Preamble
With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, the purposes for which we process it, and the scope of this processing. The privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: October 2024
Controller
schnell.digital GmbH Theodor-Heuss-Ring 9D 86405 Meitingen
Email address:
Imprint:
www.schnell.digital/legal
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
- Inventory data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
Categories of Data Subjects
- Customers.
- Employees.
- Interested parties.
- Communication partners.
- Users.
- Business and contractual partners.
- Persons depicted.
Purposes of Processing
- Provision of contractual services and compliance with contractual obligations.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Provision of our online offer and user-friendliness.
- Information technology infrastructure.
Legal Bases for Processing
Relevant legal bases under the GDPR: In the following, we provide 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 provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6(1) p. 1 lit. a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request.
- Legal obligation (Art. 6(1) p. 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and the transfer and automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Note on the applicability of the GDPR and the Swiss DSG: This privacy notice serves both to provide information in accordance with the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR). For this reason, please note that due to the broader territorial scope and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DSG, such as “processing” of “personal data,” “overriding interest,” and “sensitive personal data,” the terms used in the GDPR, such as “processing” of “personal data” and “legitimate interest” and “special categories of data,” are used. The legal meaning of the terms is, however, determined in accordance with the GDPR in the case of the applicability of the Swiss DSG.
Security 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 nature, 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, to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability, and their separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. Moreover, we consider the protection of personal data already in the development or selection of hardware, software, and procedures according to the principle of data protection by design and by default.
TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data exchanged between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. HTTPS is displayed in the URL when a website is secured by an SSL/TLS certificate.
Transmission of Personal Data
In the course of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units, or persons, or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate entrepreneurial and business interests or is carried out if it is necessary for the fulfillment of our contract-related obligations or if a consent of the data subjects or a legal permission exists.
International Data Transfers
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 in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.).
EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has recognized the level of data protection for certain companies in the USA as adequate by means of an adequacy decision as of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We inform you in the context of our privacy notices which of our service providers are certified under the Data Privacy Framework.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right to information: You have the right to obtain confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of the data concerning you or the rectification of incorrect data concerning you.
- Right to erasure 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, in accordance with the legal requirements, to demand restriction of the processing of the data.
- Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with the legal requirements, or to demand its transfer to another controller.
- Complaint to supervisory authority: You also have the right, in accordance with the legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Use of Cookies
Cookies are small text files, or other storage notes, that store information on end devices and read information from the end devices. For example, to save the login status in a user account, a shopping cart content in an e-shop, the content accessed, or functions used in an online offer. Cookies can also be used for various purposes, such as for functionality, security, and comfort of online offers as well as the creation of analysis of visitor flows.
Notes on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage of and access to information, i.e., cookies, is absolutely necessary for us to provide the telemedia service expressly requested by the user (i.e., for the sole purpose of carrying out the communication via the internet). Temporary cookies, or so-called “session cookies,” fall under this category. They store the login status, or the shopping cart content in an online store, or temporarily store entered information in online forms, among other things. Likewise, cookies with purely technical functions, which are used to ensure the proper functioning of our online offer, always fall under this category. The consent that is required is obtained from the users and contains information about the respective cookie use.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies will be based on our legitimate interests (e.g., in a business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes of processing cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
- 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 end device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General notes on revocation and objection (opt-out): Users can revoke the consent they have given at any time and object to the processing in accordance with the legal requirements. Users can also restrict the use of cookies in the settings of their browser. However, please note that this may result in a restriction of the functionality of our online offer. You can object to the use of cookies for online marketing purposes via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR). Consent (Art. 6(1) p. 1 lit. a) GDPR).
Further notes on processing procedures, methods, and services:
- Processing of cookie data based on consent: We use a cookie consent management procedure, within the framework of which the consent of users to the use of cookies, or the processing mentioned in the cookie consent management procedure, can be obtained and managed and revoked by the users. Here, the declaration of consent is stored so that it does not have to be repeated and proof of consent can be provided in accordance with the legal obligation. The storage can take place server-side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), and the browser, system, and end device used; Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR).
- CookieConsent: Cookie consent management; Service provider: Self-hosted service; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR). Website: https://cookieconsent.orestbida.com/.
- LinkedIn Insights Tag: Code that is loaded when a user visits our online offer and tracks the user’s behavior and conversions, storing them in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: Consent (Art. 6(1) p. 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; Basis for data transfer to a third country: Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offer (for further information, please refer to this privacy policy). With the Tag Manager itself (which implements the tags), for example, no profiles of users are created or cookies are stored. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms).
Business Services
We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractual), e.g., to answer inquiries.
We process this data to fulfill our contractual obligations, to safeguard our rights, and for the purposes of the administrative tasks associated with these obligations and the entrepreneurial organization. Within the framework of applicable law, we only disclose the data of the contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the contractual partners (e.g., to participating telecommunication, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). The contractual partners will be informed about further processing, e.g., for marketing purposes, as part of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contractual partners before or in the context of the data collection, e.g., in online forms by special marking (e.g., colors), and/or symbols (e.g., asterisks or the like), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons of archiving (e.g., for tax purposes, the statutory retention period is generally 10 years for data relevant to tax law and 6 years for commercial data stored in commercial books, inventories, opening balance sheets, annual financial statements, the management reports, accounting vouchers, commercial and business letters, for tax documents, etc., and for documents directly related to these).
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
- Types of data processed: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email, telephone numbers); Contract data (e.g., subject of contract, duration, customer category).
- Data subjects: Interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service; Contact requests and communication; Office and organizational procedures.
- Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR); Legal obligation (Art. 6(1) p. 1 lit. c) GDPR). Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Agency services: We process the data of our customers as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consultation or maintenance, campaign and process handling, server administration, data analysis/consulting services, and training services; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR).
- Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) to enable them to select, acquire, or commission the selected services or works as well as related activities and their payment and provision or execution or performance. The required details are identified as such within the framework of the contract, order, or equivalent contract conclusion and include the details required for service provision and invoicing as well as contact information to allow for any consultations. Insofar as we gain access to the information of end customers, employees, or other persons, we process it in accordance with legal and contractual requirements; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR).
- Offer of software and platform services: We process the data of our users, registered users, and any test users (hereinafter uniformly referred to as “users”) to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to develop it further. The required details are identified as such within the framework of the contract, order, or equivalent contract conclusion and include the details required for service provision and invoicing as well as contact information to allow for any consultations; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR).
Use of Online Platforms for Offering and Distribution Purposes
We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy notices. This applies in particular with regard to the execution of the payment process and the procedures on the platforms for reach measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email, telephone numbers); Contract data (e.g., subject of contract, duration, customer category); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers; Interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service; Marketing; Conversion measurement (measurement of the effectiveness of marketing measures). Provision of our online offer and user-friendliness.
- Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR). Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Digistore24: Online marketplace; Service provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.digistore24.com/. Privacy policy: https://www.digistore24.com/de/home/extern/cms/page/frontend/legal/privacy.
Services and Service Providers Used in the Course of Business
In the course of our business activities, we use additional services, platforms, interfaces, or plugins from third-party providers (hereinafter referred to as “services”) in compliance with legal requirements. Their use is based on our interests in the proper, legally compliant, and economical management of our business operations and internal organization.
- Types of data processed: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Contract data (e.g., subject of contract, duration, customer category).
- Data subjects: Customers; Interested parties; Users (e.g., website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service. Office and organizational procedures.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- sevDesk: Online software for invoicing, accounting, banking, and tax filing with document storage; Service provider: sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://sevdesk.de/; Privacy policy: https://sevdesk.de/sicherheit-datenschutz/. Order processing agreement: https://sevdesk.de/sicherheit-datenschutz/.
Provision of the Online Offer and Web Hosting
We process the data of users in order to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary for the transmission of the content and functions of our online services to the user’s browser or end device.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); Content data (e.g., entries in online forms).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).). Security measures.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Collection of access data and log files: The access to our online offer is logged in the form of so-called “server log files.” Server log files may include the address and name of the accessed websites and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used, on the one hand, for security purposes, e.g., 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 bases: Legitimate interests (Art. 6(1) p. 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 retention is required for evidentiary purposes is exempt from deletion until the respective incident is finally clarified.
- Vercel: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities) as well as software development; Service provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://vercel.com; Privacy policy: https://vercel.com/legal/privacy-policy; Order processing agreement: https://vercel.com/legal/dpa. Basis for data transfer to a third country: Standard contractual clauses (https://vercel.com/legal/dpa).
Purchase of Applications via Appstores
The purchase of our application is made via special online platforms operated by other service providers (so-called “appstores”). In this context, the privacy policies of the respective appstores apply in addition to our privacy notices. This applies in particular with regard to the payment process on the platforms and procedures on the platforms for reach measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email, telephone numbers); Contract data (e.g., subject of contract, duration, customer category); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); Content data (e.g., entries in online forms).
- Data subjects: Customers; Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service; Marketing.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Apple App Store: App and software sales platform; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.apple.com/de/ios/app-store/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Play: App and software sales platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://play.google.com/store/apps?hl=de. Privacy policy: https://policies.google.com/privacy.
Blogs and Publication Media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). The data of the readers are processed only to the extent necessary for the presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.
- Types of data processed: Inventory data (e.g., names, addresses); Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service; Feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Contact and Inquiry Management
When contacting us (e.g., via contact form, email, telephone, or via social media) as well as in the context of existing user or business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
- Types of data processed: Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR). Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR).
Further notes on processing procedures, methods, and services:
- HubSpot: Customer management as well as process and sales support with personalized customer care with multi-channel communication, i.e., management of customer inquiries from various channels and with analysis and feedback functions; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR), Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://legal.hubspot.com/dpa).
Chatbots and Chat Functions
We offer online chats and chatbot functions as a means of communication (collectively referred to as “chat services”). In a chat, the exchange of messages takes place with a certain immediacy. When you use our chat features, 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 can also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes to be able to prove them according to legal requirements.
We inform 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 user’s device used and, depending on the settings of their device, location information (so-called metadata) for optimization purposes and for security purposes. Likewise, the metadata of communication via chat services (i.e., the information about who has communicated with whom) may be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their regulations, to which we refer for further information.
If users agree to a chatbot communicating with them, users have the option to stop the communication at any time. The chatbot informs users how and with which terms they can stop the messages. By stopping the chatbot messages, users’ data is deleted from the message recipient directory.
We use the above information to operate our chat services, e.g., to address users personally, to respond to their inquiries, to transmit any requested content, and also to improve our chat services (e.g., to “teach” chatbots to respond to frequently asked questions).
Notes on legal bases: We use the chat services on the basis of consent if we have previously obtained the permission of the users to process their data within the scope of our chat services. If users are asked for their consent to the storage of their data, the legal basis of the processing is consent. Otherwise, the data of the users will be processed on the basis of our legitimate interests in an efficient and secure communication system. In this context, we would like to refer you to the information on the legal bases of the processing of your data within the scope of this privacy policy.
Revocation, objection, and deletion: You can revoke your consent or object to the processing of your data within the scope of our chat services at any time.
- Types of data processed: Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication; Direct marketing (e.g., by email or postal mail).
- Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR); Performance of a contract and pre-contractual requests (Art. 6(1) p. 1 lit. b) GDPR). Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- HubSpot: Chatbot and assistance software as well as related services; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://legal.hubspot.com/dpa).
Video Conferences, Online Meetings, Webinars, and Screen Sharing
We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When participating in a conference, various types of data of the participants are processed.
Data processed in connection with the participation in a conference: The scope of the processing depends on the one hand on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to the processing for the purpose of conducting the conference, the data of the participants may also be processed by the conference platforms for security purposes or service optimization. For the purpose of holding the conference, the data of the communication contents (i.e., your input in chats or audio and video contributions) as well as entry data are processed and stored on the servers of the conference platforms.
Logs and recordings: If texts are entered, 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 notices and select the most secure and data protection-friendly settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g., by notifying roommates, locking doors, and using the background blurring function, if technically possible). Links to the conference rooms as well as access data should not be passed on to unauthorized third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process the data of the users and ask 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 of the processing is this consent. Furthermore, the processing may be necessary for the fulfillment of our contractual obligations (e.g., in participant lists, in the case of reviewing the conference contents, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- Types of data processed: Inventory data (e.g., names, addresses); Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Communication partners; Users (e.g., website visitors, users of online services). Depicted persons.
- Purposes of processing: Provision of contractual services and customer service; Contact requests and communication; Office and organizational procedures.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Google Hangouts / Meet: Conference and communication software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://hangouts.google.com/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://cloud.google.com/terms/eu-model-contract-clause).
Cloud Services
We use software services accessible via the internet and executed on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g., document storage and management, exchange of documents, content, and information with specific recipients or publication of content and information).
In this context, personal data may be processed and stored on the providers’ servers to the extent that it is part of communication processes with us or otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on processes, contracts, other processes, and their contents. The providers of the cloud services also process usage data and metadata used by them for security purposes and service optimization.
If we use the cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users’ devices for web analysis purposes or to remember user settings (e.g., in the case of media control).
- Types of data processed: Inventory data (e.g., names, addresses); Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers; Employees (e.g., employees, applicants, former employees); Interested parties; Communication partners; Users (e.g., website visitors, users of online services).
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (provision and operation of information systems and technical devices (computers, servers, etc.).).
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Google Workspace: Cloud-based application software (e.g., text and spreadsheet processing, calendar 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 bases: Legitimate interests (Art. 6(1) p. 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; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.
Newsletters and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is generally carried out in a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.
- Types of data processed: Inventory data (e.g., names, addresses); Contact data (e.g., email, telephone numbers); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); Usage data (e.g., websites visited, interest in content, access times).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., by email or postal mail).
- Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR). Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
- Opt-out option: You can cancel the receipt of our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further notes on processing procedures, methods, and services:
- HubSpot: Email delivery and automation services; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://legal.hubspot.com/dpa).
- SendGrid: Email delivery and communication platform for transactional and marketing emails; Service provider: Twilio Ireland Limited, 25 – 28 North Wall Quay, North Wall, Dublin 1, D01 H104, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://sendgrid.com; Privacy policy: https://www.twilio.com/legal/privacy; Order processing agreement: https://www.twilio.com/legal/data-protection-addendum. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.twilio.com/legal/data-protection-addendum).
Advertising Communication via Email, Post, Fax, or Telephone
We process personal data for the purposes of advertising communication, which may be carried out via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to revoke the consent given at any time or to object to advertising communication at any time.
After revocation or objection, we may store the data required for proof of prior authorization for up to three years after the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest to permanently observe the revocation or objection of the users, we also store the data necessary to avoid further advertising communication (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed: Inventory data (e.g., names, addresses); Contact data (e.g., email, telephone numbers).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., by email or postal mail).
- Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR). Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Generative AI Services
We use internet-accessible software services (so-called “cloud services,” also referred to as “software as a service”) as well as locally hosted language models for the generation of texts and images, the analysis of texts, and similar application areas. In doing so, we ensure that no personal data or trade secrets covered by NDAs are passed on to external service providers.
Sensitive data is processed exclusively with locally hosted language models (e.g., Llama or Mistral/Codestral), which are operated on our own servers. For further use cases, we use cloud-based generative AI services such as OpenAI (ChatGPT) and Mistral.
- Types of data processed: Content data (e.g., input texts or uploaded data for analysis); Usage data (e.g., session and interaction data); Meta, communication, and procedural data (e.g., customer inquiries, specifications, error reports).
- Data subjects: Customers; Employees (e.g., employees, applicants, former employees); Interested parties; Communication partners; Users (e.g., website visitors, users of online services).
- Purposes of processing: Support in the creation and analysis of content; Improvement and optimization of work processes; Information technology infrastructure.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
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OpenAI (ChatGPT): Cloud-based generative AI platform for text and data processing; Service provider: OpenAI, L.L.C., 3180 18th Street, San Francisco, CA 94110, USA; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://openai.com; Privacy policy: https://openai.com/policies/privacy-policy; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://openai.com/policies/eu-model-clauses).
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Mistral: Cloud-based generative AI platform for text and data processing; Service provider: Mistral AI, 123 Rue Réaumur, 75002 Paris, France; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://mistral.ai; Privacy policy: https://mistral.ai/privacy-policy; Further information: https://mistral.ai/terms.
Web Analysis, Monitoring, and Optimization
Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or contents are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.
In addition to web analytics, we can also use test procedures, for example, to test and optimize different versions of our online offering or its components.
For these purposes, profiles, i.e., data summarized for a usage process, may be created and information may be stored in a browser or in an end device and read from it. These may include, in particular, IP addresses and technical data about the browser or end device used, but also information about the user’s actions and the content of their inquiries. The user profiles may be stored in a browser or in a file independently of the browser or the end device (e.g., in a so-called cookie file). This information may include content viewed or interacted with and the locations from which the content was accessed (even if this location determination is only approximate). Technical information about the browser used, the computer system used, as well as information about usage times may also be collected. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of the users (such as email addresses or names) are stored in the context of web analysis, A/B testing, and optimization, but 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 purposes of the respective procedures.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR).
Further notes on processing procedures, methods, and services:
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Artificial Intelligence and Generative AI: In the course of collaboration and marketing, generative AI models are used, for example, to generate or analyze texts or graphics or to process code. No personal information or trade secrets are disclosed to third parties. If the processing of sensitive information occurs, it is done exclusively in local AI models. All
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Google Analytics in consent mode: In consent mode, personal data of users is processed by Google for measurement and advertising purposes depending on the consent of the users. The consent is obtained from the users within our online services. If the consent is completely absent, the data will only be processed on an aggregated (i.e., not assigned to individual users and summarized) level. If consent only includes statistical measurement, no personal data of the users will be processed for ad display or measurement of ad success (so-called “conversion”); Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR). Website: https://support.google.com/analytics/answer/9976101?hl=de.
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Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (for further information, please refer to this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms).
Online Marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information 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 on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of the users (such as email addresses or names) are stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read out and analyzed for the purpose of content display on other websites that use the same online marketing procedure, as well as stored with them and enriched with additional data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data may be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network connects the profiles of the users with the aforementioned data. We ask you to note that users may have made additional agreements with the providers, e.g., by giving their consent as part of the registration process.
In principle, we only receive access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The 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.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavior-related profiling, use of cookies); Marketing; Profiles with user-related information (creation of user profiles); Conversion measurement (measurement of the effectiveness of marketing measures). Provision of our online offer and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR). Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
- Opt-out option: We refer to the privacy policies of the respective providers and the contact options (so-called “opt-out”) specified therein. Furthermore, the opt-out option in the data protection settings of the browser or in the settings for data protection in the respective operating system or app settings of the end device. Furthermore, you can use the opt-out options of the following services that are summarized for the respective region: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.
Further notes on processing procedures, methods, and services:
- Google Ads and Conversion Measurement: Online marketing method for placing content and advertisements within the advertising network of the service provider (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. Furthermore, we measure the conversion of the ads, i.e., whether the users took action prompted by the ads (so-called conversion). 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 bases: Consent (Art. 6(1) p. 1 lit. a) GDPR), Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF); Further information: Types of processing as well as data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for data transfers between controllers and processors: https://business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that allows users who use an online service to be included in a pseudonymous remarketing list, allowing users to be shown ads on other online services based on their visit to the online service. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF); Further information: Types of processing as well as data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for data transfers between controllers and processors: https://business.safety.google/adscontrollerterms.
- Enhanced Conversions for Google Ads: When customers click on our Google ads and then use the advertised service (so-called “conversion”), the data entered by the user, such as email address, name, home address, or phone number, may be transmitted to Google. The hash values are then matched with existing Google accounts of the users to better evaluate and improve the interaction of the users with the ads (e.g., clicks or views) and thus their performance; Legal bases: Consent (Art. 6(1) p. 1 lit. a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
- LinkedIn Insights Tag: Code that is loaded when a user visits our online offering and tracks the user’s behavior and conversions, storing them in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: Consent (Art. 6(1) p. 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; Basis for data transfer to a third country: Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Presence in Social Networks (Social Media)
We maintain online presences within social networks and process data of users in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, the enforcement of the users’ rights could be made more difficult.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Even in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.
- Types of data processed: Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Contact requests and communication; Feedback (e.g., collecting feedback via online form); Marketing.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “Fanpage”). 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/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information,” Facebook also collects and uses information to provide analytics services, known as “Page Insights,” to Page operators to help them understand how people interact with their Pages and with 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 in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of the data subject (i.e., users can, for example, provide information or make deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further information: Joint controllership agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company located in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular includes the transfer of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 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; Basis for data transfer to a third country: Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR). Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF). Opt-out option: https://adssettings.google.com/authenticated.
Plugins and Embedded Functions and Content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos, or social media buttons as well as posts (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers can 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 analyze 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, time of visit, and other information about the use of our online offering, as well as being linked to such information from other sources.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); Inventory data (e.g., names, addresses); Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness.
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF). Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for display of advertisements: https://adssettings.google.com/authenticated.
Management, Organization, and Auxiliary Tools
We use services, platforms, and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning, and providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of third-party providers. Various data may be affected by this, which we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on processes, contracts, other processes, and their content.
If users are referred to the third-party providers or their software or platforms in the course of communication, business, or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
- Types of data processed: Content data (e.g., entries in online forms); Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Communication partners; Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service; Office and organizational procedures; Reach measurement (e.g., access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
- Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR).
Further notes on processing procedures, methods, and services:
- HubSpot: Social media publishing, reporting (e.g., traffic sources, access numbers, web analytics), contact management (e.g., contact forms, direct communication, and user segmentation), landing pages; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal bases: Legitimate interests (Art. 6(1) p. 1 lit. f) GDPR); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis for data transfer to a third country: EU-US Data Privacy Framework (DPF), Standard contractual clauses (https://legal.hubspot.com/dpa).
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperative action (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.