Data protection
Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).
The terms used are not gender-specific.
As of: January 11, 2025
Responsible person
Wolfgang Feger
bewida e. U.
Waldrosengasse 1
1140 Wien
Österreich
Authorized representatives:
Wolfgang Feger
E-Mail-Adresse: [email protected]
Impressum: https://bewida.io/impressum/
Contact data protection officer
Wolfgang Feger
+43 (0) 677 6161 30 65
[email protected]
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Bestandsdaten.
- Employee data.
- Payment details.
- Standortdaten.
- Kontaktdaten.
- Inhaltsdaten.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Sozialdaten.
- Bewerberdaten.
- Image and/or video recordings.
- Tonaufnahmen.
- Contact information (Facebook).
- Event-Daten (Facebook).
- Protokolldaten.
- Performance and behavior data.
- Working time data.
- Credit details.
- Gehaltsdaten.
Special categories of data
- Gesundheitsdaten.
- Religious or ideological beliefs.
- Union affiliation.
Category betreffener Personen
- beneficiaries and clients.
- Employees.
- Interessenten.
- Communication partner.
- Nutzer.
- Bewerber.
- Competition and competition participants.
- Business and contractual partners.
- Education and course participants.
- Teilnehmer.
- People depicted.
- Dritte Personen.
- Kunden.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Kommunikation.
- Security measures.
- Direktmarketing.
- Range measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Konversionsmessung.
- Click tracking.
- Target group formation.
- A/B-Tests.
- Organizational and administrative procedures.
- Application procedure.
- Conducting sweepstakes and competitions.
- Content Delivery Network (CDN).
- Feedback.
- Heatmaps.
- Surveys and questionnaires.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Assessment of creditworthiness and creditworthiness.
- Justification and implementation of employment relationships.
- Informationstechnische Infrastruktur.
- Public relations and information purposes.
- Financial and payment management.
- Public relations.
- Absatzförderung.
- Business processes and business management procedures.
- Artificial Intelligence (AI).
Automated decisions in individual cases
- Credit report.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR, on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases apply in individual cases, we will inform you about these in the data protection declaration.
- Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR) – The data subject has given their consent to the processing of personal data concerning them for a specific purpose or several specific purposes.
- Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or to carry out pre-contractual measures at the data subject’s request.
- Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR) – the processing is necessary to safeguard the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject, which require the protection of personal data, do not outweigh them.
- Application process as a pre-contractual or contractual relationship (Art. 6 Para. 1 S. 1 lit. b) GDPR) – As far as the application process involves special categories of personal data within the meaning of Art. 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) for applicants are requested so that the person responsible or the person concerned can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard, the processing takes place in accordance with Article 9 Paragraph 2 Letter b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 Para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 Para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing takes place on the basis of Article 9 Paragraph 2 Letter a. GDPR.
- Processing of special categories of personal data relating to healthcare, occupation and social security (Art. 9 para. 2 lit. h) GDPR) – The processing is for the purposes of preventive health or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector on the basis of Union law or the law of a Member State or as a result of a contract with a health professional.
National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. This includes, in particular, the Federal Law on the Protection of Natural Persons when Processing Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or deletion, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases.
Relevant legal bases according to the Swiss Data Protection Act: If you are in Switzerland, we process your data on the basis of the Federal Data Protection Act (“Swiss Data Protection Act” for short). Unlike the GDPR, for example, the Swiss DSG does not generally provide that a legal basis for the processing of personal data must be stated and that the processing of personal data is carried out in good faith, is lawful and proportionate (Article 6 Para. 1 and 2 of the Swiss DSG). In addition, we only obtain personal data for a specific purpose that is recognizable to the person concerned and only process it in a way that is compatible with this purpose (Art. 6 Para. 3 of the Swiss Data Protection Act).
Note on the validity of the DSGVO and Swiss DSG: This data protection notice serves to provide information according to both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to their broader spatial application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss DSG, the terms “processing” of “personal data” as well as “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 according to the Swiss DSG within the scope of the Swiss DSG.
Safety measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing availability and their separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and responses are made to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use 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 advanced and more secure version of SSL, ensures that all data transfers meet the highest security standards. If 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 being transmitted securely and encrypted.
Transmission of personal data
As part of our processing of personal data, it may happen that these are transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data can include: B. include service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Internationale Datentransfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other people, bodies or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Furthermore, data transfers only take place if the level of data protection is otherwise secured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 Para. 1 GDPR). We will also inform you about the basics of third-country transfers for the individual providers from the third country, with the adequacy decisions taking precedence as the basic principles. Information on third country transfers and existing adequacy decisions can be found in the EU Commission’s information offering: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also increased the level of data protection for certain companies from the USA as part of the adequacy decision of Recognized as safe on July 10, 2023. The list of certified companies and further information about the DPF can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.
Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act, we only disclose personal data abroad if adequate protection of the persons concerned is guaranteed (Art. 16 Swiss Data Protection Act). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anwissen-staats.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations approved in advance by the FDPIC or a competent data protection authority of another country. According to Article 16 of the Swiss Data Protection Act, exceptions for the disclosure of data abroad can be permitted if certain conditions are met, including the consent of the data subject, execution of the contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These announcements are always made in accordance with legal requirements. As part of the so-called “Data Privacy Framework” (DPF), the Swiss recognized the level of data protection for certain companies from the USA as secure as part of the adequacy decision of June 7, 2024. The list of certified companies and additional information about the DPF can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we will inform you about which service providers we use are certified under the Data Privacy Framework.
General information on data storage and deletion
We delete personal data that we process in accordance with the law as soon as the underlying consent is revoked or there are no further legal bases for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. 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 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 notice contains additional information on the retention and deletion of data that specifically applies to certain processing processes.
If there is multiple information about the retention period or deletion period for a date, the longest period always applies.
If a deadline does not explicitly begin on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the deadline occurred. In the case of ongoing contractual relationships in which data is stored, the event that triggers the deadline is the time when the termination or other termination of the legal relationship comes into effect.
We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons only for the reasons that justify its storage.
Further information on processing processes, procedures and services:
- Storage and deletion of data: The following general deadlines apply to storage and archiving according to German law:
- 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents required for their understanding (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 AO, Section 14b Paragraph 1 UStG, Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 HGB).
- 8 years – accounting documents, such as B. Invoices and cost receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 Sentence 1 AO and Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 HGB).
- 6 years – Other business documents: commercial or business letters received, reproductions of the commercial or business letters sent, other documents insofar as they are important for taxation, e.g. B. hourly wage slips, company accounting sheets, calculation documents, price labels, but also payroll documents, provided they are not already accounting documents and cash register slips (Section 147 Paragraph 1 Nos. 2, 3, 5 in conjunction with Paragraph 3 AO, Section 257 Paragraph 1 Nos. 2 and 3 in conjunction with Paragraph 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 inquiries, based on previous business experience and usual industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
- Retention and deletion of data: The following general deadlines apply for retention and archiving in accordance with Austrian law:
- 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Federal Tax Code (BAO §132), Corporate Code (UGB §§190-212)).
- 6 years – Other business documents: Commercial or business letters received, copies of commercial or business letters sent and other documents if relevant for tax. These include, for example, hourly wage tickets, company accounting sheets, calculation documents, price labels and payroll documents, provided they are not already accounting documents and cash register slips (Federal Tax Code (BAO §132), Corporate Code (UGB §§190-212)).
- 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and usual industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).
- Retention and deletion of data: The following general deadlines apply to retention and archiving under Swiss law:
- 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (OR)).
- 10 years – Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as to deal with related requests, based on previous business experience and usual industry practices, will be stored for the period of the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Article 127, 130 OR). At the end of five years, claims for rent, lease and capital interest as well as other periodic services, from the delivery of food, for meals and for debts to landlords, as well as from craft work, small sales of goods, medical care, professional work by lawyers, legal agents, procurators and notaries and from the employment relationship of employees (Article 128 OR).
Rights of the data subjects
Rights of the data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.
- Right to revoke consent:You have the right to revoke your consent at any time.
- Right to information:You have the right to request confirmation as to whether the data in question is being processed and to request 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 legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.
- Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to request a restriction of the processing of the data in accordance with the legal requirements.
- Right to data portability:You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another person responsible.
- Complaint to a supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your place of work or the place of the alleged violation, if you believe that the processing of your personal data violates the GDPR.
Rights of the data subjects according to the Swiss Data Protection Act:
As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to exercise your rights under this law and to ensure transparent data processing.
- Right to data release or transfer: You have the right to request that the personal data you have provided to us be released in a common electronic format.
- Right to rectification:You have the right to request the correction of inaccurate personal data concerning you.
- Right to objection, deletion and destruction: You have the right to object to the processing of your data and to request that the personal data relating to you be deleted or destroyed.
Business Services
We process data from our contractual and business partners, e.g. B. 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-contractual), for example 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 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 the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse and jeopardy of their data, secrets, information and rights (e.g. 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 scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, such as for marketing purposes, in the context of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. B. in online forms, through special markings (e.g. colors) or symbols (e.g. asterisks, etc.), or in person.
We delete the data after statutory warranty and comparable obligations have expired, i.e. h. generally after four years, unless the data is stored in a customer account, e.g. B. as long as they must be kept for legal archiving reasons (e.g. for tax purposes, usually ten years). We delete data that was disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact information (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 length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons: Beneficiaries and clients; interested parties; Business and contractual partners. Education and course participants.
- Purposes of processing:Provision of contractual services and fulfillment of contractual obligations; Communication; office and organizational procedures; organizational and administrative procedures; Business processes and business procedures. Conversion measurement (measuring the effectiveness of marketing measures).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Agency services: We process our customers’ data as part of our contractual services, which include, for example: B. 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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
- Education and training services: We process the data of participants in our education and training offers (uniformly referred to as “trainees and advanced trainees”) in order to be able to provide them with our training services. The data processed here, the type, scope, purpose and necessity of their processing are determined by the underlying contract and training relationship. The forms of processing also include performance assessment and the evaluation of our performance and that of the teachers. As part of our activities, we can also process special categories of data, in particular information on the health of trainees and further trainees as well as data revealing ethnic origin, political opinions, religious or ideological beliefs. For this purpose, if necessary, we obtain the express consent of the trainees and further trainees and otherwise only process the special categories of data if it is necessary to provide the training services, for the purposes of health care, social protection or to protect the vital interests of the trainees and further trainees; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
- Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (collectively referred to as “clients”) in order to be able to provide our services to them. The procedures carried out as part of and for the purposes of coaching include: contacting and communicating with clients, needs analysis to determine appropriate coaching measures, planning and conducting coaching sessions, documentation of coaching progress, collection and management of client-specific information and data, scheduling and organization of appointments, provision of coaching materials and resources, billing and payment management, follow-up and follow-up of coaching sessions, quality assurance and Feedback processes.
The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
If it is necessary for the fulfillment of our contract, to protect vital interests or by law, or if the client has given their consent, we disclose or transmit the client’s data to third parties or agents, such as: B. Authorities, billing offices and in the area of IT, office or comparable services; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR). - Consulting: We process the data of our clients as well as interested parties and other clients or contractual partners (collectively referred to as “clients”) in order to be able to provide our services to them. The procedures that are part of and for the purposes of consulting include: contacting and communicating with clients, carrying out needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, collecting and managing client-specific information and data, scheduling and organizing appointments, providing consulting resources and materials, billing and payment management, follow-up and follow-up of consulting projects, quality assurance and feedback processes. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
If it is necessary for the fulfillment of our contract, to protect vital interests or by law, or if the client has given their consent, we disclose or transmit the client’s data to third parties or agents, such as: B. Authorities, subcontractors or in the area of IT, office or comparable services; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR). - Data analysis: We process the data of our customers and clients in order to provide them with data analysis, evaluation and consulting as well as related services. The required information includes the information required for analysis, evaluation and billing as well as contact information for necessary coordination. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Marketing and advertising: We process the data of our customers and clients (hereinafter referred to as “customers”) in order to offer marketing services such as market research, advertising campaigns, content creation and social media management. The required information is marked as such when placing the order and includes the information required for service provision and billing as well as contact information in order to be able to hold any consultations. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements.
Procedures required as part of marketing and advertising activities include creating marketing strategies and campaigns, designing advertising materials and content, selecting advertising channels and platforms, conducting market analyzes and target group surveys, and measuring and analyzing the success of marketing activities. In addition, they include the management and maintenance of customer and prospect data, the segmentation of target groups, the sending of newsletters and promotional emails, the tracking of online marketing activities and the collaboration with external service providers in the area of marketing and advertising.
These procedures serve to develop effective marketing strategies for our customers, to design advertising measures tailored to target groups, to measure and analyze the success of marketing activities and to ensure efficient management of customer contacts and information; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). - IT services: We process the data of our customers and clients to enable them to plan, implement and support IT solutions and related services. The required information is marked as such within the framework of the conclusion of the order, project or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements.
The processing processes include, among other things, project management and documentation, which include all phases from the initial requirements analysis to the completion of the project. This includes creating and managing project schedules, budgets and resource allocations. Data processing also supports change management, where changes in the project process are documented and tracked to ensure compliance and transparency.
Another process is customer relationship management (CRM), which involves recording and analyzing customer interactions and feedback to improve service quality and efficiently address individual customer needs. In addition, the processing process includes technical support and troubleshooting, which includes recording and processing support requests, troubleshooting and regular maintenance.
Reporting and performance analysis are also carried out, whereby key performance indicators are recorded and evaluated in order to evaluate and continuously optimize the effectiveness of the IT solutions provided. All of these processes are aimed at ensuring high customer satisfaction and compliance with all relevant requirements; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). - Online courses and online training courses: We process the data of participants in our online courses and online training courses (collectively referred to as “participants”) in order to be able to provide them with our course and training services. The data processed here, the type, scope, purpose and necessity of their processing are determined by the underlying contractual relationship. The data generally includes information about the courses taken and services and, where part of our range of services, personal specifications and results of the participants. The forms of processing also include performance assessment and the evaluation of our services as well as those of the course and training instructors. In addition, depending on the equipment and structure of the respective courses or learning content, further processing processes can be implemented, such as attendance tracking to document participation, progress monitoring to measure and analyze learning progress by collecting examination and test results, and the analysis of interactions in learning platforms, such as forum posts and task submissions; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
- Project and development services: We process the data of our customers and clients (hereinafter referred to as “customers”) in order to enable them to select, acquire or commission the selected services or works as well as associated activities as well as to pay for them and make them available or to execute or provide them.
The required information is marked as such within the framework of the conclusion of the order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR). - Management consulting: We process the data of our customers, clients, interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.
If it is necessary for the fulfillment of our contract or by law, or if the customer has given their consent, we disclose or transmit the customer’s data to third parties or agents, such as: B. Authorities, courts or in the area of IT, office or comparable services; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR). - Brokerage services: We process the information provided by interested parties as part of the brokerage request for the purposes of establishing, implementing and, if necessary, terminating a contract to broker offers from providers of the products or services you have requested.
We use the contact details of interested parties to specify their request using the agreed or otherwise permitted communication channel (e.g. telephone or email) and to suggest suitable providers or offers based on the specified request. In addition, we can ask interested parties questions about the success of our brokerage service at a later date, in accordance with legal requirements.
We process the data of interested parties and providers in order to fulfill our contractual obligations, in order to link the request submitted to us by interested parties with the relevant offers from the providers and forward them to the appropriate providers or suggest the providers.
We can log the entries in the online form sent by interested parties in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with the legal accountability requirements (Art. 5 Para. 2 GDPR). This information will be stored for a period of three to four years in case we need to provide evidence of the original request (e.g. to prove the right to contact the interested parties); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
Business processes and procedures
Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business 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 fulfill contractual obligations and to design operational processes efficiently. This includes processing business transactions, managing customer relationships, optimizing sales strategies and ensuring internal billing and financial processes. In addition, the data supports the protection of the rights of the person responsible and promotes administrative tasks and the organization of the company.
Personal data may be passed on to third parties if this is necessary to fulfill the stated purposes or legal obligations. After statutory retention periods have expired or if the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for a longer period of time due to tax and legal documentation requirements.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); Contract data (e.g. subject matter of the contract, term, customer category); 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, times, identification numbers, people involved); Protocol data (e.g. log files regarding logins or the retrieval of data or access times). Creditworthiness data (e.g. credit score obtained, estimated probability of default, risk classification based on this, historical payment behavior).
- Affected persons: Beneficiaries and clients; interested parties; communication partner; business and contractual partners; third parties; Users (e.g. website visitors, users of online services); Employees (e.g. employees, applicants, temporary workers and other employees). Customers.
- Purposes of processing:Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and business procedures; Communication; Marketing; sales promotion; public relations; Assessment of creditworthiness and creditworthiness; Financial and payment management. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
Further information on processing processes, procedures and services:
- Customer management and customer relationship management (CRM): Procedures that are required as part of customer management and customer relationship management (CRM) (e.g. customer acquisition in compliance with data protection regulations, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, CRM system management, secure account management, customer segmentation and targeting); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Contact management and contact maintenance: Procedures required in the context of organizing, maintaining and securing contact information (e.g. establishing 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, regular review of communication history and adjustment of contact strategies); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- General payment transactions: Procedures required when carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, processing direct debits, checking account statements, monitoring incoming and outgoing payments, direct debit management, account reconciliation, cash management); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures that are necessary for the recording, processing and control of business transactions in the area of accounts payable and accounts receivable (e.g. creation and checking of incoming and outgoing invoices, monitoring and managing open items, carrying out payment transactions, handling dunning, account reconciliation in the context of receivables and Payables, Accounts Payable and Accounts Receivable); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Financial accounting and taxes: Procedures that are necessary for the recording, management and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning processes, account reconciliation, tax advice, preparation and submission tax returns, tax processing); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Marketing, advertising and sales promotion: Procedures that are required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of the marketing activities, budget management and cost control); Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Economic analyzes and market research: In order to fulfill business purposes and to identify market trends, wishes of contractual partners and users, the existing data on business transactions, contracts, inquiries, etc. are analyzed. The group of data subjects may include contractual partners, interested parties, customers, visitors and users of the controller’s online offering. The analyzes are carried out for the purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, profiles of registered users are taken into account, including information about the services they use. The analyzes serve exclusively the person responsible and are not disclosed externally, unless they are anonymous analyzes with summarized, i.e. anonymized, values. In addition, the privacy of the users is taken into account; the data will be pseudonymized as far as possible for analysis purposes and, where feasible, processed anonymously (e.g. as aggregated data); Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Public relations: Procedures required in the context of public relations and 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, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Providers and services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short) in compliance with legal requirements. Their use is based on our interests in the proper, legal and economic management of our business operations and our internal organization.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
- Affected persons: Beneficiaries and clients; interested parties. Business and contractual partners.
- Purposes of processing:Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures. Business processes and business procedures.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Credit check
If we make advance payments or take comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and credit information from specialized service companies (credit agencies) in order to protect our legitimate interests in order to assess the credit risk based on mathematical-statistical procedures.
We process the information received from the credit reporting agencies about the statistical probability of payment default as part of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.
The decision as to whether we make advance payment is made in accordance with the legal requirements solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information from the credit reporting agency.
If we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is the consent. If consent is not obtained, the credit rating information will be provided on the basis of our legitimate interests in the reliability of our payment claims.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact information (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category); Creditworthiness data (e.g. credit score obtained, estimated probability of default, risk classification based on this, historical payment behavior). 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).
- Affected persons: Beneficiaries and clients; interested parties. Business and contractual partners.
- Purposes of processing: Assessment of creditworthiness and creditworthiness.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Automated decisions in individual cases: Credit report (decision based on a credit check).
Further information on processing processes, procedures and services:
- CRIF GmbH (Austria): credit agency; Service provider: CRIF GmbH, Diefenbachgasse 35 A, 1150 Vienna, Austria; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.crif.at/; Data protection declaration: https://www.crif.at/datenschutzerklaerung-website. Basic basis for third country transfers: Switzerland – adequacy decision (Austria).
- KSV1870 – Credit Protection Association from 1870: credit reporting agency; Service provider: KSV1870 Holding AG, Wagenseilgasse 7, A-1120 Vienna, Austria; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.ksv.at/; Data protection declaration: https://www.ksv.at/datenschutzerklaerung. Basic basis for third country transfers: Switzerland – adequacy decision (Austria).
- Association of associations Creditreform e.V.: credit agency; Service provider: Association of Associations Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.creditreform.de/; Data protection declaration: https://www.creditreform.de/datenschutz. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
Provision of the online offering and web hosting
We process users’ data in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.
- Types of data processed:Usage data (e.g. page views and 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, times, identification numbers, people involved); Protocol data (e.g. log files regarding logins or the retrieval of data or access times). Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation).
- Affected persons: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 devices (computers, servers, etc.)); Security measures. Content Delivery Network (CDN).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Provision of online offerings on rented storage space: To provide our online offerings, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. 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”. The server log files may include the address and name of the websites and files accessed, date and time of access, amount of data transferred, notification of successful retrieval, 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. B. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- E-mail sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information regarding 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 SPAM detection purposes. We ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and receipt on our server; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service that can be used to deliver the content of an online offering, particularly large media files such as graphics or program scripts, more quickly and securely using regionally distributed servers connected via the Internet; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- SiteGround: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service Providers: Siteground.com, SiteGround Hosting EOOD, 6 Olimpiyska Str., 1166, Sofia, Bulgaria; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://de.siteground.com; Privacy policy: https://de.siteground.com/privacy.htm; Order processing agreement: https://www.siteground.com/blog/siteground-is-gdpr-compliant/. Basic basis for third country transfers: Switzerland – adequacy decision (Bulgaria).
- Cloudways: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service Providers: Cloudways, Junction Business Centre, 1st Floor Sqaq Lourdes, St Julians STJ3334, Malta; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.cloudways.com/de/; Privacy Policy: https://www.cloudways.com/en/terms.php#privacy. Basic basis for third country transfers: Switzerland – adequacy decision (Malta).
- WordPress.com: Hosting and software for creating, providing and operating websites, blogs and other online offerings; Service Provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/; Order processing agreement: https://wordpress.com/support/data-processing-agreements/. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Cloudflare: Content Delivery Network (CDN) – Service with which the content of an online offering, especially large media files, such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.cloudflare.com; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Order processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Base on third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
Use of cookies
The term “cookies” refers to functions that store and read information from users’ end devices. Cookies can also be used for various purposes, such as the functionality, security and convenience of online offerings and the creation of analyzes of visitor flows. We use cookies in accordance with legal regulations. If necessary, we obtain the users’ consent in advance. If consent is not necessary, we rely on our legitimate interests. This applies if storing and reading information is essential in order to be able to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.
Notes on data protection legal bases: Whether we process personal data using 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 relevant services and procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also: session or session cookies):Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
- Permanent cookies:Permanent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. as part of obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and can also declare an objection to the processing in accordance with the legal requirements, including using the privacy settings of their browser.
- Types of data processed: Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved).
- Affected persons:Users (e.g. website visitors, users of online services).
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
- Processing of cookie data based on consent: We use a consent management solution in which users’ consent to the use of cookies or to the procedures and providers mentioned as part of the consent management solution is obtained. This procedure is used to obtain, record, manage and revoke consent, particularly 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’ consents are obtained for the use of cookies and the related processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option to manage and revoke 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. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If there is no specific information about the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the device used; Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- Cookiebot: Consent management: Procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing; Service Provider: Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/de; Privacy policy: https://www.cookiebot.com/de/privacy-policy/; Order processing agreement: Provided by the service provider; More information: Data stored (on the service provider’s server): The user’s IP number in anonymized form (the last three digits are set to 0), date and time of consent, browser details, the URL from which the consent was sent, an anonymous, random and encrypted key value. the user’s consent status.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved).
- Affected persons:Users (e.g. website visitors, users of online services).
- Purposes of processing:Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Contact and inquiry management
When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent that this is necessary to answer the contact requests and any requested measures.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved).
- Affected people:Communication partner.
- Purposes of processing: Communication; organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Contact form: When you contact us via our contact form, by email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information and, if necessary, other information that is provided to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- HubSpot CRM: Customer contact management, sales activity tracking, marketing campaign automation, sales data analysis, email campaign creation and management, integration with other tools and platforms, customer support request management, AI-powered content generation, personalized email creation, predictive sales forecasting, automated 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 fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.hubspot.de/pa/crm; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing contract: https://legal.hubspot.com/dpa. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.
You can also contact us in alternative ways, e.g. B. via telephone or email. Please use the contact options provided to you or the contact options provided within our online offering.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted 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 activated to ensure that the message content is encrypted.
However, we also point out to our communication partners that the messenger providers cannot view the content, but can find out that and when communication partners communicate with us as well as technical information about the device used by the communication partner and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes 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 your consent and you do so, for example. For example, if you contact us on your own initiative, we use Messenger in relation to our contractual partners and as part of the 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 in meeting the needs of our communication partner in communicating via Messenger. We would also like to point out that we will not transmit the contact details provided to us to Messenger for the first time 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 information from the communication partner, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
Reserve the reference to other communication channels: In order to ensure your security, we ask for your understanding that for certain reasons we may not be able to answer inquiries via messenger. This applies to situations in which contract details must be treated particularly confidentially or in which a response via messenger does not meet the formal requirements. In these 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. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved).
- Affected people:Communication partner.
- Purposes of processing: Communication. Direct marketing (e.g. by email or post).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Instagram: Sending messages via the social network Instagram; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basic basis for third country transfers: Switzerland – adequacy decision (Ireland).
- Facebook Messenger: Send and receive text messages, make voice and video calls, create group chats, share files and media, transmit location information, sync contacts, encrypt messages; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Microsoft Teams: Chat, audio and video conferencing, file sharing, integration with Office 365 applications, real-time document collaboration, calendar functions, task management, screen sharing, optional recording; Service Providers: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Signal: Signal Messenger with end-to-end encryption; Service Provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite 120-223 Mountain View, CA 94041, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://signal.org/de/. Privacy policy: https://signal.org/legal/.
- Skype: Video calling, voice calling, instant messaging, file sharing, screen sharing, voicemail, call forwarding and integration with other Microsoft services. – Skype end-to-end encryption requires it to be enabled (unless it is enabled by default); Service Providers: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.skype.com/de/; Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Slack: Team communication and collaboration, real-time messaging, file and document sharing, integration with third-party tools, video and voice calling, topic-specific discussion channels, message and file search; Service provider: Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://slack.com/intl/de-de/; Privacy policy: https://slack.com/intl/de-de/legal; Order processing agreement: https://slack.com/intl/de-de/terms-of-service/data-processing; Basic for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). More information: Security measures: https://slack.com/intl/de-de/security-practices.
- WhatsApp: Text messages, voice and video calls, sending pictures, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Chatbots and chat functions
We offer online chats and chatbot functions (collectively referred to as “Chat Services”) as a means of communication. A chat is an online conversation that takes place with a certain degree of timeliness. A chatbot is software that answers users’ questions or informs them about messages. If you use our chat functions, we may process your personal data.
If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. We also store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.
We would like to point out to users that the respective platform provider can find out that and when users communicate with our chat services and can collect technical information about the device used by the user and, depending on the settings of their device, location information (so-called metadata) for the purpose of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e., for example, the information about who communicated with whom) could be used by the respective platform providers in accordance with their regulations, to which we refer for further information, for marketing purposes or to display advertising tailored to users.
If users agree to activate information with regular messages from a chatbot, they have the option to unsubscribe from receiving information in the future at any time. The chatbot tells users how and with which terms they can unsubscribe from the messages. When you unsubscribe from chatbot messages, user data is deleted from the list of message recipients.
We use the above information to operate our chat services, e.g. B. to personally address users to answer their queries, to deliver any requested content and also to improve our chat services (e.g. to “teach” chatbots answers to frequently asked questions or to detect unanswered queries).
Notes on legal bases: We use the chat services on the basis of consent if we have previously obtained users’ permission to process their data as part of our chat services (this applies to cases in which users are asked for consent, for example so that a chatbot can send them regular messages). If we use chat services to answer user inquiries about our services or our company, this is for contractual and pre-contractual communication. Furthermore, we use chat services based on our legitimate interests in optimizing the chat services, their business efficiency and increasing the positive user experience.
Revocation, objection and deletion: You can revoke your consent at any time or object to the processing of your data as part of our chat services.
- Types of data processed:Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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); Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contract data (e.g. subject matter of the contract, term, customer category). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved).
- Affected people:Communication partner; Users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Communication; Provision of contractual services and fulfillment of contractual obligations; Marketing. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- HubSpot chatbot software: Automating customer interactions, answering common questions, scheduling appointments, routing to human agents, integrating with CRM systems for data storage and management, customizing conversations based on user behavior and preferences; Service Provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central Guild Street, Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.hubspot.de/products/crm/chatbot-builder; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing contract: https://legal.hubspot.com/dpa. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Push notifications
With the users’ consent, we can send users so-called “push notifications”. These are messages that are displayed on users’ screens, devices or browsers, even if our online service is not being actively used.
In order to register for push notifications, users must confirm that their browser or device asks them to receive push notifications. This consent process is documented and saved. Storage is necessary to determine whether users have agreed to receive push notifications and to be able to prove their consent. For these purposes, a pseudonymous browser identifier (so-called “push token”) or the device ID of a terminal device is stored.
The push messages may be necessary for the fulfillment of contractual obligations (e.g. technical and organizational information relevant to the use of our online offering) and are otherwise sent on the basis of the user’s consent, unless specifically mentioned below. Users can change the receipt of push notifications at any time using the notification settings of their respective browsers or devices.
- 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, times, identification numbers, people involved). Location data (information about the geographical position of a device or person).
- Affected people:Communication partner.
- Purposes of processing: Communication; Provision of our online offering and user-friendliness; Reach measurement (e.g. access statistics, recognition of returning visitors). Direct marketing (e.g. by email or post).
- Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Deletion after termination.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Push notifications with promotional content: The push notifications we send may contain promotional information. The advertising push messages are processed based on the consent of the users. If their content is specifically described as part of consent to receive advertising push messages, the descriptions are decisive for the user’s consent. Furthermore, our newsletters contain information about our services and us; Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- Location-dependent delivery of push notifications: The push notifications we send can be displayed depending on the user’s location based on the location data transmitted by the device used; Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- Analysis and measurement of success: We evaluate push messages statistically and can thus recognize whether and when push messages were displayed and clicked on. This information is used to technically improve our push messages based on the technical data or the target groups and their retrieval behavior or retrieval times. This analysis also includes determining whether the push messages are opened, when they are opened and whether users interact with their content or buttons. For technical reasons, this information can be assigned to the individual push message recipients. However, it is neither our intention nor, if used, that of the push notification service provider to monitor individual users. Rather, the evaluations serve us to recognize the usage habits of our users and to adapt our push messages to them or to send different push messages according to the interests of our users.
The evaluation of the push messages and the measurement of success are carried out on the basis of the express consent of the user, which occurs with the consent to receive the push messages. Users can object to the analysis and performance measurement by unsubscribing from push notifications. Unfortunately, a separate revocation of the analysis and performance measurement is not possible; Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
Artificial Intelligence (AI)
We use artificial intelligence (AI) to process personal data. The specific purposes and our interest in using AI are mentioned below. By AI, we understand, in accordance with the concept of an “AI system” as defined in Article 3 No. 1 of the AI Regulation, a machine-based system that is designed to operate to a varying extent autonomously, can be adaptable once introduced and, from the inputs received, produces results such as predictions, content, recommendations or decisions that can influence physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In doing so, we particularly adhere to the principles of legality, transparency, fairness, human control, purpose limitation, data minimization and integrity as well as confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can either be the consent of the data subjects or a legal permission.
When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that AI providers comply with applicable regulations. We also observe the obligations incumbent on us when using or operating the purchased AI services. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or legal authorization. We place particular emphasis on transparency, fairness and maintaining human control over AI-supported decision-making processes.
To protect the data processed, we implement appropriate and robust technical and organizational measures. These ensure the integrity and confidentiality of the data processed and minimize potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
- Types of data processed:Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). 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).
- Affected persons:Users (e.g. website visitors, users of online services). Third parties.
- Purposes of processing:Artificial intelligence (AI).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Adobe AI: AI-powered tools and features in Adobe products that support creative processes. Adobe AI offers features such as automatic image editing, content generation and intelligent image adjustments to optimize creative workflow; Service Provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.adobe.com/de/sensei.html; Privacy policy: https://www.adobe.com/de/privacy.html; Order processing agreement: Provided by the service provider. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- ChatGPT: AI-based service designed to understand and generate natural language and associated inputs and data, analyze information and make predictions (“AI”, i.e. “Artificial Intelligence”, is to be understood in the applicable legal sense of the term); Service Provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://openai.com/product; Privacy policy: https://openai.com/de/policies/eu-privacy-policy; Basic basis for third country transfers: Switzerland – adequacy decision (Ireland). Opt-out option: https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
- DALL-E: Creating images from text descriptions, adapting and editing existing images based on text instructions, generating variations of an image, supporting creative projects through visual content; Service provider: OpenAI, 3180 18th St, San Francisco, CA 94110, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://openai.com/product; Privacy Policy: https://openai.com/policies/privacy-policy. Opt-out option: https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
- DeepL: Translating texts into different languages and providing synonyms and contextual examples. Support in correcting and improving texts in different languages; Service provider: DeepL SE, Maarweg 165, 50825 Cologne, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.deepl.com; Privacy policy: https://www.deepl.com/de/privacy; Order processing agreement: Provided by the service provider. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- Fireflies.ai: Fireflies.ai is an AI-powered conversation recording and analysis assistant that enables users to automatically record, transcribe meetings, and extract key insights. The platform makes it easy to track and manage meetings; Service Provider: Fireflies.ai, 5424 Sunol Blvd, Ste 10-531, Pleasanton, CA 94566, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.fireflies.ai. Privacy policy: https://fireflies.ai/privacy_policy.pdf.
- Google Gemini: AI-powered system designed to provide advanced voice and image processing capabilities. It uses machine learning to understand and generate natural language and analyze images, offering versatile applications in various areas; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/processorterms/?hl=de. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Lumen5: Creating videos from text content, automatically summarizing articles into video clips, adding music and visual effects; Service Provider: Lumen5 Technologies Ltd, 1100-1200 W 73rd Ave, Vancouver, BC V6P 6G5, Canada; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://lumen5.com/; Privacy policy: https://lumen5.com/privacy/. Basic basis for third country transfers: EU/EEA – adequacy decision (Canada), Switzerland – adequacy decision (Canada).
- Microsoft Copilot: Enables the creation and editing of texts, tables and presentations. Provides assistance in analyzing data, automating tasks, and integrating with various Microsoft Office applications. Leverages machine learning to improve workflows and provide contextual suggestions; Service Providers: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-copilot/organizations; Privacy policy: https://www.microsoft.com/de-de/privacy/privacystatement; Order processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Midjourney: Creating AI-generated images based on text input, customizing and refining the generated images through iterative input, storing and managing created content, providing an online platform to interact with other users and share results; Service Provider: Midjourney, Inc., 795 Folsom Street, 1st Floor, San Francisco, CA 94107 USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.midjourney.com/. Privacy policy: https://docs.midjourney.com/docs/privacy-policy.
- nele.ai: Software that enables the integration of AI models and the creation of AI content using API access to AI-based services in various use cases. User input is not forwarded directly to the AI providers, but is saved on EU servers. Using a data protection filter, it is also possible to anonymize these. Users’ communication histories are secured in the EU, on nele.ai’s servers. Depending on the functions selected by the user and provided by the provider, the use of AI functions is regulated in such a way that user input may neither be stored by the AI providers nor used for learning purposes; Service provider: GAL Digital GmbH, Unter den Linden 26, 35410 Hungen, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.nele.ai/; Privacy policy: https://www.nele.ai/de/datenschutz; Order processing agreement: Provided by the service provider. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- OpenAI API: An AI API that gives developers access to a variety of powerful language and image models, including GPT-4 and DALL-E. The OpenAI API makes it possible to integrate complex tasks such as text generation, language processing and image analysis into applications; Service Provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://openai.com/product; Privacy policy: https://openai.com/de/policies/eu-privacy-policy; Order processing agreement: https://openai.com/policies/data-processing-addendum; Basic third country transfers: EU/EEA – Standard contractual clauses (https://openai.com/policies/data-processing-addendum), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
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”). When selecting conference platforms and their services, we observe the legal requirements.
Data processed by conference platforms: As part of participation in a conference, the conference platforms process the participants’ personal data mentioned below. The scope of processing depends, on the one hand, on what data is required as part of a specific conference (e.g. providing access data or real names) and what optional information is provided by the participants. In addition to processing to carry out the conference, the participants’ data can also be processed by the conference platforms for security purposes or service optimization. The data processed includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information about professional status/function, the IP address of the Internet access, information about the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information about the content of communication processes, i.e. h. Entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference provider. If the participants are registered as users on the conference platforms, then further data can be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent – if necessary.
Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms in their data protection information and select the security and data protection settings that are optimal for you within the framework of the settings of the conference platforms. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and using, where technically possible, the function to obscure the background). Links to the conference rooms and access data may not be passed on to unauthorized third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask the users for their consent to the use of the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, etc.). Furthermore, 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, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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); Image and/or video recordings (e.g. photographs or video recordings of a person); Sound recordings. Protocol data (e.g. log files regarding logins or the retrieval of data or access times.).
- Affected people:Communication partner; Users (e.g. website visitors, users of online services). People shown.
- Purposes of processing:Provision of contractual services and fulfillment of contractual obligations; Communication. Office and organizational procedures.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Discord: Chat, audio and video broadcasts, instant messaging and community management; Service provider: Discord, Inc., 444 De Haro St, Suite 200, San Francisco, California 94107, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://discord.com/; Privacy policy: https://discord.com/privacy. Base on third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- Google Hangouts / Meet: Konferenz- und Kommunikationssoftware; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://hangouts.google.com/; Datenschutzerklärung: https://policies.google.com/privacy; Auftragsverarbeitungsvertrag: https://cloud.google.com/terms/data-processing-addendum. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Angemessenheitsbeschluss (Irland).
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time document collaboration, calendar features, task management, screen sharing, optional recording; Service Providers: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Skype: Messenger- und Konferenz-Software; Dienstanbieter: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Irland; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.skype.com/de/; Datenschutzerklärung: https://privacy.microsoft.com/de-de/privacystatement, Sicherheitshinweise: https://www.microsoft.com/de-de/trustcenter. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Angemessenheitsbeschluss (Irland).
- Slack: Messenger- und Konferenz-Software; Dienstanbieter: Slack Technologies Limited, Level 1, Block A Nova Atria North, Sandyford Business District, Dublin 18, Irland; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://slack.com/intl/de-de/; Datenschutzerklärung: https://slack.com/intl/de-de/legal; Auftragsverarbeitungsvertrag: https://slack.com/intl/de-de/terms-of-service/data-processing. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Angemessenheitsbeschluss (Irland).
- TeamViewer: Conferencing and communication software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.teamviewer.com/de/; Privacy policy: https://www.teamviewer.com/de/legal/privacy-and-cookies/. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- Zoom: Video conferencing, online meetings, webinars, screen sharing, optional session recording, chat function, integration with calendars and other apps; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://zoom.us; Privacy policy: https://explore.zoom.us/de/privacy/; Order processing agreement: https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf. Base on third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
Cloud-Dienste
We use software services accessible via the Internet and running on their providers’ servers (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, exchanging documents, content and information with specific recipients or publishing content and information).
In this context, personal data can be processed and stored on the providers’ servers, provided that they are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. This data may include, in particular, user master data and contact details, data on processes, contracts, other processes and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.
If we provide forms or other documents and content to other users or publicly accessible websites using the cloud services, the providers may store cookies on the users’ devices for the purposes of web analysis or to remember the user’s settings (e.g. in the case of media control).
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). 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).
- Affected people:Interested parties; communication partner; Business and contractual partners. Users (e.g. website visitors, users of online services).
- Purposes of processing:Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Dropbox: Cloud-Speicher-Dienst; Dienstanbieter: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.dropbox.com/de; Datenschutzerklärung: https://www.dropbox.com/privacy; Auftragsverarbeitungsvertrag: https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Data Privacy Framework (DPF).
- Google Cloud-Dienste: Cloudinfrastrukturdienste und cloudbasierte Anwendungssoftware; Dienstanbieter: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Irland; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://cloud.google.com/; Datenschutzerklärung: https://policies.google.com/privacy; Auftragsverarbeitungsvertrag: https://cloud.google.com/terms/data-processing-addendum; Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Angemessenheitsbeschluss (Irland). Weitere Informationen: https://cloud.google.com/privacy.
- Google Cloud Storage: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). More information: https://cloud.google.com/privacy.
- Google Workspace: Cloud-based application software (e.g. text and spreadsheet editing, appointment and contact management), cloud storage and cloud infrastructure services; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://workspace.google.com/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). More information: https://cloud.google.com/privacy.
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services and cloud-based application software; Service Providers: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://microsoft.com/de-de; Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter; Order processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Newsletters and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipient or on the basis of a legal basis. If the content is mentioned when registering for the newsletter, this content is decisive for the user’s consent. To register for our newsletter, it is usually sufficient to provide your email address. However, in order to be able to offer you a personalized service, we may ask you to provide your name for a personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove that we have previously given consent. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called “blocklist”) solely for this purpose.
The registration process is recorded on the basis of our legitimate interests for the purpose of providing evidence of its proper execution. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved); 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). Event data (Facebook) (“Event data” is information that is sent, for example, via meta pixels (be it via apps or other channels) to the provider Meta and relates to people or their actions. This data includes details about website visits, interactions with content and functions, app installations and product purchases. The event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event data does not include actual content such as written comments, no login information and no contact information such as names, email addresses or telephone numbers. “Event data” will be deleted by Meta after a maximum of two years, and the target groups formed from it will disappear when our Meta user accounts are deleted.).
- Affected people:Communication partner; service recipients and clients; interested parties. Users (e.g. website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g. by email or post); Reach measurement (e.g. access statistics, recognition of returning visitors); Conversion measurement (measuring the effectiveness of marketing measures); click tracking; Marketing; Profiles with user-related information (creating user profiles); Communication. Provision of contractual services and fulfillment of contractual obligations.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Opt-out option: You can cancel your receipt of our newsletter at any time, i.e. .h. Revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further information on processing processes, procedures and services:
- Measuring opening and click rates: The newsletters contain a so-called “web beacons”, i.e. h. a pixel-sized file that is retrieved from our server or its server if we use a shipping service provider when the newsletter is opened. As part of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until deleted. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent. Unfortunately, it is not possible to revoke the success measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the saved profile information will be deleted; Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- Requirement for the use of free services: Consent to the sending of mailings can be made dependent on the use of free services (e.g. access to certain content or participation in certain promotions). If users would like to take advantage of the free service without registering for the newsletter, we ask you to contact us.
- Reminder emails about the ordering process: If users do not complete an ordering process, we can remind users of the ordering process by email and send them a link to continue it. This function can e.g. This can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight or forgetting. Shipping is based on consent, which users can revoke at any time; Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- Sending via SMS: The electronic notifications can also be sent as SMS text messages (or are sent exclusively via SMS if the authorization to send, e.g. consent, only includes sending via SMS); Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).
- ActiveCampaign: E-mail marketing, automation of marketing processes, survey. Storage and management of contact details, creation and management of landing pages, measurement of campaign performance, recording and analysis of recipients’ interaction with content, personalization of content; Service Provider: ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.activecampaign.com; Privacy policy: https://www.activecampaign.com/privacy-policy/. Base on third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- Clickfunnels: Email sending and automation services; Service Provider: Etison LLC, 3443 W. Bavaria Street, Eagle, Idaho 83616, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.clickfunnels.com/; Privacy Policy: https://signup.clickfunnels.com/privacy-policy; Order processing agreement: https://signup.clickfunnels.com/dpa. Basic third country transfers:EU/EEA – Standard contractual clauses (https://signup.clickfunnels.com/dpa), Switzerland – Standard Contractual Clauses (https://signup.clickfunnels.com/dpa).
- Facebook Messenger Broadcasts: Messenger with end-to-end encryption; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://www.facebook.com/adpreferences/ad_settings (Facebook login is required).
- HubSpot Email Marketing: Sending emails, creating personalized campaigns, automating workflows, segmenting audiences, integrating with CRM systems, analyzing performance through reports and dashboards; Service Provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central Guild Street, Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.hubspot.com/products/marketing/email; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing contract: https://legal.hubspot.com/dpa. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Mailchimp: E-mail marketing, automation of marketing processes, survey. Storage and management of contact details, measurement of campaign performance, collection and analysis of recipients’ interaction with content, personalization of content; Service Provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/; Order processing agreement: https://mailchimp.com/legal/; Basic for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.
- Brevo: Email sending and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/legal/privacypolicy/; Order processing agreement: Provided by the service provider. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- Zapier: Automation of processes, merging of various services, import and export of personal and contact data as well as analysis of these processes; Service Provider: Zapier, Inc., 548 Market St #62411, San Francisco, California 94104, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://zapier.com; Privacy policy: https://zapier.com/privacy; Order processing agreement: https://zapier.com/legal/data-processing-addendum. Basic third country transfers: EU/EEA – Standard contractual clauses (https://zapier.com/legal/standard-contractual-clauses), Switzerland – Standard contractual clauses (https://zapier.com/legal/standard-contractual-clauses).
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of promotional communication via various channels, such as: B. E-mail, telephone, post or fax, can be done in accordance with the legal requirements.
The recipients have the right to revoke their consent at any time or to object to the advertising communication at any time.
After revocation or objection, we store the data required to prove previous authorization for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of possible defense against claims. Based on the legitimate interest in permanently observing the user’s revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation).
- Affected people:Communication partner.
- Purposes of processing: Direct marketing (e.g. by email or post); Marketing. Sales promotion.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Sweepstakes and competitions
We only process personal data of participants in competitions and competitions in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, implementation and processing of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).
If participants’ contributions are published as part of the competition (e.g. as part of a vote or presentation of the competition entries or the winners or reporting on the competition), we would like to point out that the names of the participants can also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection regulations of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by participants as part of the competition and that inquiries regarding the competition should be directed to us.
The participants’ data will be deleted as soon as the competition or competition has ended and the data is no longer required to inform the winners or because there are no longer any questions about the competition. In principle, the participants’ data will be deleted no later than 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. B. to be able to answer questions about the prizes or fulfill the prize requirements; In this case, the retention period depends on the type of prize and is e.g. B. for things or services up to three years, for example. B. to be able to process warranty cases. Furthermore, the participants’ data can be stored for longer, e.g. B. in the form of reporting on the competition in online and offline media.
If data was also collected for other purposes as part of the competition, its processing and retention period are based on the data protection information on this use (e.g. in the case of registration for the newsletter as part of a competition).
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation).
- Affected people: competition and competition participants.
- Purposes of processing:Conducting sweepstakes and competitions.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Surveys and surveys
We carry out surveys and surveys to collect information for the communicated purpose of the survey or survey. The surveys and surveys we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the survey to be resumed using a cookie).
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). 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).
- Affected people: participants.
- Purposes of processing:Feedback (e.g. collecting feedback via online form); Surveys and questionnaires (e.g. surveys with input options, multiple choice questions); Tracking (e.g. interest/behavioral profiling, use of cookies); click tracking; A/B testing; Heatmaps (mouse movements by users that are combined to form an overall image); Profiles with user-related information (creating user profiles). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Google form: Creation and evaluation of online forms, surveys, feedback forms, etc; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.google.de/intl/de/forms; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Hotjar Ask: Software for the analysis and optimization of online offers based on feedback functions, which may in particular include feedback forms and surveys; Service Provider: Hotjar Ltd., 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.hotjar.com; Privacy Policy: https://www.hotjar.com/legal/policies/privacy; Basic basis for third country transfers: Switzerland – Adequacy Decision (Malta); Deletion of data: The cookies that Hotjar uses have a different “lifespan”; some remain valid for up to 365 days, some only during the current visit; Cookie Policy: https://www.hotjar.com/legal/policies/cookie-information. Opt-out option: https://www.hotjar.com/legal/compliance/opt-out.
- SurveyMonkey: Durchführung von Online-Umfragen; Dienstanbieter: SurveyMonkey Inc., 1 Curiosity Way, San Mateo, California 94403, USA; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://de.surveymonkey.com/; Datenschutzerklärung: https://de.surveymonkey.com/mp/policy/privacy-policy/?ut_source=footer. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Data Privacy Framework (DPF).
- Typeform: Creation of forms and surveys and management of participant contributions; Service Provider: TYPEFORM SL, Carrer Bac de Roda, 163, local, 08018 – Barcelona, Spain; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.typeform.com/; Privacy Policy: https://admin.typeform.com/to/dwk6gt/; Order processing agreement: https://admin.typeform.com/to/dwk6gt/. Basic basis for third country transfers: Switzerland – adequacy decision (Spain).
Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite them to reuse it. It is also possible for us to understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized into a usage process, can be created for these purposes and information can be stored in a browser or in a device and then read out. 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 about times of use. If users have agreed to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.
In addition, the users’ IP addresses are stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we as well as 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 third-party providers, the legal basis for data processing is consent. Otherwise, the 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 data protection declaration.
- 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, times, identification numbers, people involved).
- Affected persons:Users (e.g. website visitors, users of online services).
- Purposes of processing: Remarketing; target group formation; Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles); Provision of our online offering and user-friendliness. Conversion measurement (measuring the effectiveness of marketing measures).
- Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
- Security measures:IP masking (pseudonymization of the IP address).
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Adobe Analytics: Adobe Analytics; Dienstanbieter: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Irland; Rechtsgrundlagen: Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO); Website: https://business.adobe.com/de/products/analytics/adobe-analytics.html; Datenschutzerklärung: https://www.adobe.com/de/privacy.html. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Angemessenheitsbeschluss (Irland).
- Firebase: Google Firebase is a platform for developers of applications (“apps” for short) for mobile devices and websites. Google Firebase offers a variety of features for testing apps, monitoring their functionality, and optimizing them (which are presented on the following overview page: https://firebase.google.com/products-build). The functions include, among other things, the storage of apps including personal data of application users, such as: B. content created by you or information regarding your interaction with the apps (so-called “cloud computing”). Google Firebase also offers interfaces that allow interaction between app users and other services, e.g. B. authentication using services such as Facebook, Twitter or using an email-password combination; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://firebase.google.com; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on 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 device in order to identify which content users have accessed within one or different usage processes, which search terms they have used, which they have accessed again or which have interacted with our online offering. The time of use and its duration are also stored, as are the sources of the users who refer to our online offering and technical aspects of their devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the city’s derived latitude and longitude), 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. They are not logged, are not accessible and are not used for any other purposes. When Google Analytics collects metrics, all IP queries are performed on EU-based servers before passing traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Opt-Out Option:Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and the data processed). - Google as a recipient of consent: The consent given by users as part of a consent dialog (also known as “cookie opt-in/consent”, ‘cookie banner’, etc.) serves several purposes. On the one hand, it helps us fulfill our obligation to obtain consent to store and read information on and from the user’s device (according to ePrivacy guidelines). On the other hand, it covers the processing of users’ personal data in accordance with data protection regulations. In addition, this consent also applies to Google, as the company is obliged under the Digital Markets Act to obtain consent for personalized services. Therefore, we share the status of the consents given by users with Google. Our consent management software informs Google whether consent has been given or not. The aim is to ensure that users’ consent, whether given or not, is taken into account when using Google Analytics and when integrating functions and external services. This means that user consent and its revocation can be adjusted dynamically and depending on user selection within the framework of Google Analytics and other Google services in our online offering; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de; Privacy policy: https://policies.google.com/privacy. Basic basis for third country transfers: Switzerland – adequacy decision (Ireland).
- Google Analytics (Server-side use): We use Google Analytics to measure and analyze how users use our online services. Although user data is processed, it is not transmitted directly from the user’s device to Google. In particular, the user’s IP address is not transmitted to Google. Instead, the data is first transmitted to our server, where the user records are assigned to our internal user identification number. The subsequent transmission only takes place in this pseudonymized form from our server to Google. The identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a device in order to identify which content users have accessed within one or different usage processes, which search terms they have used, which they have accessed again or which have interacted with our online offering. The time of use and its duration are also stored, as are the sources of the users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Analytics provides higher-level geolocation data by collecting the following metadata from IP search: “City” (and the city’s derived latitude and longitude), “Continent”, “Country”, “Region”, “Subcontinent” (and the ID-based equivalents); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Further information: https://business.safety.google/adsservices/ (types of processing and the data processed).
- Google Signals (Google Analytics feature): Google signals are session data from websites and apps that Google associates with users who have logged in to their Google accounts and enabled ad personalization. This mapping of data to these logged in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion measurement. These include: Cross-platform reporting – linking data across devices and activity from different sessions using your User ID or Google Signals data, enabling an understanding of user behavior at every step of the conversion process, from initial contact to conversion and beyond; Remarketing with Google Analytics – Creating remarketing audiences from Google Analytics data and sharing those audiences with linked advertising accounts; Demographics and Interests – Google Analytics collects additional information about demographics and interests from users who are logged into their Google accounts and have ad personalization enabled; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/7532985?hl=de; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Further information: https://business.safety.google/adsservices/ (types of processing and the data processed).
- Target group creation with Google Analytics: We use Google Analytics to present advertisements that are placed via Google’s advertising services and those of its partners specifically to those users who have already shown interest in our online offering or who have certain characteristics (e.g. interests in specific topics or products, which are determined based on the websites they visit). We transmit this data to Google as part of so-called “remarketing” or “Google Analytics Audiences”. The aim of using remarketing audiences is to ensure that our advertisements match users’ potential interests as closely as possible; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Legal basis: https://business.safety.google/adsprocessorterms/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information:Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Google Tag Manager: We use Google Tag Manager, software from Google that allows us to manage so-called website tags centrally via a user interface. Tags are small pieces of code on our website that are used to record and analyze visitor activity. This technology helps us to improve our website and the content offered on it. The Google Tag Manager itself does not create user profiles, does not store cookies with user profiles and does not carry out any independent analyses. Its function is limited to simplifying and making more efficient the integration and management of tools and services that we use on our website. Nevertheless, when using the Google Tag Manager, the user’s IP address is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies can also be set. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information about these services and their data processing, we refer to the further sections of this data protection declaration; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Order processing contract:
https://business.safety.google/adsprocessorterms. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). - Google Tag Manager (server-side use): The Google Tag Manager is an application with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (see also the further information in this data protection declaration). The tag manager itself (which implements the tags) does not store user profiles or cookies. The integration of the other services takes place on the server side. This means that the user’s data is not transmitted directly from their device to the respective service or Google. In particular, the user’s IP address is not transmitted to the other service. Instead, the data is first transmitted to our server, where the user records are assigned to our internal user identification number. The subsequent transmission of the data from our server to the servers of the respective service providers only takes place in this pseudonymized form. The user identification number does not contain any unique information such as names or email addresses; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Further information: https://business.safety.google/adsservices/ (types of processing and the data processed).
- Matomo (without cookies): Matomo is a privacy-friendly web analysis software that is used without cookies and in which returning users are recognized using a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; With the “digital fingerprint” user movements within our online offering are recorded using pseudonymized IP addresses in combination with the user’s browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected when using Matomo is only processed by us and is not shared with third parties; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Website: https://matomo.org/.
- Matomo: Matomo is software that is used for web analysis and reach measurement purposes. When using Matomo, cookies are generated and stored on the user’s device. The user data collected when using Matomo is only processed by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Deletion of data: The cookies have a storage period of a maximum of 13 months.
- Piwik PRO: Reach measurement and web analysis; Service provider: Piwik PRO GmbH, Kurfürstendamm 21, 10719 Berlin, Germany; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://piwikpro.de; Data protection declaration: https://piwikpro.de/datenschutz/. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- Piwik Pro Consent Manager: Consent management: Procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing; Service provider: Execution on servers and/or computers under their own data protection responsibility; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://piwikpro.de/dsgvo-consent-manager/. Data protection declaration: https://piwikpro.de/datenschutz/.
Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and 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 processes are used, by means of which the user information relevant to the display of the aforementioned content is stored. 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 times of use and functions used. If users have consented to the collection of their location data, this can also be processed.
The users’ IP addresses are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of the online marketing process, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we as well as the providers of online marketing processes do not know the actual user identity, but only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or using similar methods. These cookies can later generally be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, supplemented with further data and stored on the server of the online marketing process provider.
Exceptionally, it is possible to assign clear data to the profiles, especially if, for example, the users are members of a social network whose online marketing processes we use and the network connects the user profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, for example by giving consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. h. for example, to conclude a contract with us. Conversion measurement is used solely to analyze the success 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 users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, the users’ data will be 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 data protection declaration.
Notes on revocation and objection:
We refer to the data protection information of the respective providers and the objection options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of turning off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas:
- a) Europa: https://www.youronlinechoices.eu.
- b) Kanada: https://www.youradchoices.ca/choices.
- c) USA: https://www.aboutads.info/choices.
- d) Gebietsübergreifend: https://optout.aboutads.info.
- Types of data processed:Content data (e.g. textual or visual messages and posts and the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved); Event data (Facebook) (“Event data” is information that is sent, for example, via meta pixels (be it via apps or other channels) to the provider Meta and relates to people or their actions. This data includes details about website visits, interactions with content and functions, app installations and product purchases. The event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event data does not include actual content such as written comments, no login information and no contact information such as names, email addresses or telephone numbers. “Event data” will be deleted by Meta after a maximum of two years, and the target groups formed from it will disappear when our Meta user accounts are deleted.); Contact information (Facebook) (“Contact information” is data that (clearly) identifies data subjects, such as names, email addresses and telephone numbers, which can be transmitted to Facebook, e.g. via Facebook pixel or upload for matching purposes to form custom audiences; after matching for the purpose of forming target groups, the contact information will be deleted). Contact details (e.g. postal and email addresses or telephone numbers).
- Affected persons:Users (e.g. website visitors, users of online services). Communication partner.
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Tracking (e.g. interest/behavioral profiling, use of cookies); Conversion measurement (measuring the effectiveness of marketing measures); target group formation; Marketing; Profiles with user-related information (creating user profiles); Provision of our online offering and user-friendliness; remarketing; Click tracking. Communication.
- Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
- Security measures:IP masking (pseudonymization of the IP address).
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Meta pixel and target group formation (Custom Audiences): With the help of the meta pixel (or comparable functions, for transmitting event data or contact information via interfaces in apps), it is possible for the Meta company to determine the visitors to our online offering as a target group for the display of advertisements (so-called “meta ads”). Accordingly, we use the Meta pixel to only show the Meta ads placed by us to users on Meta platforms and within the services of partners cooperating with Meta (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products, which are evident from the websites visited), which we transmit to Meta (so-called “Custom Audiences”). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of the users and do not appear annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a meta ad (so-called “conversion measurement”); Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); More information: User event data, i.e. .h. Behavioral and interest information is used for the purposes of targeted advertising and audience building based on the Joint Responsibility Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum) processed. The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Advanced comparison for the Meta-Pixel: In addition to the processing of event data as part of the use of the Meta-Pixel (or comparable functions, e.g. in apps), contact information (individual identifying data, such as names, email addresses and telephone numbers) is also collected by Meta within our online offering or transmitted to Meta. The processing of the contact information serves to form target groups (so-called “custom audiences”) for the display of content and advertising information based on the presumed interests of the users. The collection, transmission and comparison with data available at Meta does not take place in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, when storing passwords). After matching to create target groups, the contact information is deleted; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Privacy Policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basic for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). More information: https://www.facebook.com/legal/terms/data_security_terms.
- Meta – Target group formation via data upload: Formation of target groups for marketing purposes – We transmit contact information (names, email addresses and telephone numbers) in list form to Meta for the purpose of forming target groups (so-called “custom audiences”) for displaying content and advertising information based on the presumed interests of the users. The transmission and comparison with data available at Meta is not done in plain text, but rather as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, when storing passwords). After matching to create target groups, the contact information is deleted; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook advertisements: Placement of advertisements within the Facebook platform and evaluation of the ad results; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Ability to object (opt-out): We refer to the data protection and advertising settings in the user profile on the Facebook platforms as well as to Facebook’s consent process and contact options for exercising information and other data subject rights, as described in Facebook’s data protection declaration; More information: User event data, i.e. .h. Behavioral and interest information is used for the purposes of targeted advertising and audience building based on the Joint Responsibility Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum) processed. The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ad Manager: We use the “Google Ad Manager” service to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that ads are displayed in real time based on users’ presumed interests. This allows us to show advertisements for our online offering to users who may have a potential interest in our offering or have previously been interested in it, and to measure the success of the advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information:Types of processing and data processed: https://business.safety.google/adsservices/; Data processing conditions for Google advertising products: Information about the services Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms. if Google acts as a processor, data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Google Ads and conversion measurement: Online marketing process for the purpose of placing content and advertisements within the service provider’s advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the ads, i.e. h. whether users took them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information:Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology with which users who use an online service are included in a pseudonymous remarketing list so that users can be shown ads on other online offers based on their visit to the online service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information:Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Advanced conversions for Google Ads: When users click on our Google ads and then use the advertised service (so-called “conversion”), the data entered by the user, such as: B. the email address, name, home address or telephone number are transmitted to Google. The hash values are then compared with the users’ existing Google accounts in order to better evaluate and improve the users’ interaction with the ads (e.g. clicks or views) and thus their performance; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
- Instagram advertisements: Placement of advertisements within the Instagram platform and evaluation of the ad results; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Ability to object (opt-out): We refer to the data protection and advertising settings in the user profile on the Instagram platform as well as within the framework of Instagram’s consent process and Instagram’s contact options for exercising information and other data subject rights in Instagram’s data protection declaration; More information: User event data, i.e. .h. Behavioral and interest information is used for the purposes of targeted advertising and audience building based on the Joint Responsibility Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum) processed. The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user’s behavior and conversions and stores them in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar target groups); Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Order processing agreement: https://www.linkedin.com/legal/l/dpa; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Microsoft Advertising: Online marketing practices for the purpose of placing content and advertisements within the service provider’s advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the ads, i.e. h. whether the users took them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service Providers: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://about.ads.microsoft.com/en-us; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://account.microsoft.com/privacy/ad-settings/.
- UTM Parameter: Analysis of sources and user actions based on an expansion of web addresses pointing to us with an additional parameter, the “UTM” parameter. For example, a UTM parameter “utm_source=platformX &utm_medium=video” can tell us that a person clicked the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video). With the help of this information we can e.g. B. check our online visibility or the effectiveness of our campaigns; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- LinkedIn advertisements: Placement of advertisements within the LinkedIn platform and evaluation of the ad results; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://business.linkedin.com/de-de/marketing-solutions/ads; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://www.linkedin.com/legal/l/dpa; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. More information: https://legal.linkedin.com/dpa.
- LinkedIn messages: Message delivery via the social network LinkedIn; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Customer reviews and rating procedures
We participate in review and rating processes to evaluate, optimize and promote our services. If users rate us via the evaluation platforms or procedures involved or otherwise give feedback, the general terms and conditions or terms of use and the data protection information of the providers also apply. As a rule, the evaluation also requires registration with the respective provider.
In order to ensure that the reviewers have actually used our services, we transmit, with the consent of the customer, the necessary data regarding the customer and the service used to the respective review platform (including name, email address and order number or item number). This data is used solely to verify the authenticity of the user.
- Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category); 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, times, identification numbers, people involved).
- Affected persons: Beneficiaries and clients. Users (e.g. website visitors, users of online services).
- Purposes of processing:Feedback (e.g. collecting feedback via online form). Marketing.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Rating widget: We include so-called “rating widgets” in our online offering. A widget is a functional and content element integrated into our online offering that displays changeable information. It can e.g. B. can be presented in the form of a seal or comparable element, sometimes also called a “badge”. Although the corresponding content of the widget is displayed within our online offering, it is currently being retrieved from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. To do this, a data connection must be established from the website accessed within our online offering to the widget provider’s server and the widget provider receives certain technical data (access data, including IP address) that is necessary so that the content of the widget can be delivered to the user’s browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to recognize which online offers that take part in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Google Customer Reviews: Service to collect and/or present customer satisfaction and opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.google.com/; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information: As part of the collection of customer reviews, an identification number and the time for the business transaction to be evaluated are processed; in the case of review requests sent directly to customers, the customer’s email address and their country of residence as well as the review information itself are processed; Further information on the types of processing and the data processed: https://business.safety.google/adsservices/. Data processing conditions for Google advertising products: Information about the services Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Digitale Badges
Digital badges, also referred to as open badges (hereinafter referred to as “badges”), are digital certificates that confirm the skills, achievements and interests of people or organizations. They are issued by credible organizations. The badges contain metadata and information about the skills and achievements acquired. Typically, badges are represented by an image or a digital certificate that contains information about the recipient, issuer, metadata and other relevant information.
If badges are issued individually to specific people, the metadata stored in the badges and used to assign them to the skills, achievements and interests of the people concerned are processed.
If cookies and comparable technologies are not used as part of the badges and user consent is therefore or otherwise required, we will obtain the relevant consent from the user and inform them accordingly.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved). Contract data (e.g. subject matter of the contract, term, customer category).
- Affected persons: Beneficiaries and clients; Users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing:Marketing; Provision of our online offering and user-friendliness; Public relations and information purposes. Provision of contractual services and fulfillment of contractual obligations.
- Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Deletion after termination.
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Provision of digital badges: We provide digital badges. We process the data given to us by our customers, participants, business and contractual partners in order to provide, store, assign and issue these badges; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).
- Embedding of digital badges: As part of our online offering, we integrate badges from other sources (so-called “embedding”). This means that both the representation of the badge and the associated metadata are displayed within our offer. They are loaded in real time from the servers of the respective badge provider in order to always present the most current content of the badge. To achieve this, a data connection is established between our online offering and the badge provider’s server. The technical data that the badge provider receives includes the IP address, details and metadata of the badge, information about the website visited, the time of access and technical details about the browser and system, as transmitted from the end device to the server. This data transfer also informs the badge provider that a user has accessed our online offering; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Presences in social networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This can result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. The latter may in turn be used to place advertisements inside and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. In addition, data can also be stored in the usage profiles regardless of the devices used by the users (especially if they are members of the respective platforms and logged in there).
For a detailed description of the respective forms of processing and the objection options (opt-out), we refer to the data protection declarations and information of the operators of the respective networks.
In the case of requests for information and the assertion of the rights of those affected, we would like to point out that these can most effectively be asserted with the providers. Only the latter have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed:Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved). Inventory data (e.g. full name, home address, contact information, customer number, etc.).
- Affected persons:Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form); public relations; Marketing. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
- Instagram: Social network, allows you to share photos and videos, comment and favorite posts, send messages, subscribe to profiles and pages; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook pages: Profiles within the social network Facebook – Together with Meta Platforms Ireland Limited, we are responsible for the collection (but not further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook data policy: https://www.facebook.com/privacy/policy/). As described in the Facebook Data Policy under “How do we use this information?” Facebook also explains, collects and uses information to provide analysis services, so-called “Page Insights”, to site operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook groups: We use the “Groups” function of the Facebook platform to create interest groups within which Facebook users can contact each other or with us and exchange information. We process personal data of the users of our groups to the extent that this is necessary for the purpose of group use and its moderation. Our guidelines within the groups may contain further guidelines and information about the use of the respective group. This data includes information on first and last names, as well as published or privately communicated content, as well as values on the status of group membership or group-related activities, such as. B. Entry or exit as well as the times for the aforementioned dates. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content that users view or interact with, or the actions they take (see under “Things done and provided by you and others” in the Facebook data policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook data policy: https://www.facebook.com/privacy/policy/). As described in the Facebook Data Policy under “How do we use this information?” Facebook also explains, collects and uses information to provide analytical services, so-called “insights”, to group operators so that they can gain insights into how people interact with their groups and with the content associated with them; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook events: Event profiles within the social network Facebook – We use the “Events” function of the Facebook platform to point out events and dates as well as to get in touch with users (participants and interested parties) and to be able to exchange information. We process the personal data of users of our event pages to the extent that this is necessary for the purpose of the event page and its moderation. This data includes information on first and last names, as well as published or privately communicated content, as well as values on the status of participation and the time information for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content that users view or interact with, or the actions they take (see under “Things done and provided by you and others” in the Facebook data policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook data policy: https://www.facebook.com/privacy/policy/). As described in the Facebook Data Policy under “How do we use this information?” Facebook also explains, collects and uses information to provide analytics services, so-called “insights”, to event providers so that they can gain insights into how people interact with their event pages and the content associated with them; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- LinkedIn: Social network – We, together with LinkedIn Ireland Unlimited Company, are responsible for the collection (but not further processing) of visitor data, which is used to create the “page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details about the devices used are also recorded, such as: B. IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s data protection information: 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 regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of those affected (i.e. users can, for example, address requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of the 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 transmission of the 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 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - TikTok: Social network, allows you to share photos and videos, comment and favorite posts, send messages, subscribe to accounts; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy. Basic third country transfers: EU/EEA – Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland – Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- TikTok Business: Social network, allows you to share photos and videos, comment and favorite posts, send messages, subscribe to accounts – We and TikTok are jointly responsible for the collection and transmission of event data as well as the measurement and creation of insights reports (statistics) for profile holders. This event data includes information about the types of content users view or interact with or the actions they take, as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the users’ profile, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok’s data protection information: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have entered into a special agreement on shared responsibility with TikTok, which regulates in particular which security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to TikTok). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with TikTok. The agreement on shared responsibility can be found in TikTok’s “Jurisdiction Specific Terms”: https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basic third country transfers: EU/EEA – Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland – Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://myadcenter.google.com/personalizationoff.
Plug-ins and embedded functions and content
We incorporate 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”). This can be, for example, graphics, videos or city maps (hereinafter referred to as “content”).
The integration always requires that the third-party providers of this content process the users’ IP address, as without an IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offering, but 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 permission. Otherwise, the user data will be 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 data protection declaration.
- 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, times, identification numbers, people involved); Location data (information about the geographical position of a device or person); Event data (Facebook) (“Event data” is information that is sent, for example, via meta pixels (be it via apps or other channels) to the provider Meta and relates to people or their actions. This data includes details about website visits, interactions with content and functions, app installations and product purchases. The event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event data does not include actual content such as written comments, no login information and no contact information such as names, email addresses or telephone numbers. “Event data” will be deleted by Meta after a maximum of two years, and the target groups formed from it will disappear when our Meta user accounts are deleted.); Contact details (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation).
- Affected persons:Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; Reach measurement (e.g. access statistics, recognition of returning visitors); Tracking (e.g. interest/behavioral profiling, use of cookies); target group formation; Marketing; Provision of contractual services and fulfillment of contractual obligations. Profiles with user-related information (creating user profiles).
- Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
- Legal basis:Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the user and can 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. – We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the user and can 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 basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Facebook plugins and content: Facebook social plugins and content – This can be done, for example. This includes, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly with Meta Platforms Ireland Limited for the collection or receipt as part of a transfer (but not the further processing) of “event data” that Facebook collects using the Facebook social plugins (and embedding functions for content) that are carried out on our online offering or receives as part of a transmission for the following purposes: a) displaying content and advertising information that correspond to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improve ad delivery and personalization of features and content (e.g. improving detection of which content or advertising information is likely to match users’ interests). We have concluded a special agreement with Facebook (“Addition for those responsible”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, provide information or requests for deletion directly to Facebook). Note: If Facebook provides us with measured values, analyzes and reports (which are aggregated, i.e. do not contain information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but rather on the basis of an order processing contract (“data processing conditions”, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Google Fonts (provision on our own server): Provision of font files for the purpose of a user-friendly presentation of our online offering; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Google Fonts (obtained from Google server): Acquisition of fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform presentation and consideration of possible licensing restrictions. The font provider is informed of the user’s IP address 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) is transmitted that is necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the font provider in the USA – When you visit our online offering, the users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent that describes the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent needs to customize the font that is generated for each browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregate usage statistics are published on the Google Fonts Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. Google says it does not use any of the information collected by Google Fonts to create end-user profiles or serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). More information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Font Awesome (deployment on own server): Display of fonts and symbols; Service provider: The Font Awesome icons are hosted on our server, no data is transmitted to the Font Awesome provider; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Google Maps: We integrate the maps from the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of the users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Google Maps APIs and SDKs: Interfaces to Google’s map and location services, e.g. B. allow the addition of address entries, location determinations, distance calculations or the provision of additional information about locations and other locations; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Instagram plugins and content: Instagram plugins and content – This can be done, for example. This includes, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of “event data” that Facebook collects or receives as part of a transmission using Instagram functions (e.g. embedding functions for content) that are carried out on our online offering for the following purposes: a) displaying content and advertising information that correspond to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improve ad delivery and personalization of features and content (e.g. improving detection of which content or advertising information is likely to match users’ interests). We have concluded a special agreement with Facebook (“Addition for those responsible”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, provide information or requests for deletion directly to Facebook). Note: If Facebook provides us with measured values, analyzes and reports (which are aggregated, i.e. do not contain information about individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but rather on the basis of an order processing contract (“data processing conditions”, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basic basis for third country transfers: Switzerland – adequacy decision (Ireland).
- LinkedIn plugins and content: LinkedIn plugins and content- This can be done e.g. This includes, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within LinkedIn; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- MyFonts: Fonts; Data processed as part of the font retrieval includes the identification number of the web font project (anonymized), the URL of the licensed website, which is linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized webfont project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; After such extraction and storage of the number of page views, the log files are deleted; Service provider: Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.myfonts.co. Privacy policy: https://www.myfonts.com/info/legal/#Privacy.
- reCAPTCHA: We include the “reCAPTCHA” function in order to be able to recognize whether entries (e.g. in online forms) are made by people and not by automatically acting machines (so-called “bots”). The data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions or selecting objects in images). Data processing is based on our legitimate interest in protecting our online offering from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-Out Option:Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://myadcenter.google.com/personalizationoff.
- YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-Out Option:Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://myadcenter.google.com/personalizationoff.
- YouTube videos: Videos that are stored on YouTube are embedded within our online offering. These YouTube videos are integrated via a special domain using the “youtube-nocookie” component in the so-called “extended data protection mode”. In the “extended data protection mode” until the video starts, only information, which includes your IP address and information about the browser and your device, can be stored on your device in cookies or using comparable methods that YouTube requires to output, control and optimize the video display. As soon as you play the videos, additional information can be processed by YouTube to analyze usage behavior, store it in the user profile and personalize content and ads. The storage period for cookies can be up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). More information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-privacy-enhanced-mode%2Cturn-on-privacy-enhanced-mode%2Cenable-enhanced-privacy-mode.
- Vimeo video player: Integration of a video player; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Order processing agreement: https://vimeo.com/enterpriseterms/dpa. Basic third country transfers: EU/EEA – Standard contractual clauses (https://vimeo.com/enterpriseterms/dpa), Switzerland – Standard Contractual Clauses (https://vimeo.com/enterpriseterms/dpa).
Management, organization and support tools
We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data can be processed and stored on the third-party servers. This may affect various data, which we process in accordance with this data protection declaration. This data may include, in particular, user master data and contact details, data on processes, contracts, other processes and their content.
If users are referred to third-party providers or their software or platforms as part of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection information of the respective third-party providers.
- Types of data processed:Content data (e.g. textual or visual messages and posts and the information relating to them, such as information on authorship or time of creation); 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, times, identification numbers, people involved); Contract data (e.g. subject matter of the contract, term, customer category). Contact details (e.g. postal and email addresses or telephone numbers).
- Affected people:Communication partner; Users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Communication; Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles); Provision of our online offering and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Bitly: URL-Kürzungsdienst und Link-Management-Plattform; Dienstanbieter: Bitly, Inc., 139 Fifth Avenue, 5th Floor, New York, NY 10010, USA; Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://bitly.com; Datenschutzerklärung: https://bitly.com/pages/privacy. Grundlage Drittlandtransfers: EU/EWR – Data Privacy Framework (DPF), Schweiz – Data Privacy Framework (DPF).
- calendly: Online scheduling and appointment management; Service Provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://calendly.com/de; Privacy policy: https://calendly.com/privacy; Order processing contract: https://calendly.com/dpa. Basic basis for third country transfers: EU/EEA – Standard Contractual Clauses (https://calendly.com/dpa), Switzerland – Standard contractual clauses (https://calendly.com/dpa).
- DocuSign: Electronic signature of documents, sending documents for signature, tracking the status of documents, storing signed documents; Service Provider: DocuSign, Inc., 221 Main Street Suite 1000 San Francisco, CA 94105, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.docusign.com/; Privacy policy: https://www.docusign.com/privacy; Order processing agreement: https://www.docusign.com/legal/terms-and-conditions/data-protection-attachment; Basic third country transfers: EU/EEA – Standard contractual clauses (https://www.docusign.com/legal/terms-and-conditions/data-protection-attachment), Switzerland – Standard Contractual Clauses (https://www.docusign.com/legal/terms-and-conditions/data-protection-attachment). Further information: Processing as a processor and controller is also carried out on the basis of approved binding internal data protection regulations, which ensure a level of data protection that meets the requirements of the GDPR (English: “Binding Corporate Rules”, Art. 47 GDPR): https://www.docusign.com/trust/privacy/binding-corporate-rules.
- Claude API: Interface access (so-called “API”) to AI-based services designed to understand and generate natural language and related inputs, analyze information and make predictions (“AI”, i.e. “Artificial Intelligence”, is to be understood in the applicable legal sense of the term). Providing the AI Services includes processing (including collecting, storing, organizing and structuring) personal data as part of a natural language-based machine learning process; carrying out activities to verify or maintain the quality of the Services; identifying and resolving errors that affect existing intended functionality and helping to ensure the security and integrity of the AI Services; Service Provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.anthropic.com/; Terms and Conditions: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Privacy policy: https://www.anthropic.com/legal/privacy; Order processing agreement: https://www.anthropic.com/legal/commercial-terms. Basic third country transfers:EU/EEA – Standard contractual clauses (https://www.anthropic.com/legal/commercial-terms), Switzerland – Standard Contractual Clauses (https://www.anthropic.com/legal/commercial-terms).
- HubSpot social media publishing and contact management: Social media publishing, reporting (e.g. traffic sources, access numbers, web analysis), contact management (e.g. contact forms, direct communication and user segmentation), landing pages; Service Provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central Guild Street, Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing contract: https://legal.hubspot.com/dpa. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- AI software (on own server): Use of “artificial intelligence” in the applicable legal sense of the term, i.e. h. software based primarily on certain logic and substantially autonomously understanding and generating natural language or other inputs as well as data, analyzing information and making predictions; Service provider: Execution on servers and/or computers under their own data protection responsibility; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- WeTransfer: Transferring files over the Internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://wetransfer.com; Privacy policy: https://wetransfer.com/legal/privacy. Basic basis for third country transfers: Switzerland – adequacy decision (Netherlands).
- Meetergo: Online scheduling and appointment management; Service provider: meetergo GmbH Hansaring 6150670 Cologne; Website: https://www.meetergo.com/de/. Privacy policy: https://www.meetergo.com/de/datenschutz/.
- Zapier: Automatisierungsplattform; Dienstanbieter: Zapier, Inc., 548 Market St #62411, San Francisco, Kalifornien 94104, USA; Website: https://zapier.com/. Datenschutzerklärung: https://zapier.com/privacy.
- make.com: Automatisierungsplattform; Dienstanbieter: Celonis SE, Theresienstr. 6, 80333 München, Deutschland; Website: https://www.make.com/. Datenschutzerklärung: https://www.make.com/en/privacy-notice.
Processing of data within the context of employment relationships
As part of employment relationships, personal data is processed with the aim of effectively establishing, implementing and terminating such relationships. This data processing supports various operational and administrative functions necessary for the management of employee relations.
Data processing includes various aspects, ranging from contract initiation to contract termination. This includes the organization and management of daily working hours, the management of access rights and authorizations as well as the handling of personnel development measures and employee discussions. The processing also serves the billing and administration of wage and salary payments, which represent critical aspects of the execution of the contract.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data to evaluate and optimize operational processes. Furthermore, data processing includes the disclosure of employee data as part of external communication and publication processes, where this is necessary for operational or legal purposes.
The processing of this data always takes place in compliance with the applicable legal framework, with the aim always being to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the affected employees, the anonymization or deletion of data after the processing purpose has been fulfilled or in accordance with statutory retention periods.
- Types of data processed:Employee data (information on employees and other persons in an employment relationship); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category); Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); Social data (data that is subject to social secrecy and is processed, for example, by social insurance providers, social assistance providers or pension authorities.); Protocol data (e.g. log files regarding logins or the retrieval of data or access times.); Performance and behavioral data (e.g. performance and behavioral aspects such as performance ratings, feedback from supervisors, training participation, compliance with company policies, self-evaluations and behavioral ratings.); Working time data (e.g. start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special vacation days, sick days, absences, home office days, business trips); Salary data (e.g. basic salary, bonus payments, bonuses, tax class information, surcharges for night work/overtime, tax deductions, social security contributions, net payout amount); Image and/or video recordings (e.g. photographs or video recordings of a person); 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, times, identification numbers, people involved).
- Special categories of personal data:Health data; Religious or ideological beliefs. Union membership.
- Affected people:Employees (e.g. employees, applicants, temporary workers and other employees).
- Purposes of processing: Establishment and implementation of employment relationships (processing of employee data within the framework of the establishment and implementation of employment relationships); business processes and business procedures; Provision of contractual services and fulfillment of contractual obligations; public relations; Security measures. Office and organizational procedures.
- Legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Processing of special categories of personal data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR).
Further information on processing processes, procedures and services:
- Working time recording: Methods for recording employees’ working hours include both manual and automated methods, such as the use of time clocks, time recording software or mobile apps. Activities such as entering arrival and departure times, break times, overtime and absences are carried out. Checking and validating the recorded working times includes comparing them with deployment or shift plans, checking absences and approving overtime by superiors. Reports and analyzes are created based on recorded working hours to provide timesheets, overtime reports and absence statistics for management and human resources; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Permissions Management: Procedures involved in defining, managing and controlling access rights and user roles within a system or organization (e.g. creation of permissions profiles, role and access-based control, review and approval of access requests, periodic review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Special categories of personal data: Special categories of personal data are processed as part of the employment relationship or to fulfill legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data can be passed on to health insurance companies or processed to assess the ability of employees to work or for company health management or to provide information to the tax office; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Sources of processed data: Personal data received as part of the employee’s application and/or employment relationship is processed. In addition, if required by law, personal data is collected from other sources. These can be tax authorities for tax-relevant information, the respective health insurance company for information about incapacity to work, third parties such as employment agencies or publicly accessible sources such as professional social networks as part of the application process; Legal basis: Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Purposes of data processing: Employees’ personal data are primarily processed to establish, implement and terminate the employment relationship. In addition, the processing of this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to meet regulatory and supervisory requirements, to optimize electronic data processing processes and to compile internal or cross-company data, possibly including statistical data. Furthermore, employees’ data can be processed to assert legal claims and to defend themselves in legal disputes; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Transmission of employee data: Employee data is only processed internally by those departments that need it to fulfill operational, contractual and legal obligations.
Data will only be passed on to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or if there are capital accumulation services. Furthermore, the person responsible can forward personal data to other recipients to the extent that this is necessary to fulfill his contractual and legal obligations as an employer. These recipients can include: a) Banks b) Health insurance companies, pension insurance providers, pension providers and other social insurance providers c) Authorities, courts (e.g. tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the event of garnishment of wages and salaries f) Other bodies to which legally binding declarations must be made.
In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples of this include information in the sender area of emails or letterhead as well as creating profiles on external platforms; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). - Transfer of employee data to third countries: The transfer of employee data to third countries, i.e. countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the fulfillment of the employment relationship, is required by law or if employees have given their consent to this. Employees will be informed separately about the details, if required by law; Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Business trips and travel expense reporting:Procedures required when planning, executing and accounting for business trips (e.g. booking trips, organizing accommodation and means of transport, managing travel expense advances, submitting and reviewing travel expense reports, controlling and accounting for costs incurred, compliance with travel guidelines, handling travel expense management); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Payroll and payroll accounting: Procedures that are necessary for the calculation, payment and documentation of wages, salaries and other remuneration of employees (e.g. recording of working hours, calculation of deductions and surcharges, payment of taxes and social security contributions, preparation of payroll and salary statements, management of payroll accounts, reporting to the tax office and social security institutions); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR).
- Deletion of employee data: Employee data will be deleted according to German law if it is not necessary for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or due to the interests of the employer. The following storage and archiving obligations are observed:
- General personnel documents – General personnel documents (such as employment contracts, job references, additional agreements) are retained for up to three years after termination of the employment relationship (§ 195 BGB).
Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 AO, § 257 HGB).
Information about wages and working hours – Information about wages and working hours for (accident) insured persons with proof of wages is kept for five years (§ 165 I 1, IV 2 SGB VII). - Salary lists including lists for special payments – Salary lists including lists for special payments, provided a booking voucher is available, are kept for ten years (§ 147 AO, § 257 HGB).
- Wage lists for interim, final and special payments – Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
- Employee insurance documents – Employee insurance documents, provided booking documents are available, are retained for ten years (§ 147 AO, § 257 HGB).
- Contribution statements to social insurance institutions – Contribution statements to social insurance institutions are kept for ten years (§ 165 SGB VII).
Wage accounts – Payroll accounts are kept for six years (§ 41 I 9 EStG). - Applicant data – Will be stored for a maximum of six months from receipt of the rejection.
- Working time records (for more than 8 hours on weekdays) – are kept for two years (§ 16 II Working Hours Act (ArbZG)).
- Application documents (according to the online job advertisement) – Will be kept for three to a maximum of six months after receipt of the rejection (§ 26
- Federal Data Protection Act (BDSG) n.F., § 15 IV General Equal Treatment Act (AGG)).
- Certificates of incapacity for work (AU) – are kept for up to five years (Section 6 I of the Expenditure Equalization Act (AAG)).
- Documents on company pension schemes – are kept for 30 years (Section 18a of the Act to Improve Company Pension Schemes (BetrAVG)).
- Employee illness data – Will be kept twelve months after the onset of the illness if absences in a year do not exceed six weeks.
- Maternity protection documents – are kept for two years (Section 27 Para. 5 MuSchG).
- General personnel documents – General personnel documents (such as employment contracts, job references, additional agreements) are retained for up to three years after termination of the employment relationship (§ 195 BGB).
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR), processing special categories of personal data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR).
- Personnel record keeping: Procedures required when organizing, updating and managing employee data and documents (e.g. recording personnel master data, storing employment contracts, references and certificates, updating data in the event of changes, compiling documents for employee interviews, archiving personnel files, compliance with data protection regulations); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR), processing of special categories of personal data Data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR).
- Human resources development, performance evaluation and employee appraisals: Procedures that are necessary in the area of promoting and developing employees as well as in assessing their performance and in the context of employee appraisals (e.g. needs analysis for further training, planning and implementing training measures, creating performance appraisals, conducting target agreement and feedback discussions, career planning and talent management, succession planning); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR), processing of special categories of personal data Data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR).
- Obligation to provide data: The person responsible informs employees that it is necessary to provide their data. This is generally the case if the data is necessary for the establishment and implementation of the employment relationship or if its collection is required by law. Providing data may also be necessary if employees assert claims or if employees are entitled to claims. The implementation of these measures or the fulfillment of services depends on the provision of this data (for example the provision of data for the purpose of receiving wages); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
- Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if this is necessary to carry out the work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website or in public registers after consultation or agreed job description, or if the field of responsibility contains representative functions. This can also be the case if, as part of the performance of the task, a representation or communication with the public takes place, such as images taken as part of public relations work. Otherwise, employees’ data will only be published with their consent or based on the legitimate interests of the employer, for example in the case of stage or group photos as part of a public event; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Application process
The application process requires that applicants provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.
Basically, the required information includes personal information such as name, address, a contact option and evidence of the qualifications required for a position. Upon request, we will also be happy to provide information about what information is required.
If available, applicants are welcome to submit their applications using our online form, which is encrypted using the latest technology. Alternatively, it is also possible to send applications to us by email. However, we would like to point out that emails on the Internet are generally not sent encrypted. Although email is typically encrypted in transit, it is not encrypted on the servers from which it is sent and received. Therefore, we cannot assume any responsibility for the security of the application during its transmission between the sender and our server.
For the purposes of finding applicants, submitting applications and selecting applicants, we can use applicant management and recruitment software and platforms and services from third-party providers in compliance with legal requirements.
Applicants are welcome to contact us about how to submit the application or send us the application by post.
Processing of special categories of data: If special categories of personal data (Art. 9 Para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from or communicated to applicants as part of the application process, their processing is carried out by the person responsible or the person concerned who gives him or her information under labor law and exercise rights under social security and social protection law and fulfill his or her obligations in this regard, in the case of protecting the vital interests of applicants or other persons or for the purposes of preventive health or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, for health or social care or treatment or for the management of health or social systems and services.
Deletion of data: If the application is successful, the data provided by the applicants can be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified revocation by the applicant, at the latest after a period of six months has elapsed, so that we can answer any follow-up questions about the application and fulfill our obligations to provide proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.
Admission to an applicant pool: Admission to an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time in the future.
- Types of data processed:Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). Applicant data (e.g. personal information, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letter, CV, certificates and other information about their person or qualifications provided voluntarily by applicants with regard to a specific position).
- Affected people: Applicants.
- Purposes of processing:Application process (justification and possible subsequent implementation as well as possible later termination of the employment relationship).
- Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
- Legal basis:Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Facebook Jobs: Job search and application-related services within the Facebook platform; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- LinkedIn Recruiter: Job search and application-related services within the LinkedIn platform; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com; Terms and Conditions: https://legal.linkedin.com/dpa; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa. Basic basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Monster: Services related to employee acquisition/recruitment (search for employees, communication, application process, contract negotiations); Service provider: Monster Worldwide Deutschland GmbH, Ludwig-Erhard-Straße 14, 65760 Eschborn, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.monster.de; Privacy policy: https://www.monster.de/datenschutz/datenschutz/home.aspx. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- Stepstone: Services related to employee acquisition/recruitment (search for employees, communication, application process, contract negotiations); Service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.stepstone.de; Data protection declaration: https://www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
- Xing: Job search and application-related services within the Xing platform; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.xing.com; Data protection declaration: https://privacy.xing.com/de/datenschutzerklaerung. Basic basis for third country transfers: Switzerland – adequacy decision (Germany).
Changes and updates
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration 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 cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information for companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.
Supervisory authority responsible for us:
Austrian Data Protection Authority
Barichgasse 40-42
1030 Wien
Telefon: +43 1 52 152-0
E-Mail: [email protected]
Definitions of terms
This section provides an overview of the terms used in this data protection declaration. To the extent that the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are intended primarily to provide understanding.
- A/B tests: A/B tests serve to improve the user-friendliness and performance of online offerings. Users are given e.g. For example, different versions of a website or its elements, such as input forms, are shown, on which the placement of the content or the labels of the navigation elements may differ. Then, based on the behavior of the users, e.g. B. longer stay on the website or more frequent interaction with the elements, it can be determined which of these websites or elements are more likely to meet the needs of the user.
- Employees:Employees are people who are in an employment relationship, be it as employees, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It involves the employer’s obligation to pay remuneration to the employee while the employee performs his or her work. The employment relationship includes various phases, including the justification in which the employment contract is concluded, the implementation in which the employee carries out his work activity and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information that relates to these people and is in the context of their employment. This includes aspects such as personal identification information, identification numbers, salary and banking information, working hours, vacation entitlements, health information and performance reviews.
- Inventory data:Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This information may include, but is not limited to, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear attribution and communication.
- Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if those affected consent, if they are necessary for the fulfillment of the contract or if national laws permit these decisions.
- Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that can be used to deliver the content of an online offering, especially large media files such as graphics or program scripts, more quickly and securely with the help of regionally distributed servers connected via the Internet.
- Heatmaps: “Heatmaps” are mouse movements of the user that are combined into an overall image, with the help of which, for example, B. it can be recognized which website elements are preferred and which website elements users prefer less.
- Content data: Content data includes information that is generated in the course of creating, editing and publishing all types of content. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not only 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
- Click tracking:Click tracking allows users to monitor the movements of users within an entire online offering. Since the results of these tests are more accurate if user interaction can be tracked over a certain period of time (e.g. so that we can find out whether a user likes to return), cookies are usually stored on the users’ computers for these testing purposes.
- Contact details: Contact details are essential information that enables communication with people or organizations. They include, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then accessed again on the target website. For example, we can see whether the advertisements we placed on other websites were successful.
- Artificial Intelligence (AI):The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data in order to recognize 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 as well as the continuous review and optimization of the results and is only carried out with the consent of the users or based on legal permission.
- Performance and Behavioral Data:Performance and Behavioral Data refers to information related to how people perform tasks or behave in a particular context, such as an educational, work, or social environment. This data may include metrics such as productivity, efficiency, quality of work, attendance, and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes and reactions to different situations. These types of data are often used for performance evaluations, training and development, and decision making within organizations.
- Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, provenance, and structure of other data. They can include information about file size, creation date, author of a document and change histories. Communication data records the exchange of information between users across various channels, such as email traffic, call logs, social network messages and chat histories, including the people involved, timestamps and transmission routes. Procedural data describes the processes and operations within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review 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 spend on certain pages, and the paths they use to navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered identifiable if he or she 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 special characteristics that express the physical, physiological, genetic, psychological, 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, which consists in the use of these personal data to determine certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information regarding demographics, behavior and interests, such as e.g. to analyze, evaluate or predict interaction with websites and their content, etc. (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Log Data:Log data is information about events or activities logged on a system or network. This data typically includes 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 analyze system problems, monitor security, or create performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can determine the behavior or interests of visitors in certain information, such as: B. content of websites. With the help of reach analysis, operators of online offers can e.g. B. recognize at what time users visit your websites and what content they are interested in. This allows you, for example, B. adapt the content of the websites better to the needs of your visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyzes of the use of an online offer.
- Remarketing: We speak of “remarketing” or “retargeting” when, for example. B. for advertising purposes it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. B. in advertisements to remember.
- Location data:Location data is created when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions for location determination. Location data is used to indicate at which geographically determinable position on earth the respective device is located. Location data can e.g. B. can be used to display map functions or other information dependent on a location.
- Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the tracking technology providers with regard to the online offers used (so-called profiling). This information can then be used e.g. B. can be used to show users advertisements that are likely to match their interests.
- Responsible person: The “responsible person” is the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
- Processing: “Processing” means any operation or series of operations carried out on personal data, with or without the aid of automated procedures. The term is wide-ranging and includes practically every handling of data, be it collecting, evaluating, storing, transmitting or deleting.
- Contract Data: Contract Data is specific information related to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, extension options and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are 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 electronic commerce, online banking and any other form of financial transaction. They include details such as credit card numbers, bank details, payment amounts, transaction details, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorizations and fees.
- Target group formation: Target group formation (“Custom Audiences”) is used when target groups are created for advertising purposes, e.g. B. Display of advertisements can be determined. So can e.g. 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 in which he viewed the products. “Lookalike audiences” (or similar target groups) are when the content deemed 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 usually used for the purpose of forming custom audiences and lookalike audiences.