Privacy Policy

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of 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: 1. November 2022

Table of contents

• Introduction
• Responsible
• Overview of the processing
• Relevant legal bases
• Security measures
• Transmission of personal data
• Data processing in third countries
• Data deletion
• Use of cookies
• Business services
• Providers and services used in the course of business
• Provision of the online offer and web hosting
• Blogs and publication media
• Contact and enquiry management
• Video conferencing, online meetings, webinars and screen sharing
• Cloud services
• Newsletter and electronic notifications
• Web analysis, monitoring and optimisation
• Online marketing
• Affiliate programmes and affiliate links
• Presence in social networks (social media)
• Plugins and embedded functions and content
• Management, organisation and auxiliary tools
• Amendment and update of the privacy policy
• Rights of the data subjects
• Definitions of terms

Responsible

Malte Niepel
Schanzenstr. 12b
20357 Hamburg

Authorised representatives:

Malte Niepel
Sergey Zelenov

E-mail address:

contact@recova.ai

Overview of the processing

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

Types of data processed

• Inventory data.
• Payment details.
• Location data.
• Contact details.
• Content data.
• Contract data.
• Usage data.
• Meta/communication data.
• Contact information (Facebook).
• Event data (Facebook).

Categories of persons concerned

• Customers.
• Employees.
• Interested parties.
• Communication partner.
• Users.
• Business and contractual partners.

Purposes of the processing

• Provision of contractual services and customer service.
• Contact requests and communication.
• Safety measures.
• Direct marketing.
• Reach measurement.
• Tracking.
• Office and organisational procedures.
• Conversion measurement.
• Click tracking.
• Target group formation.
• Affiliate tracking.
• Managing and responding to enquiries.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Target group formation.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal basis 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 domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

• Consent (Art. 6 para. 1 sent. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
• Contract performance and pre-contractual enquiries (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
• Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, 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). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.

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 access to, entry into, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

TLS encryption (https): In order to protect your data transmitted via our online offer, we use TLS encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Transfer of data within the organisation: We may transfer or provide access to personal data to other entities within our organisation. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or is made where it is necessary for the performance of our contract-related obligations or where there is consent from the data subjects or legal permission.

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, bodies or companies, this is only 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 recognised 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 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

As part of our privacy notices, we may provide users with further information on the deletion and retention of data specific to the processing operation.

Use of cookies

Cookies are small text files or other memory 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, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process the cookies in the course of this data protection declaration 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 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 app).
• 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 to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Cookie settings/ objection option:

To opt-in and -out to certain cookies see our cookie policy.

Further guidance on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able 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.
• Complianz: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/; Further information: An individual user ID, language as well as types of consents and the time of their submission are stored on the server side and in the cookie on the users’ device.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, 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, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall begin at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual accounts or the management report was drawn up, the commercial or business letter was received or sent or the accounting document was created, furthermore the recording was made or the other documents were created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms 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. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category).
• Affected persons: Interested parties; business and contractual partners.
• Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organisational procedures; administration and response to requests.
• Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• 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”) in order to be able to provide our contractual services to them and on the basis of legitimate interests in order to be able to guarantee the security of our offer and to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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; legal basis: contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO).

Providers and services used in the course of business

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

• Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of contract, term, 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 organisational procedures.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• sevDesk: Online software for invoicing, accounting, banking and tax filing with receipt storage; Service provider: sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); 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 users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• 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; provision of contractual services and customer service.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.The server log files may be used for security purposes, for example, to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilisation and stability; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
• Amazon Web Services (AWS): Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://aws.amazon.com/de/; Privacy policy: https://aws.amazon.com/de/privacy/; Order processing contract: https://aws.amazon.com/de/compliance/gdpr-center/; Standard contractual clauses (ensuring level of data protection for processing in third countries): Inclusion in the order processing contract.
• IONOS by 1&1: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; Order processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/?utm_source=search&utm_medium=global&utm_term=Auft&utm_campaign=HELP_CENTER&utm_content=/hilfe/.

Blogs and publication media

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

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• 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; security measures; administration and response to enquiries.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.Furthermore, we reserve the right, based on our legitimate interests, to process the information of users for the purpose of spam detection.On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple voting.The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Contact and enquiry management

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

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Affected persons: Communication partner.
• Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• HubSpot: Customer management as well as process and sales support with personalised customer care with multi-channel communication, i.e. management of customer enquiries from different channels as well as with analysis and feedback functions; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.hubspot.com/dpa.

• Leadinfo: We use the lead generation service of Leadinfo B.V., Rotterdam, Netherlands. This recognizes visits from companies to our website based on IP addresses and shows us publicly available information, such as company names or addresses. In addition, Leadinfo sets two first-party cookies to evaluate user behavior on our website and processes domains from form entries (e.g. “leadinfo.com”) in order to correlate IP addresses with companies and improve the services. Further information can be found at www.leadinfo.com. On this page: www.leadinfo.com/en/opt-out you have an opt-out option. If you opt out, your data will no longer be collected by Leadinfo.”

  Translated with DeepL.com (free version)

Video conferencing, 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 selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. 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 on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to 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 and select the optimal security and data protection 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 videoconference (e.g. by notifying fellow participants, locking doors and using the function to make the background unrecognisable, if technically possible). Links to the conference rooms as well as access data, may not be passed on to unauthorised third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in participant lists, in the case of processing of conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services).
• Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organisational procedures.
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Hangouts / Meet: Messenger and conferencing software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://hangouts.google.com/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause.

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this data protection declaration. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.

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

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• 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 organisational procedures; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
• Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• 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 p. 1 lit. f) DSGVO); Website: https://workspace.google.com/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause; Further information: https://cloud.google.com/privacy.

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further details if these are required for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail 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. Changes to your data stored with the dispatch service provider are also logged.

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

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, promotions and offers.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
• Data subjects: Communication partners; 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 (measurement of the effectiveness of marketing measures); profiles with user-related information (creation of user profiles).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Possibility of objection (opt-out): 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 given above, preferably e-mail, for this purpose.

Further guidance on processing operations, procedures and services:

• Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve us to recognise 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 the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are based on the consent of the users. Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
• Google Analytics: Measurement of the success of email campaigns and creation of user profiles with a storage period of up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).
• HubSpot: Email marketing platform; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.hubspot.com/dpa.

Web analysis, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed 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. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, 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 purpose of the respective procedures.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles); tracking (e.g. interest/behaviour-related profiling, use of cookies); provision of our online offer and user-friendliness.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Analytics: web analysis, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “Content”) based on users’ potential interests and measuring its 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. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope 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 on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods 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 analyse 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: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Event data (Facebook) (“Event data” is data that can be transmitted, e.g. via Facebook Pixel (via apps or in other ways) by us to Facebook and relates to persons or their actions; The data includes e.g.. Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data are deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account); 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 for the purpose of forming Custom Audiences; After matching for the purpose of forming target groups, the contact information is deleted).
• 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/behaviour-related profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiling with user-related information (creation of user profiles); target group formation (determination of target groups relevant for marketing purposes or other output of content); provision of our online offer and user friendliness; click tracking.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the options for objection (so-called “opt-out”) given to the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.

Further guidance on processing operations, procedures and services:

• Facebook pixel and target group formation (Custom Audiences): With the help of the Facebook pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook Pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Further information: Event data of users, i.e. behavioural and interest data, are processed for the purposes of targeted advertising and audience building on the basis of the Joint Responsibility Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Shared 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 data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of 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.).
• Facebook – Audience creation via data upload: Creation of target groups for marketing purposes – We transmit contact information (names, e-mail addresses and telephone numbers) in list form to Facebook for the purpose of creating target groups (so-called “Custom Audiences”) for the display of content and advertising information oriented to the presumed interests of the users. The transmission and comparison with data available at Facebook is not carried out 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 for the purpose of forming target groups, the contact information is deleted. Contact information is processed on the basis of an order processing agreement with Meta Platforms Ireland Limited (“Data Processing Terms and Conditions”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms and Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, 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). Further information on the processing of contact information can be found in the “Terms of Use for Custom Audiences with Customer List”, https://www.facebook.com/legal/terms/customaudience; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
• Google Ads and conversion measurement: We use the online marketing procedure “Google Ads” to place ads in the Google 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 ads (so-called “conversion”). We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag”. However, we ourselves do not receive any information with which users can be identified; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
• Enhanced conversions for Google Ads: When customers click on our Google ads and subsequently use the advertised service (so-called “conversion”), the data entered by the user, such as the email address, name, residential address or telephone number, may be transmitted to Google. The hash values are then matched with existing Google accounts of the users in order to better evaluate and improve the interaction of the users with the advertisements (e.g. clicks or views) and thus their performance; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); website: https://support.google.com/google-ads/answer/9888656.
• Instagram ads: Placement of ads within the Instagram platform and evaluation of the ad results; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy; Opt-out: We refer to the data protection and advertising settings in the user’s profile on the Instagram platform as well as Instagram’s consent procedure and Instagram’s contact options for exercising access and other data subject rights in Instagram’s privacy policy; Further information: Event data of users, i.e. behavioural and interest data, is processed for the purposes of targeted advertising and audience building on the basis of the Joint Accountability Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Shared 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 data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of 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: Insights Tag / conversion measurement; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy: https://www.linkedin.com/legal/cookie_policy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• UTM parameter: Analysis of sources and user actions based on an extension of web addresses referring 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 on 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, for example, check our visibility on the internet or the effectiveness of our campaigns; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Affiliate programmes and affiliate links

We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers in our online offer (collectively referred to as “affiliate links”). If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, “Commission”).

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

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

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

• Types of data processed: Contractual data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Affiliate tracking.
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• AWIN Affiliate Program (formerly Zanox and Affilinet): Affiliate marketing partner programme; Service provider: AWIN AG, Eichhornstr. 3, 10785 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.awin.com/de; Privacy policy: https://www.awin.com/de/rechtliches/privacy-policy-DACH.
• Belboon partner programme: Affiliate marketing partner programme; Service provider: belboon GmbH, Weinmeisterstr. 12-14, 10178 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: www.belboon.de; Privacy policy: https://www.belboon.com/de/ueber-uns/datenschutz/.
• Commission Junction – Affiliate Programme: Affiliate Marketing Partner Programme; Service Provider: Conversant Europe Limited, 1st Floor, 40, Dukes Place London, EC3A 7NH, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.cj.com/de; Privacy policy: https://www.conversantmedia.eu/de/legal/datenschutzerklaerung.
• Tradedoubler affiliate programme: Affiliate marketing affiliate programme; Service provider: Tradedoubler GmbH, Herzog-Wilhelm-Straße 26, 80331 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.tradedoubler.com/de; Privacy policy: https://www.tradedoubler.com/de/privacy-policy.
• TradeTracker partner programme: Affiliate marketing partner programme; Service provider: TradeTracker Deutschland GmbH, Uhlandstraße 26, 22087 Hamburg, Germany (further addresses: https://tradetracker.com/contact/); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://tradetracker.com/de; Privacy policy: https://tradetracker.com/de/privacy-policy.
• WEBGAINS partner programme: Affiliate marketing partner programme; Service provider: ad pepper media GmbH, FrankenStraße 150C, FrankenCampus 90461, Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.webgains.com/public/de; Privacy policy: https://www.webgains.com/public/de/datenschutzerklaerung.

Presence in social networks (social media)

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

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

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour 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 behaviour 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 options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• 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 basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
• Facebook pages: Profiles within the Facebook social network – 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 (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “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 under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information”, 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 fulfil the data subject rights (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 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, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint accountability 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, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the US (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
• LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
• Vimeo: Social network and video platform; 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 p. 1 lit. f) DSGVO); Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy.
• 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 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Opt-out: https://adssettings.google.com/authenticated.
• Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer 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 city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, 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 endeavour 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 analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online 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 data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); location data (information on the geographical position of a device or a person).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: provision of our online offer and user-friendliness; profiles with user-related information (creation of user profiles); marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The data processed may include, in particular, IP addresses and user location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy.
• LinkedIn plugins and content: LinkedIn plugins and content- This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Twitter plugins and content: Twitter plugins and buttons – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Twitter; Service Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent Company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://twitter.com/de; Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
• YouTube videos: Video content; YouTube videos are integrated via a special domain (recognisable by the component “youtube-nocookie”) in the so-called “extended data protection mode”, whereby no cookies on user activities are collected in order to personalise the video playback. Nevertheless, information on the user’s interaction with the video (e.g. remembering the last playback point) may be stored; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy.
• Xing plugins and buttons: Xing plugins and buttons – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within Xing; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
• Vimeo: Video content; 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 p. 1 lit. f) DSGVO); Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Opt-out: We would like to point out that Vimeo may use Google Analytics and refer to the data protection declaration (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or the Google settings for data use for marketing purposes (https://adssettings.google.com/).

Management, organisation and auxiliary tools

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

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

If users are referred to 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 optimisation 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 data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication; provision of contractual services and customer service; office and organisational procedures; range measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Asana: Project management – organisation and management of teams, groups, workflows, projects and processes; Service provider: Asana, Inc, 1550 Bryant Street, Suite 200, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://asana.com; Privacy policy: https://asana.com/de/terms#privacy-policy; Order processing agreement: https://asana.com/de/terms#data-processing; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://asana.com/de/terms#data-processing.
• HubSpot: Social media publishing, reporting (e.g. traffic sources, access figures, web analysis), 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 basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.hubspot.com/dpa.
• Miro: Online whiteboard and collaboration platform; Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite 1100, San Francisco, California 94105, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://miro.com/; Privacy policy: https://miro.com/legal/privacy-policy/.
• Trello: Project management tool; Service provider: Trello Inc, 55 Broadway New York, NY 10006, USA; parent company: Atlassian Inc (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://trello.com/; Privacy Policy: https://trello.com/privacy; Standard Contractual Clauses (ensuring level of data protection for processing in third countries): Inclusion in the order processing contract; Further information: Data Transfer Impact Assessment: https://www.atlassian.com/legal/data-transfer-impact-assessment.
• WeTransfer: Transfer of files via the internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://wetransfer.com; Privacy policy: https://wetransfer.com/legal/privacy.

Amendment and update of the privacy policy

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

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are 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 of revocation for consents: You have the right to revoke any consent you have given at any time.
• Right of access: You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
• Right to data portability: You have the right to receive data relating to 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 transferred to another controller.
• Complaint to the supervisory authority: In accordance with the law 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 where you usually reside, the supervisory authority of 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.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

• Affiliate tracking: In the context of affiliate tracking, links with the help of which the linking websites refer users to websites with product or other offers are logged. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as, for example, advertising material ID, partner ID and categorisations.
• Click tracking: Click tracking allows us to keep track of users’ movements within an entire online experience. Since the results of these tests are more accurate if the interaction of the users 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.
• 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 user’s devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
• 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 the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
• Tracking: We speak of “tracking” when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information with regard to the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
• Controller: The term “controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
• Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
• Target group formation: We speak of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he or she viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) 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 generally used to create custom audiences and lookalike audiences.