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Privacy Policy

Preamble

With the following Privacy Policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly 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 Offer").

The terms used are not gender-specific.

As of: December 19, 2025

Table of Contents

Controller

Louis Materi / SMI - Digital UG (haftungsbeschränkt)
Wallensteinstraße 127
90431 Nuremberg Germany

Represented by the managing directors: Louis Materi, Pascal Stefani, and Leon Ivkovic

E-Mail Address: kontakt@smi-digital.com

Imprint: https://www.smi-digital.com/en/imprint/

Overview of Processing Activities

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

Types of Processed Data

  • Inventory Data.
  • Payment Data.
  • Location Data.
  • Contact Data.
  • Content Data.
  • Contract Data.
  • Usage Data.
  • Meta, Communication, and Procedural Data.
  • Log Data.

Categories of Data Subjects

  • Service Recipients and Clients.
  • Interested Parties.
  • Communication Partners.
  • Users.
  • Sweepstakes and Competition Participants.
  • Business and Contractual Partners.
  • Educational and Course Participants.

Purposes of Processing

  • Provision of Contractual Services and Fulfillment of Contractual Obligations.
  • Communication.
  • Security Measures.
  • Direct Marketing.
  • Reach Measurement.
  • Tracking.
  • Office and Organizational Procedures.
  • Target Audience Formation.
  • Affiliate Tracking.
  • Organizational and Administrative Procedures.
  • Execution of Sweepstakes and Competitions.
  • Feedback.
  • Marketing.
  • Profiles with User-Related Information.
  • Provision of our Online Offer and User-Friendliness.
  • Information Technology Infrastructure.
  • Public Relations.
  • Sales Promotion.
  • Business Processes and Economic Procedures.

Relevant Legal Bases

Relevant Legal Bases under the GDPR: Below you will find an overview of the legal bases of the GDPR upon which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection requirements in your or our country of residence or domicile may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the Privacy Policy.

  • Consent (Art. 6 (1) sentence 1 lit. a GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal Obligation (Art. 6 (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) sentence 1 lit. f GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

Security Measures

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

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transmission, securing availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data, and responses to data threats. Furthermore, we consider the protection of personal data as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

IP Address Truncation: If IP addresses are processed by us or by the service providers and technologies we use, and processing a full IP address is not required, the IP address is truncated (also referred to as "IP masking"). In this process, the last two digits, or the last part of the IP address after a period, are removed or replaced by placeholders. The purpose of truncating the IP address is to prevent or significantly impede the identification of a person based on their IP address.

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

Transmission of Personal Data

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

International Data Transfers

Data Processing in Third Countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies (which becomes recognizable based on the postal address of the respective provider or if explicitly pointed out in the privacy policy regarding data transfer to third countries), this always takes place in accordance with the legal requirements.

For data transfers to the US, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which correspond to the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual protection ensures comprehensive security for your data: The DPF forms the primary protection layer, while the Standard Contractual Clauses serve as an additional safeguard. Should changes arise within the framework of the DPF, the Standard Contractual Clauses step in as a reliable fallback option. This allows us to ensure that your data remains adequately protected at all times, even in the event of political or legal changes.

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

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

General Information on Data Storage and Deletion

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

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

Our privacy notices contain additional information on the retention and deletion of data that apply specifically to certain processing operations.

If multiple indications are provided for the retention period or deletion deadlines of a data record, the longest period is always decisive. Data that is no longer kept for the originally intended purpose, but rather due to legal requirements or other reasons, is processed exclusively for the reasons that justify its retention.

Retention and Deletion of Data: The following general periods apply to retention and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet, as well as the working instructions and other organizational documents required 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 vouchers, 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: received commercial or business letters, copies of dispatched commercial or business letters, other documents, insofar as they are relevant for taxation, e.g., hourly wage slips, business accounting sheets, calculation documents, price tags, but also payroll documents, provided they are not already accounting vouchers, and cash register strips (Section 147 (1) No. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) No. 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 associated inquiries, based on previous business experiences and usual industry practices, are stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

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

Rights of Data Subjects

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

  • Right to Object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6 (1) lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw given consents at any time.
  • Right of Access: You have the right to request confirmation as to whether the data in question is being processed and to request access to this data as well as further information and a copy of the data in accordance with statutory requirements.
  • Right to Rectification: You have the right, in accordance with the legal requirements, to demand the completion of data concerning you or the rectification of incorrect data concerning you.
  • Right to Erasure and Restriction of Processing: You have the right, in accordance with the legal requirements, to demand that data concerning you be deleted without delay, or, alternatively, to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to Data Portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with the statutory requirements, or to demand its transmission to another controller.
  • Complaint to Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes 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 as well as associated measures and with regard to communication with the Contractual Partners (or pre-contractually), such as to answer inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedying warranty and other service disruptions. Furthermore, we use the data to safeguard our rights and for the purposes of the administrative tasks associated with these duties as well as company organization. In addition, we process the data based on our legitimate interests in orderly and business-like management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., involving 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 insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about further forms of processing, such as for marketing purposes, within this Privacy Policy.

We inform the contractual partners of which data is required for the aforementioned purposes before or in the context of data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally.

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 reasons by law (e.g., for tax purposes generally ten years). Data disclosed to us by the contractual partner in the context of a contract will be deleted in accordance with the specifications and generally after the end of the contract.

  • Processed Data Types: Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Payment Data (e.g., bank details, invoices, payment history); Contact Data (e.g., postal and e-mail addresses or telephone numbers); Contract Data (e.g., subject of the contract, term, customer category); Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Service Recipients and Clients; Interested Parties; Business and Contractual Partners; Educational and Course Participants.
  • Purposes of Processing: Provision of Contractual Services and Fulfillment of Contractual Obligations; Security Measures; Communication; Office and Organizational Procedures; Organizational and Administrative Procedures; Business Processes and Economic Procedures.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR); Legal Obligation (Art. 6 (1) sentence 1 lit. c GDPR); Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Online Shop, Order Forms, E-Commerce, and Service Fulfillment: We process the data of our customers in order to enable them to select, acquire, or order the selected products, goods, and related services, as well as their payment and provision, or delivery, or execution. Insofar as necessary for the execution of an order, we engage service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the ordering or comparable acquisition process and includes the information required for delivery, or provision, and billing as well as contact information in order to be able to consult if necessary; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).
  • Agency Services: We process the data of our customers within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).
  • Educational and Training Services: We process the data of the participants of our educational and training offers (uniformly referred to as "Trainees") in order to be able to provide our training services to them. The data processed here, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include performance assessment and the evaluation of our services as well as those of the teachers. In the context of our activities, we may also process special categories of data, here in particular health data of the trainees as well as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. For this purpose, we obtain explicit consent from the trainees if necessary and otherwise process the special categories of data only if it is necessary for the provision of the training services, for purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services, or to protect the vital interests of the trainees; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).
  • Project and Development Services: We process the data of our customers and clients (hereinafter uniformly referred to as "Customers") to enable them to select, purchase, or commission the chosen services or works, as well as related activities, and their payment and provision, or execution, or fulfillment.

    The required information is identified as such within the context of the order, purchase, or comparable conclusion of a contract and includes the details needed for the provision of services and billing, as well as contact information to handle any necessary follow-up. Insofar as we gain access to information concerning end customers, employees, or other persons, we process this in accordance with legal and contractual requirements; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).
  • Offering of Software and Platform Services: We process the data of our users, registered users, and potential test users (hereinafter uniformly referred to as "Users") to provide them with our contractual services, and on the basis of legitimate interests, to ensure the security of our offer and to further develop it. The required information is marked as such within the context of the order, purchase, or comparable conclusion of the contract and includes the information necessary for the provision of services and billing, as well as contact information for any queries; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).
  • Technical Services: We process the data of our customers and clients (hereinafter uniformly referred to as "Customers") to enable them to select, purchase, or commission the chosen services or works, as well as related activities, and their payment and provision, or execution, or fulfillment.

    The required information is identified as such within the context of the order, purchase, or comparable conclusion of a contract and includes the details needed for the provision of services and billing, as well as contact information to handle any necessary follow-up. Insofar as we gain access to information concerning end customers, employees, or other persons, we process this in accordance with legal and contractual requirements; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).
  • Event Management: We process the data of the participants in events, functions, and similar activities offered or hosted by us (hereinafter uniformly referred to as "Participants" and "Events") in order to enable them to participate in the Events and utilize the services or promotions associated with participation.

    If we process health-related data, religious, political, or other special categories of data in this context, this is done within the scope of public knowledge (e.g., at thematically oriented events or serves healthcare, security, or is carried out with the consent of the data subjects).

    The required information is marked as such during the order, booking, or comparable conclusion of the contract and includes the information required for service provision and billing, as well as contact information for any necessary inquiries. Insofar as we gain access to information about end customers, employees, or other individuals, we process this in accordance with statutory and contractual requirements; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).

Provision of the Online Offer and Web Hosting

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

  • Processed Data Types: Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved); Log Data (e.g., log files concerning logins or the retrieval of data or access times).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Provision of our Online Offer and User-Friendliness; Information Technology Infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security Measures.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Provision of Online Offer on Rented Storage Space: For the provision of our online offer, we use storage space, computing capacity, and software that we rent or otherwise obtain from an appropriate server provider (also called "Web Hoster"); Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).
  • Collection of Access Data and Log Files: Access to our online offer is logged in the form of so-called "Server Log Files". Server log files may include the address and name of the retrieved web pages and files, date and time of retrieval, transferred data volumes, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), and generally IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to avoid an overload of the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the capacity of the servers and their stability; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR). Deletion of Data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes are exempt from deletion until the final clarification of the respective incident.
  • netcup: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service Provider: netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.netcup.de/; Privacy Policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php. Data Processing Agreement: https://helpcenter.netcup.com/de/wiki/general/avv/.

Use of Cookies

The term "cookies" refers to functions that store information on users' end devices and read information from them. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online offers as well as the creation of analyses of visitor flows. We use cookies in accordance with statutory regulations. For this, if necessary, we obtain the prior consent of the users. If consent is not required, we rely on our legitimate interests. This applies when the storage and reading of information is indispensable to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offer. Consent can be withdrawn at any time. We inform clearly about their scope and which cookies are used.

Notes on Legal Bases under Data Protection Law: Whether we process personal data with the help of cookies depends on consent. If consent is 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 Duration: With regard to the storage duration, a distinction is made between the following types of cookies:

  • Temporary Cookies (also: Session Cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his or her end device (e.g., browser or mobile application).
  • Permanent Cookies: Permanent cookies remain stored even after the end device has been closed. For example, the log-in status can be saved, and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used for reach measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., as part of obtaining consent), they should assume that these are permanent and the storage duration can be up to two years.

General Notes on Withdrawal and Objection (Opt-Out): Users can revoke their consent at any time and also declare an objection to the processing in accordance with the statutory requirements, including by means of the privacy settings of their browser.

  • Processed Data Types: Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Consent (Art. 6 (1) sentence 1 lit. a GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Processing of cookie data on the basis of consent (Custom In-House Solution): We use a custom-developed consent management solution (cookie banner) on our website, which obtains the explicit consent of users for the use of cookies requiring consent or for the procedures and providers mentioned within this solution (e.g., for web analysis or online marketing). This system strictly blocks the setting of cookies and comparable technologies requiring consent until you, as a user, actively give your consent. The procedure serves the purpose of obtaining, logging, managing, and revoking consents. Users have the option to manage and revoke their granted consents at any time via the corresponding settings on our website. The declarations of consent are stored to avoid a repeated request during future page visits and to be able to provide proof of consent in accordance with legal requirements (Art. 7 (1) GDPR). Since this system was developed entirely in-house and is hosted on our own servers, no data transmission to external third-party providers (consent management providers) takes place. The storage takes place server-side and/or locally in your browser (e.g., in the Local Storage or as a so-called opt-in cookie) using a pseudonymous user identifier to be able to assign the consent to a specific user or their device. The duration of the storage of the consent is up to two years. In this process, the pseudonymous user identifier is stored together with the time of consent, information on the scope of the consent (e.g., relevant categories of cookies and/or service providers), as well as basic information about the browser, the system, and the end device used; Legal basis: Compliance with a legal obligation (Art. 6 (1) (c) GDPR in conjunction with Art. 7 (1) GDPR) as well as Section 25 (2) No. 2 TDDDG (technical necessity for setting the consent cookie/local storage).

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter "Publication Medium"). Readers' data is only processed for the purposes of the publication medium insofar as it is necessary for its presentation and the communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within this privacy notice.

  • Processed Data Types: Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Contact Data (e.g., postal and e-mail addresses or telephone numbers); Content Data (e.g., text or visual messages and posts as well as information relating to them, such as details on authorship or time of creation); Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Feedback (e.g., collecting feedback via an online form); Provision of our Online Offer and User-Friendliness.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Contact and Request Management

When contacting us (e.g., by post, contact form, e-mail, telephone, or via social media) as well as within the framework of existing user and business relationships, the details of the inquiring persons are processed insofar as this is necessary to respond to the contact requests and any requested measures.

  • Processed Data Types: Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Contact Data (e.g., postal and e-mail addresses or telephone numbers); Content Data (e.g., text or visual messages and posts as well as information relating to them, such as details on authorship or time of creation); Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Communication Partners.
  • Purposes of Processing: Communication; Organizational and Administrative Procedures; Feedback (e.g., collecting feedback via an online form); Provision of our Online Offer and User-Friendliness.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Contact Form: When contacting us via our contact form, by e-mail, or other communication channels, we process the personal data transmitted to us to respond to and handle the respective inquiry. This usually includes details such as name, contact information, and possibly other information provided to us that is required for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR), Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Newsletters and Electronic Notifications

We send newsletters, e-mails, and other electronic notifications (hereinafter "Newsletter") exclusively with the consent of the recipient or on a legal basis. Insofar as the contents of a newsletter are specifically described as part of a registration, they are decisive for the consent of the users. For registration to our newsletter, the provision of your e-mail address is normally sufficient. However, to provide you with a personalized service, we may ask you to provide your name to address you personally in the newsletter, or for further information if necessary for the purpose of the newsletter.

Deletion and Restriction of Processing: We may store the unsubscribed e-mail addresses for up to three years based on our legitimate interests before deleting them, to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense 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 e-mail address solely for this purpose in a blocklist.

The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of proving its proper sequence. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Contents:

Information about us, our services, promotions, and offers.

  • Processed Data Types: Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Contact Data (e.g., postal and e-mail addresses or telephone numbers); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Communication Partners.
  • Purposes of Processing: Direct Marketing (e.g., by e-mail or post).
  • Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR).
  • Right to Object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e., revoke your consents, or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or can otherwise use one of the contact options given above, preferably e-mail, for this purpose.

Promotional Communication via E-Mail, Post, Fax, or Telephone

We process personal data for purposes of promotional communication, which can take place via various channels, such as e-mail, telephone, post, or fax, in accordance with legal requirements.

Recipients have the right to revoke given consents at any time or to object to promotional communication at any time free of charge using the contact option mentioned above.

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

  • Processed Data Types: Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Contact Data (e.g., postal and e-mail addresses or telephone numbers); Content Data (e.g., text or visual messages and posts as well as information relating to them, such as details on authorship or time of creation).
  • Data Subjects: Communication Partners.
  • Purposes of Processing: Direct Marketing (e.g., by e-mail or post); Marketing; Sales Promotion.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Sweepstakes and Competitions

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

If participants' entries are published within the context of the sweepstakes (e.g., in the context of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we point out that the names of the participants may also be published in this context. Participants can object to this at any time.

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

The data of the participants will be deleted as soon as the sweepstakes or competition has ended and the data is no longer necessary to inform the winners or because no further inquiries about the sweepstakes are to be expected. As a rule, participants' data is deleted at the latest 6 months after the end of the sweepstakes. Data of the winners can be retained longer to, e.g., answer inquiries about the prizes or fulfill the prize benefits; in this case, the retention period depends on the type of prize and is, e.g., up to three years for items or services to be able to process warranty cases. Furthermore, participants' data can be stored longer, e.g., in the form of reporting on the sweepstakes in online and offline media.

If data was also collected for other purposes within the scope of the sweepstakes, their processing and the retention period follow the privacy notices for this use (e.g., in the case of a registration for the newsletter as part of a sweepstakes).

  • Processed Data Types: Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Contact Data (e.g., postal and e-mail addresses or telephone numbers); Content Data (e.g., text or visual messages and posts as well as information relating to them, such as details on authorship or time of creation).
  • Data Subjects: Sweepstakes and Competition Participants.
  • Purposes of Processing: Execution of Sweepstakes and Competitions.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Performance of a Contract and Prior Requests (Art. 6 (1) sentence 1 lit. b GDPR); Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Web Analytics, Monitoring, and Optimization

Web analytics (also referred to as "reach measurement") serves the evaluation of visitor flows to our online offer and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are used most frequently, or invite for reuse. We can also trace which areas need optimization.

In addition to web analytics, we can also use test procedures, for example, to test and optimize different versions of our online offer or its components.

Unless stated otherwise below, profiles, i.e., data compiled for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and then read out. The information collected primarily includes visited websites and elements used there as well as technical information, such as the browser used, the computer system used, and details on usage times. If users have agreed to the collection of their location data vis-à-vis us or the providers of the services we use, 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., pseudonymization by truncating the IP address) to protect users. Generally, within the scope of web analytics, A/B testing, and optimization, no clear data of the users (such as e-mail addresses or names) is stored, but pseudonyms. This means that both we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

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

  • Processed Data Types: Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, 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 (creating user profiles); Provision of our Online Offer and User-Friendliness.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (Unless stated otherwise, cookies and similar storage methods can be stored on users' devices for a period of two years).
  • Security Measures: IP Masking (Pseudonymization of the IP address).
  • Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offer based on a pseudonymous user identification number. This identification number contains no clear data, such as names or e-mail addresses. It serves to assign analysis information to a device in order to recognize which content the users accessed within one or various usage processes, which search terms they used, called them up again, or interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their devices and browsers.
    Pseudonymous profiles of users are created with information from the use of various devices, wherein cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse 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). With EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is routed to Analytics servers for processing; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security Measures: IP Masking (Pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Right to Object (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Ads: https://myadcenter.google.com/personalizationoff. Further Information: https://business.safety.google/adsservices/ (Types of Processing and Processed Data).

Online Marketing

We process personal data for the purpose of online marketing, which includes in particular the marketing of advertising space or the presentation of promotional and other contents (collectively referred to as "Contents") based on potential interests of the users as well as the measurement of their effectiveness.

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

In addition, the IP addresses of the users are stored. However, we use available IP masking procedures (i.e., pseudonymization by truncating the IP address) to protect users. Generally, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing procedure, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the user, but only the information stored in their profiles.

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

Exceptionally, clear data can be assigned to the profiles, primarily if the users are members of a social network, for example, whose online marketing procedure we use and the network links the user profiles with the aforementioned details. We ask you to note that users can make additional agreements with the providers, e.g., through consent during registration.

We generally only receive access to summarized information on the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used exclusively for the performance analysis of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

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

Notes on Withdrawal and Objection:

We refer to the privacy notices of the respective providers and the opt-out options specified for the providers. If no explicit opt-out option has been provided, you have the option on the one hand to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered in a summarized manner aimed at respective regions:

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

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

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

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

  • Processed Data Types: Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, 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); Tracking (e.g., interest/behavior-related profiling, use of cookies); Target Audience Formation; Marketing; Profiles with User-Related Information (creating user profiles).
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (Unless stated otherwise, cookies and similar storage methods can be stored on users' devices for a period of two years).
  • Security Measures: IP Masking (Pseudonymization of the IP address).

Affiliate Programs and Affiliate Links

We incorporate so-called affiliate links or other references (which may include, e.g., search masks, widgets, or discount codes) into our online offer that lead to the offers and services of third-party providers (collectively referred to as "Affiliate Links"). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "Commission").

To be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third-party providers to learn that the users followed an affiliate link placed within our online offer. The assignment of affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission settlement and is deleted as soon as it is no longer required for the purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented with certain values that are a component of the link or can be stored elsewhere, e.g., in a cookie. The values may in particular include the referring website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.

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

  • Processed Data Types: Contract Data (e.g., subject of the contract, term, customer category); Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Interested Parties; Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Affiliate Tracking.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Amazon Partner Program: Affiliate partner program (Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates); Service Provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.amazon.de; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010. Basis for Third-Country Transfers: Data Privacy Framework (DPF).

Customer Reviews and Rating Procedures

We participate in review and rating procedures in order to evaluate, optimize, and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions or Terms of Use and the privacy notices of the providers apply additionally. As a rule, a review also requires registration with the respective providers.

To ensure that the reviewing persons have actually used our services, we transmit the necessary data regarding the customer and the service used to the respective rating platform with the customer's consent (including name, e-mail address, and order number or article number). This data is used solely to verify the authenticity of the user.

  • Processed Data Types: Contract Data (e.g., subject of the contract, term, customer category); Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Service Recipients and Clients; Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Feedback (e.g., collecting feedback via an online form); Marketing.
  • Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Presences in Social Networks (Social Media)

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

We point out that user data may be processed outside the European Union. This can result in risks for users because, for example, the enforcement of users' rights could be made more difficult.

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

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

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

  • Processed Data Types: Contact Data (e.g., postal and e-mail addresses or telephone numbers); Content Data (e.g., text or visual messages and posts as well as information relating to them, such as details on authorship or time of creation); Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Inventory Data (e.g., full name, residential address, contact information, customer number, etc.); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Communication; Feedback (e.g., collecting feedback via an online form); Public Relations; Provision of our Online Offer and User-Friendliness; Information Technology Infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Instagram: Social network; allows sharing of photos and videos, commenting and favoriting posts, messaging, subscribing to profiles and pages; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for Third-Country Transfers: Data Privacy Framework (DPF).
  • Facebook Pages: Profiles within the social network Facebook - The controller is jointly responsible with Meta Platforms Ireland Limited for collecting and transferring data of visitors to our Facebook page ("Fanpage"). This includes, in particular, information about user behavior (e.g., viewed or interacted contents, actions performed) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). More details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical analyses via the "Page Insights" service, giving insight into how people interact with our page and its content. The basis for this is an agreement with Facebook ("Information about Page Insights Data": https://www.facebook.com/legal/terms/page_controller_addendum), which, among other things, governs security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore send access or deletion requests directly to Facebook. The rights of the users (especially access, deletion, objection, complaint to a supervisory authority) remain unaffected by this. The joint responsibility is strictly limited to the collection of data by Meta Platforms Ireland Limited (EU). For further processing, including a possible transfer to Meta Platforms Inc. in the US, Meta Platforms Ireland Limited is solely responsible; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • LinkedIn: Social Network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not further processing) of data of visitors used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as professional function, country, industry, hierarchy level, company size, and employment status. Data protection information regarding the processing of user data by LinkedIn can be found in LinkedIn's privacy notices: https://www.linkedin.com/legal/privacy-policy.
    We have concluded a specific agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), in which it is specifically regulated what security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, send access or deletion requests directly to LinkedIn). The rights of users (in particular the right to access, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly regarding 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 Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Right to Object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Pinterest: Social network; allows sharing of photos, commenting, favoriting, and curating posts, messaging, subscribing to profiles; Service Provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/en/privacy-policy.
  • Threads: Social Network; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.threads.com/. Privacy Policy: https://help.instagram.com/515230437301944.
  • X: Social Network; Service Provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://x.com. Privacy Policy: https://x.com/en/privacy.
  • YouTube: Social network and video platform; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for Third-Country Transfers: Data Privacy Framework (DPF). Right to Object (Opt-Out): https://myadcenter.google.com/personalizationoff.

Plug-ins and Embedded Functions and Content

We integrate function and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "Third-Party Providers"). This can include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "Content").

The integration always requires that the third-party providers of this content process the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content or functions. We endeavor to use only such 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 referred to as "web beacons") for statistical or marketing purposes. By means of "pixel tags", information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user's device and may include, among other things, technical information regarding the browser and operating system, referring websites, time of visit, and other details regarding the use of our online offer, but it can also be linked to such information from other sources.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is 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.

  • Processed Data Types: Usage Data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, Communication, and Procedural Data (e.g., IP addresses, times, identification numbers, persons involved); Location Data (details on the geographical position of a device or a person).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Provision of our Online Offer and User-Friendliness; Reach Measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavior-related profiling, use of cookies); Target Audience Formation; Marketing.
  • Retention and Deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (Unless stated otherwise, cookies and similar storage methods can be stored on users' devices for a period of two years).
  • Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further Information on Processing Operations, Procedures, and Services:

  • Integration of Third-Party Software, Scripts, or Frameworks (e.g., jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g., function libraries that we use for presentation or user-friendliness of our online offer). The respective providers collect the user's IP address and may process it for the purpose of transmitting the software to the user's browser, as well as for security purposes and to evaluate and optimize their offer; Legal Bases: Legitimate Interests (Art. 6 (1) sentence 1 lit. f GDPR).
  • Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include in particular users' IP addresses and location data; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for Third-Country Transfers: Data Privacy Framework (DPF).
  • YouTube Videos: Video Content; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 (1) sentence 1 lit. a GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for Third-Country Transfers: Data Privacy Framework (DPF). Right to Object (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Ads: https://myadcenter.google.com/personalizationoff.

Changes and Updates

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

If we provide addresses and contact information of companies and organizations in this Privacy Policy, we kindly ask you to note that the addresses may change over time and request you to verify the details before contacting them.

Definitions of Terms

This section provides you with an overview of the terms used in this Privacy Policy. If the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Affiliate Tracking: In the context of affiliate tracking, links through which referring websites point users to websites offering products or other services are logged. The operators of the respective referring websites may receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). For this, it is necessary that the providers can track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. Therefore, for the functionality of affiliate links, it is necessary that they be supplemented by certain values that become a component of the link or are otherwise stored, e.g., in a cookie. These values include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as e.g., advertising media ID, partner ID, and categorizations.
  • Inventory Data: Inventory data (master data) includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data can include personal and demographic details such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unambiguous assignment and communication.
  • Content Data: Content data encompasses information generated in the course of creating, editing, and publishing content of all kinds. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata providing information about the content itself, such as tags, descriptions, author information, and publication dates.
  • Contact Data: Contact data is essential information that allows communication with individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and e-mail addresses, as well as communication channels like social media handles and instant messaging identifiers.
  • Meta, Communication, and Procedural Data: Meta, communication, and procedural data are categories containing information about the way data is processed, transmitted, and managed. Meta-data, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details on file size, creation date, the author of a document, and version histories. Communication data records the exchange of information between users across various channels, such as e-mail traffic, call logs, messages in social networks, and chat histories, including the people involved, timestamps, and transmission routes. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and review operations.
  • Usage Data: Usage data refers to information recording how users interact with digital products, services, or platforms. This data covers a broad range of information highlighting how users use applications, which features they prefer, how long they stay on specific pages, and the paths they navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information, and location data. They are highly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a critical role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal Data: "Personal Data" means any information relating to an identified or identifiable natural person (hereinafter "Data Subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles with User-Related Information: The processing of "profiles with user-related information", or simply "profiles", comprises any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information regarding demographics, behavior, and interests, such as interaction with websites and their contents, etc.) to analyze, evaluate, or predict them (e.g., interests in certain contents or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log Data: Log data is information about events or activities logged within a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details concerning the use or operation of a system. Log data is often used for analyzing system problems, security monitoring, or creating performance reports.
  • Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows to an online offer and can encompass the behavior or interests of visitors in specific information, such as the contents of webpages. With the aid of reach analysis, operators of online offers can identify, for example, at what times 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. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Location Data: Location data occurs when a mobile device (or another device with the technical prerequisites for determining location) connects to a cellular network, a WLAN, or similar technical means and functions of location determination. Location data serves to indicate the geographically determinable position on Earth where the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Tracking: "Tracking" occurs when the behavior of users can be traced across multiple online offers. Generally, behavior and interest information regarding the used online offers are stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to show users advertisements that are likely to correspond to their interests.
  • Controller: "Controller" refers to 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 or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission, or deletion.
  • Contract Data: Contract data is specific information related to the formalization of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include contract start and end dates, the nature of agreed services or products, price agreements, payment terms, cancellation rights, renewal options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
  • Payment Data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of critical importance for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data can also contain information about the payment status, chargebacks, authorizations, and fees.
  • Target Audience Formation: Target audience formation (or "Custom Audiences") occurs when target groups are determined for advertising purposes, e.g., for the display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in ads for similar products or the online shop where they viewed the products. "Lookalike Audiences" (or similar target audiences) refers to when content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.

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