical or virtual environments. 

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

When using external AI systems, we carefully select their providers (hereinafter referred to as ‘AI providers’). In accordance with our legal obligations, we ensure that AI providers comply with the applicable regulations. We also observe our obligations when using or operating the AI services we purchase. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. In doing so, we attach particular importance to transparency, fairness and maintaining human control over AI-supported decision-making processes. 

We implement appropriate and robust technical and organisational measures to protect the data processed. These measures ensure the integrity and confidentiality of the data processed and minimise potential risks. We conduct regular reviews of AI providers and their services to ensure ongoing compliance with current legal and ethical standards. 

  • Types of data processed: Content data (e.g. textual or image-based 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, usage intensity and frequency, device types and operating systems used, interactions with content and functions). 
  • Data subjects: Users (e.g. website visitors, users of online services). Third parties. 
  • Purposes of processing: Artificial intelligence (AI). 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing operations, procedures and services: 

Video conferences, online meetings, webinars and screen sharing

We use platforms and applications from other providers (hereinafter referred to as ‘conference platforms’) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as ‘conference’). We comply with legal requirements when selecting conference platforms and their services. 

Data processed by conference platforms: When participants take part in a conference, the conference platforms process the personal data of the participants as described below. The scope of processing depends, on the one hand, on what data is required in the context of a specific conference (e.g. provision of access data or real names) and what optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ end devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e. entries in chats as well as audio and video data, and 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 on the conference platforms, additional data may be processed in accordance with the agreement with the respective conference provider. 

Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, participants will be informed of this in advance and, where necessary, asked for their consent. 

Data protection measures for participants: Please refer to the data protection information provided by the conference platforms for details on how your data is processed and select the security and data protection settings that are best for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing housemates, locking doors and, if technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties. 

Information on legal bases: If, in addition to the conference platforms, we also process user 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 processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of processing meeting results, etc.). Otherwise, user 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. text or image 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, usage intensity and frequency, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times). 
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted. 
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication. Office and organisational procedures. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, processes and services: 

  • Microsoft Teams: Use for conducting online events, conferences and communication with internal and external participants. Voice transmission, direct messaging, group communication and collaboration functions are used; name, business contact details, work profile, participation and content (audio/video, voice, chat, files, speech transcription) are processed for the purposes of and in the interests of increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and Microsoft business processing. Audio signals are not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is stored according to the guidelines specified by the administrator or user; automatic deletion is not set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata are processed, and diagnostic data on product stability, security and improvement is collected. Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA). 

Cloud services

We use software services accessible via the internet and run on the servers of their providers (so-called ‘cloud services’, also referred to as ‘software as a service’) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients, or publication of content and information). 

In this context, personal data may be processed and stored on the providers’ servers if it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimise their services. 

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image 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, usage intensity and frequency, device types and operating systems used, interactions with content and functions). 
  • Data subjects: Prospective customers; communication partners. Business and contractual partners. 
  • Purposes of processing: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, processes and services: 

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

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter referred to as ‘newsletters’) exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter. 

Deletion and restriction of processing: We may store the unsubscribed 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 limited to the purpose of potential defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called ‘blocklist’) for this purpose alone. 

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing 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 details (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, usage intensity and frequency, device types and operating systems used, interactions with content and functions). 
  • Data subjects: Communication partners. 
  • Purposes of processing: Direct marketing (e.g. by e-mail or post). Reach measurement (e.g. access statistics, recognition of returning visitors). 
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 
  • Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter at the end of each newsletter or you can use one of the contact options listed above, preferably by email. 

Further information on processing procedures, methods and services: 

  • Brevo: Email delivery and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider. 

Web analysis, monitoring and optimisation

Web analysis (also known as ‘reach measurement’) is used to evaluate visitor traffic to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite reuse. It also enables us to identify areas that require optimisation. 

In addition to web analysis, we can also use test procedures to test and optimise different versions of our online offering or its components. 

Unless otherwise specified below, profiles, i.e. data summarised for a usage process, can be created and information can be stored in a browser or on a terminal device and then read. 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 agreed to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible. 

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored during web analysis, A/B testing and optimisation, 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 purpose 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 data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy. 

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, 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: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years). 
  • Security measures: IP masking (pseudonymisation of the IP address). 
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, methods and services: 

  • Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a terminal device in order to identify which content users have accessed within one or more usage processes, which search terms they have used, have accessed again or have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their end devices and browsers. 
  • Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6(1)(a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/; security measures: IP masking (pseudonymisation of the IP address); Privacy policy:https://policies.google.com/privacy; Data processing agreement:https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information:https://business.safety.google/adsservices/(types of processing and the data processed). 

Online marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as ‘content’) based on the potential interests of users and the measurement of its effectiveness. 

For these purposes, so-called user profiles are created and stored in a file (the so-called ‘cookie’) or similar procedures are used to store information about the user that is relevant for the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this may also be processed. 

In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles. 

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

In exceptional cases, it is possible to assign clear data to the profiles, primarily if the users are members of a social network, for example, whose online marketing method we use and which links the user profiles with the aforementioned information. Please note that users can enter into additional agreements with the providers, for example by giving their consent during registration. 

We generally only have access to summarised information about the success of our advertisements. However, we can use conversion measurements to check which of our online marketing methods have led to a conversion, i.e. for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures. 

Unless otherwise stated, please assume that the cookies used will be stored for a period of two years. 

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

Information on revocation and objection: 

We refer you to the data protection information of the respective providers and the options for objection (so-called ‘opt-out’) specified for the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions: 

a) Europe: https://www.youronlinechoices.eu. 

b) Canada: https://youradchoices.ca/. 

c) USA: https://optout.aboutads.info/. 

d) Cross-regional: https://optout.aboutads.info. 

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, 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). 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). Communication partners. 
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-based profiling, use of cookies); target group formation; marketing; profiles with user-related information (creation of user profiles). Communication. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years). 
  • Security measures: IP masking (pseudonymisation of the IP address). 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing operations, procedures and services: 

  • LinkedIn messages: Sending messages via the LinkedIn social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy. Basis for third-country transfers: Data Privacy Framework (DPF). 

Presence on social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us. 

We would like to point out that user data may be processed outside the European Union. This may result in risks for users, as it could, for example, make it more difficult to enforce user rights. 

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

For a detailed description of the respective forms of processing and the options for objection (opt-out), please 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 would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still require assistance, please contact us. 

  • Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image 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, usage intensity and frequency, 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: Communication; feedback (e.g. collecting feedback via online form). Public relations. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing operations, procedures and services: 

  • Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.instagram.com; Privacy policy:https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF). 
  • LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible 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 that users view or interact with, as well as the actions they take. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size and employment status. 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 entered into a special agreement with LinkedIn Ireland (‘Page Insights Joint Controller Addendum’, https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option:https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. 

Plug-ins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavour to only use 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. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, but 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 data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy. 

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, types of devices 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: Provision of our online services and user-friendliness. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years). 
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, methods and services: 

  • Font Awesome (obtained from the provider’s server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform display and consideration of possible licensing restrictions. The user’s IP address is communicated to the font provider so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) necessary for the provision of the fonts depending on the devices used and the technical environment is transmitted. Service provider: Fonticons, Inc., 6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fontawesome.com/. Privacy policy: https://fontawesome.com/privacy. 

Management, organisation and support tools

We use services, platforms and software from other providers (hereinafter referred to as ‘third-party providers’) for the purposes of organisation, administration, planning and provision of our services. We comply with the legal requirements when selecting third-party providers and their services. 

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

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

  • Types of data processed: Content data (e.g. text or image 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, usage intensity and frequency, 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); Inventory data (e.g. full name, residential address, contact information, customer number, etc.). Contact details (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: Communication; provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures. 
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. 
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing procedures, processes and services: 

Changes and updates

We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your involvement (e.g. consent) or other individual notification is required as a result of the changes. 

If we provide addresses and contact information for companies and organisations in this privacy policy, please note that the addresses may change over time and check the information before contacting them. 

Definition of terms

This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding. 

  • Employees: Employees are persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is 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 the establishment, in which the employment contract is concluded, the performance, in which the employee carries out their work, and the termination, when the employment relationship ends, whether through dismissal, a termination agreement or otherwise. Employee data is all information relating to these individuals and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals. 
  • Master data: Master data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities or systems by enabling unique assignment and communication. 
  • Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates. 
  • Contact data: Contact data is essential information that enables communication with individuals or organisations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers. 
  • Artificial intelligence (AI): The purpose of processing data using artificial intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of data, the training and application of AI models, and the continuous review and optimisation of results, and is carried out exclusively with the consent of users or on the basis of legal permissions. 
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It may include details of file size, creation date, document author and change history. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages and chat histories, including the individuals involved, timestamps and transmission routes. Procedural data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations. 
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising 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’ is any information relating to an identified or identifiable natural person (hereinafter ‘data subject’); A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 
  • Profiles with user-related information: The processing of ‘profiles with user-related information’, or ‘profiles’ for short, includes any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information regarding demographics, behaviour and interests, such as interaction with websites and their content, etc.). 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 timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, monitor security or create performance reports. 
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them to better tailor the content of their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more accurate analyses of the use of an online service. 
  • Tracking: ‘Tracking’ refers to the tracking of user behaviour across multiple online services. As a rule, information about behaviour and interests is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling) with regard to the online offerings used. This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests. 
  • Controller: The ‘controller’ is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. 
  • Processing: ‘Processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it is collection, evaluation, storage, transmission or deletion. 
  • Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment 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 the start and end dates of the contract, the type of services or products agreed upon, price 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 includes all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorisations and fees. 
  • Target group formation: Target group formation (known as ‘custom audiences’) refers to the process of determining target groups for advertising purposes, e.g. displaying advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. The term ‘lookalike audiences’ (or similar target groups) is used when content that is considered suitable is displayed to users whose profiles or interests are presumed to correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences. 

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