Privacy Policy
Preamble
With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").
The terms used are not gender-specific.
Last Update: 2. July 2026
Table of contents
- Preamble
- Controller
- Contact information of the Data Protection Officer
- Overview of processing operations
- Relevant legal bases
- Security Precautions
- Transmission of Personal Data
- International data transfers
- General Information on Data Retention and Deletion
- Rights of Data Subjects
- Business services
- Business processes and operations
- Providers and services used in the course of business
- Provision of online services and web hosting
- Use of Cookies
- Processing of data in the context of applications (apps)
- Purchase of applications via Appstores
- Registration, Login and User Account
- Contact and Inquiry Management
- Communication via Messenger
- Artificial Intelligence (AI)
- Video Conferences, Online Meetings, Webinars and Screen-Sharing
- Cloud Services
- Newsletter and Electronic Communications
- Commercial communication by E-Mail, Postal Mail, Fax or Telephone
- Surveys and Questionnaires
- Web Analysis, Monitoring and Optimization
- Online Marketing
- Profiles in Social Networks (Social Media)
- Plugins and embedded functions and content
- Job Application Process
- Changes and Updates
- Terminology and Definitions
Controller
HEAD acoustics GmbH, Ebertstr. 30a, 52134 Herzogenrath, Germany
E-mail address: info@head-acoustics.com
Legal Notice: www.head-acoustics.com/legal-notices
Contact information of the Data Protection Officer
datenschutz@head-acoustics.com
Overview of processing operations
The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.
Categories of Processed Data
- Inventory data.
- Payment Data.
- Location data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Job applicant details.
- Images and/ or video recordings.
- Audio recordings.
- Location history and mobility profiles.
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Prospective customers.
- Communication partner.
- Users.
- Job applicants.
- Business and contractual partners.
- Participants.
- Persons depicted.
- Third parties.
- Customers.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Web Analytics.
- Targeting.
- Office and organisational procedures.
- Remarketing.
- Conversion tracking.
- Clicktracking.
- Affiliate Tracking.
- A/B Tests.
- Organisational and Administrative Procedures.
- Job Application Process.
- Feedback.
- Polls and Questionnaires.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and usability.
- Information technology infrastructure.
- Financial and Payment Management.
- Public relations.
- Sales promotion.
- Business processes and management procedures.
- Artificial Intelligence (AI).
Relevant legal bases
Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate Interests (Article 6 (1) (f) GDPR) - the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.
- Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR) - If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states may apply.
Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as "Swiss DPA"). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).
Reference to the applicability of the GDPR and the Swiss DPA: This privacy policy is intended to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). Where references are made to concepts such as the processing of personal data, legitimate interests, or special categories of data, these references are to be understood in accordance with the applicable data protection laws. Within the scope of application of the Swiss FADP, the legal interpretation of these terms is determined exclusively by Swiss law.
Security Precautions
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.
Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information that is transferred between the website or app and the user's browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being securely and encryptedly transmitted.
Transmission of Personal Data
In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.
Data Transmission within the Group of Companies: Data transfer within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to it. This data sharing is based on our legitimate business and economic interests. By this, we mean, for example, the improvement of business processes, ensuring efficient and effective internal communication, the optimal use of our human and technological resources, as well as the ability to make informed business decisions. In certain cases, data sharing may also be necessary to fulfil our contractual obligations or may be based on the consent of the data subjects or a legal permission.
International data transfers
Data Processing in Third Countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies (which becomes apparent either from the postal address of the respective provider or when explicitly mentioned in the privacy policy regarding data transfer to third countries), this is always done in accordance with legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by the EU Commission's adequacy decision of July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the EU Commission's requirements and establish contractual obligations to protect your data.
This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Contractual Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and if Standard Contractual Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce's website at www.dataprivacyframework.gov.
For data transfers to other third countries, appropriate safeguards apply, particularly Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.
Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DPA). If the Federal Council has not determined an adequate level of protection (list of states: www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by Switzerland's adequacy decision of September 15, 2024. Additionally, we have concluded Standard Data Protection Clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations to protect your data.
This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Data Protection Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Data Protection Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and if Standard Data Protection Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce's website at www.dataprivacyframework.gov.
For data transfers to other third countries, appropriate safeguards apply, including international agreements, specific guarantees, FDPIC-approved Standard Data Protection Clauses, or internal company data protection regulations previously recognized by the FDPIC or a competent data protection authority of another country.
Under Art. 16 of the Swiss DPA, exceptions can be made for the disclosure of data abroad if certain conditions are met, including the consent of the affected person, contract execution, public interest, protection of life or physical integrity, publicly made data, or data from a legally provided register. Such disclosures always comply with the legal requirements.
We will inform you which of our service providers are certified under the Data Privacy Framework as part of our privacy notices.
General Information on Data Retention and Deletion
We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or special interests require a longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data specifically applicable to certain processing processes.
In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.
Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.
Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:
- 10 Years - Fiscal Code/Commercial Code - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
- 8 years - Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB))
- 6 Years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
- 3 Years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).
Data Retention and Deletion: The following general retention and archiving periods apply under Swiss law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
- 10 years - Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries based on previous business experiences and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Articles 127, 130 OR). Claims for rent, lease, and interest on capital, as well as other periodic services, for the delivery of food, for board and lodging, for innkeeper debts, as well as for craftsmanship, small-scale sales of goods, medical care, professional services by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees, expire after five years (Article 128 OR).
Start of the period at the end of the year: If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.
Rights of Data Subjects
Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right of withdrawal for consents: You have the right to revoke consents at any time.
- Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
- Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
- Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission 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 habitually 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.
Rights of the data subjects under the Swiss DPA:
As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:
- Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
- Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.
Business services
We process personal data of our contractual and business partners, such as Customers, Clients, Prospective Customers, Suppliers and other cooperation partners (collectively referred to as "Contractual Partners"), for the initiation, execution and settlement of contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures carried out at the request of the parties and communication related to the respective contractual relationship.
Processing serves in particular to fulfil our primary and secondary contractual obligations. This includes providing the agreed services, any update and information obligations, handling warranty claims and other service disruptions, processing revocations, terminations of continuing obligations, reversals, refunds as well as handling other contract-related statements and enquiries. Both one-off contracts and ongoing contractual relationships are covered.
In particular, we process master data such as name, address and where applicable company name; contact details such as email address and telephone number; contract and service data such as subject matter of the contract, duration of the contract, order or transaction number; usage and performance data; payment and billing data; as well as communication content and histories. Where necessary, we also process data disclosed or transmitted to us in connection with carrying out an assignment.
Furthermore, we process the data to safeguard our rights and to comply with legal obligations. This particularly includes commercial law and tax law retention requirements, documentation obligations as well as possible duties of proof or accountability. Processing may also take place on the basis of our legitimate interests in proper business management, internal administration, risk control and IT security as well as in protecting our business operations and Contractual Partners against misuse or threats to data, secrets or other legal assets. This may include involving external Service Providers such as IT- and telecommunications providers, transport- or logistics companies, payment service providers, banks, tax advisors or legal advisors or other vicarious agents insofar as this is required for executing contracts or fulfilling legal obligations.
Personal data will only be passed on to third parties if this is necessary for fulfilling a contract or conducting pre-contractual measures; safeguarding legitimate interests; or complying with statutory obligations. We will inform you separately within this privacy policy about any further processing activities—particularly those undertaken for marketing purposes.
Which specific data is required in each case will be communicated to Contractual Partners during collection—for example by appropriate labelling in online forms or during personal contact.
Data will be deleted once it is no longer required for these purposes provided there are no statutory retention requirements preventing deletion. Statutory retention periods—particularly under commercial- or tax law—may require longer storage periods. Data transmitted in connection with a specific assignment will be deleted after completion of that assignment and expiration of any applicable retention period unless further statutory or contractual storage obligations exist.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Acoustics Tutorial: To download our free Acoustics Tutorial the user needs to request login data, which we will provide via e-mail. In case the email address provided by the user is not a private address we save these data in our CRM-system and we or our local subsidiary or local distributor will use it to contact you, which is why your data will be transferred to them. Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Events (Taking photos and videos): At events organized by us, we take photos and videos to subsequently publish them on our website and social media. We take care here to take only photos and videos of the overall event and group photos. Photographs taken from a closer distance (e.g. portrait photos) are only taken if the person to be recognized has given at least implied consent to the photographer.
• Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). - Whitepaper: We offer the user the opportunity to receive a whitepaper. The user will only receive one e-mail containing the download link. The user will receive no further e-mails.
In case you have given us the permission to contact you, we will contact you via e-mail e.g. to ask for your interest in our products and services.
• Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO). - Online shop, order forms, e-commerce and fulfilment of services: We process our customers' data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and provision, delivery, or execution. If necessary for the execution of an order, we employ service providers, particularly postal services, freight carriers, and shipping companies to carry out delivery or execution for our customers. For processing payment transactions, we use the services of banks and payment service providers. The necessary information is marked as such within the ordering or comparable acquisition process and includes the details required for delivery or provision and billing as well as contact information to facilitate any necessary consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Provision of software and platforms: We process the data of our Customers and users (hereinafter collectively referred to as "users") in order 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 context of the conclusion of the agreement, order or comparable contract and include the details required for the provision of services and invoicing as well as contact information in order to be able to hold any further consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Provision of mobile applications: We process the data of our Customers and users (hereinafter collectively referred to as "users") in order to provide them with our contractual services within the scope of the provision and operation of our mobile applications, as well as to ensure the security, availability, and further development of our online services. The required information is identified as such within the context of order placement, conclusion of a contract or similar agreements, and includes the details necessary for service provision and billing, as well as contact information in order to enable any necessary communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Consulting: We process the data of our clients as well as prospects and other commissioning parties or contractual partners (collectively referred to as "clients") in order to be able to provide our services to them. The processes that are part of and for the purposes of consulting include: contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, capturing and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, invoicing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the nature, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship with the client.
If it is necessary for our contract performance, for the protection of vital interests or legally required, or if there is consent from the clients, we disclose or transmit client data in compliance with professional legal requirements to third parties or agents such as authorities, subcontractors or in the field of IT, office or similar services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). - Online Courses and Online Training: We process the data of participants in our online courses and training sessions (collectively referred to as "participants") in order to be able to provide them with our course and training services. The data processed, the type, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services utilized, as well as personal preferences and results of the participants, insofar as they are part of our service offering. Processing forms also include performance evaluation and the evaluation of our services as well as those of the course and training instructors. Additionally, depending on the equipment and structure of the respective courses or learning content, further processing operations may be implemented, such as attendance tracking for documenting participation, progress monitoring for measuring and analyzing learning progress by collecting exam and test results, and analyzing interactions on learning platforms, such as forum posts and assignment submissions; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Project and Development Services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the selected services or works as well as associated activities and to pay for and make available such services or works or to perform such services or works.
The required information is indicated as such within the framework of the conclusion of the agreement, order or equivalent contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we gain access to the information of end customers, employees or other persons, we process it in accordance with the legal and contractual requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). - Technical and Engineering services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the selected services or works as well as associated activities and to pay for and make available such services or works or to perform such services or works.
The required information is indicated as such within the framework of the conclusion of the agreement, order or equivalent contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we gain access to the information of end customers, employees or other persons, we process it in accordance with the legal and contractual requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). - Event Management: We process the data of the participants of the events, events and similar activities offered or organized by us (hereinafter uniformly referred to as "participants" and "events") in order to enable them to participate in the events and to make use of the services or actions associated with their participation.
Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the framework of disclosure (e.g. for thematically oriented events or serves health care, security or is done with the consent of the data subjects).
The necessary information is identified as such in the context of the conclusion of the agreement, booking or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any enquiries. Insofar as we gain access to information of end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Business processes and operations
Personal data of service recipients and clients - including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties - are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.
The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.
Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or access times.).
- Data subjects: Service recipients and clients; Customers; Prospective customers; Business and contractual partners; Communication partner (Recipients of e-mails, letters, etc.); Third parties. Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Security measures; Provision of our online services and usability; Communication; Marketing; Sales promotion; Public relations; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).
Further information on processing methods, procedures and services used:
- Video Surveillance: The monitoring of our premises serves the security of the company, the protection of property, and the safety of employees. For this purpose, various processes and data processing steps are carried out.
Initially, surveillance cameras are installed and positioned after a site analysis to identify security-relevant areas. Following this, cameras are installed at suitable locations, with signs or warnings provided to indicate surveillance.
Regular checks are conducted to ensure that the cameras are functioning properly and no failures occur that could compromise security.
The actual monitoring is done through video recordings to capture and document potential security incidents. These recordings are then evaluated and analysed to identify suspicious activities and respond appropriately.
All recorded video data is archived in accordance with legal regulations and privacy policies. It should be noted that the data must be deleted after a maximum of 96 hours unless there is a specific suspicion requiring longer retention to investigate the circumstances or ensure the company's security.
Additionally, measures for data deletion are implemented once retention periods have expired or when the data is no longer needed, to comply with privacy policies and protect employees' privacy. Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). - Customer Management and Customer Relationship Management (CRM): Processes required in the context of customer management and Customer Relationship Management (CRM) include customer acquisition in compliance with data protection regulations, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, management of CRM systems, secure account management, customer segmentation and targeting; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Customer Account: Customers can create an account within our online offer (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, customers will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent registration and use of the customer account, we store the IP addresses of the contractual partners along with the access times, in order to be able to prove the registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the customers' responsibility to back up their data when terminating the customer Account; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Purchasing: Processes required in the procurement of goods, raw materials, or services (e.g., selection and evaluation of suppliers, price negotiations, placement and monitoring of orders, inspection and control of deliveries, invoice verification, management of orders, inventory management, creation and maintenance of purchasing policies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Sales: Procedures required for the planning, implementation, and control of measures for marketing and selling products or services (e.g., customer acquisition, preparation and tracking of offers, order processing, customer consultation and support, sales promotion, product training, sales controlling and analysis, management of distribution channels); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Economic Analyses and Market Research: To fulfill business management purposes and to identify market trends, desires of contractual partners, and users, the present data regarding business transactions, contracts, inquiries, etc., are analyzed. The group of affected individuals may include contractual partners, interested parties, customers, visitors, and users of the online service managed by the responsible entity. The execution of these analyses serves the purposes of business economic evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, profiles of registered users along with their information on services utilized are considered. The analyses are exclusively for the use of the responsible entity and are not disclosed externally unless they pertain to anonymous analyses with aggregated, thus anonymized values. Moreover, user privacy is accounted for; data is processed for analysis purposes in as pseudonymized a manner as possible and anonymized when feasible (e.g., as aggregated data); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Guest Wi-Fi: Procedures required for the setup, operation, maintenance, and monitoring of a wireless network for guests (e.g., installation and configuration of Wi-Fi access points, creation and management of guest access, monitoring of network connection, ensuring network security, resolving connection issues, updating network software, compliance with data protection regulations); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Providers and services used in the course of business
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, "services") in compliance with legal requirements. Their use is based on our interests in the proper, legal and economic management of our business operations and internal organization.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Images and/ or video recordings (e.g. photographs or video recordings of a person). Audio recordings.
- Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners; Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Participants.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Provision of our online services and usability; Direct marketing (e.g. by e-mail or postal); Security measures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Geofabrik: We use Tileserver (map tiles) to display maps; Service provider: Geofabrik GmbH, Amalienstraße 44, 76133 Karlsruhe; Website: www.geofabrik.de. Privacy Policy: www.geofabrik.de/de/geofabrik/imprint.html.
- Microsoft Teams: Utilisation for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration functions are used; name, business contact details, work profile, participation as well as content (audio/video, speech, chat, files, speech transcription) are processed for purposes and interests in efficiency and productivity improvements, cost efficiency, flexibility, mobility, enhanced communication, IT security, use of a central platform as well as business operations by Microsoft. Audio signals are generally not stored unless recording is enabled. Meeting and conference recordings are stored by default for 90 days unless a different duration is specified. Chat and file contents are stored according to the policies determined by the administrator or user; there is no preset automatic deletion. Channels must be renewed every 180 days; otherwise contents are deleted. Additionally processed are system-generated logs, diagnostic and metadata as well as diagnostic data collected for product stability, security and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com/en-us/microsoft-teams/; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Microsoft Teams: Utilisation for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration functions are used; name, business contact details, work profile, participation as well as content (audio/video, speech, chat, files, speech transcription) are processed for purposes and interests in efficiency and productivity improvements, cost efficiency, flexibility, mobility, enhanced communication, IT security, use of a central platform as well as business operations by Microsoft. Audio signals are generally not stored unless recording is enabled. Meeting and conference recordings are stored by default for 90 days unless a different duration is specified. Chat and file contents are stored according to the policies determined by the administrator or user; there is no preset automatic deletion. Channels must be renewed every 180 days; otherwise contents are deleted. Additionally processed are system-generated logs, diagnostic and metadata as well as diagnostic data collected for product stability, security and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com/de-de/microsoft-365; Privacy Policy: www.microsoft.com/en-GB/privacy/privacystatement, Security information: www.microsoft.com/en-GB/trust-center. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Adobe Sign: Electronic signature of documents, sending documents for signature, tracking the status of documents, storage of signed documents
; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.adobe.com/sign.html. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF). - Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, as well as the use of system-generated log, diagnostic, and metadata for contract execution by Microsoft. The data processed includes contact details (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), as well as log and metadata. The processing is carried out for purposes of improving efficiency and productivity, cost efficiency, flexibility, mobility, enhanced communication, integration of Microsoft services, IT security and business operations of Microsoft. Data retention is determined by the respective document and company policies: up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: microsoft.com; Privacy Policy: privacy.microsoft.com/de-de/privacystatement, Security information: www.microsoft.com/de-de/trustcenter; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Provision of online services and web hosting
We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
- Data subjects: Users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)). Security measures.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Provision of online services on own/ dedicated server hardware: For the provision of our online services, we use server hardware operated by us as well as, the storage space, computing capacity and software associated with it; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
- Content-Delivery-Network: We use a so-called "Content Delivery Network" (CDN). A CDN is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Amazon Web Services (AWS): Services in the field of the provision of 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, 1855, Luxembourg; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: aws.amazon.com; Privacy Policy: aws.amazon.com/privacy/; Data Processing Agreement: aws.amazon.com/compliance/gdpr-center/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://aws.amazon.com/de/compliance/gdpr-center/), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://aws.amazon.com/de/compliance/gdpr-center/).
- STRATO: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: STRATO AG, Pascalstraße 10,10587 Berlin, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.strato.de; Privacy Policy: www.strato.de/datenschutz. Data Processing Agreement: Provided by the service provider.
- Amazon CloudFront: Content-Delivery-Network (CDN) - service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: aws.amazon.com/cloudfront/; Privacy Policy: aws.amazon.com/privacy/; Data Processing Agreement: aws.amazon.com/compliance/gdpr-center/. Basis for third-country transfers: EEA - Standard Contractual Clauses (Provided by the service provider), Switzerland - Standard Contractual Clauses (Provided by the service provider).
Use of Cookies
The term "cookies" refers to functions that store information on users' devices and read it from them. Cookies can also be used for different purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users' consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.
Information on legal data protection bases: Whether we process personal data using cookies depends on users' consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as outlined in this section and in the context of the respective services and procedures.
Storage duration: The following types of cookies are distinguished based on their storage duration:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user revisits a website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that these are permanent and may have a storage duration of up to two years.
General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to the processing according to legal regulations, including through the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
- Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users' consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users' devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Usercentrics: Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users' devices as well as their processing; Service provider: Usercentrics GmbH, Sendlinger Strasse 7, 80331 Munich, Germany; Website: usercentrics.com. Privacy Policy: usercentrics.com/privacy-policy/.
Processing of data in the context of applications (apps)
We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.
Legal basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings; Location data (Information on the geographical position of a device or person). Location history and mobility profiles (Collection of location data and position changes over a certain period of time).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Commercial use: We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to develop it further. The required details are identified as such within the scope of the conclusion of a contract for the use of the application, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Storage of the universally unique identifier (UUID): The application stores a so-called Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality of the application and storing the user's settings. This identifier is generated when the application is installed (but is not connected to the device, so no device ID in this sense), remains stored between the start of the application and its updates and is deleted when users remove the application from their device.
- Storage of an own unique identifier: In order to provide the application and ensure its functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no clear data such as names are used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated during the installation of the application, remains stored between the start of the application and its updates and is deleted when users remove the application from the device.
- Device authorizations for access to functions and data: The use of certain functions of our application may require access to the camera and the stored recordings of the users. By default, these authorizations must be granted by the user and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorizations can affect the functionality of our application.
- Accessing the camera and stored recordings: In the course of using our application, image and/or video recordings (whereby audio recordings are also included) of the users (and of other persons captured by the recordings) are processed by accessing the camera functions or stored recordings. Access to the camera functions or stored recordings requires an authorization by the user that can be withdrawn at any time. The processing of the image and/or video recordings serves only to provide the respective functionality of our application, according to its description to the users or the typical and expectable functionality of the application.
- Use of the microphone functions: The use of certain functions of our application may require access to the camera and the stored recordings of the users. By default, these authorizations must be granted by the user and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorizations can affect the functionality of our application.
- Processing of location data: Within the course of using our application, the location data collected by the device used or otherwise entered by the user are processed. The use of the location data requires an authorization of the users, which can be revoked at any time. The use of the location data serves only to provide the respective functionality of our application, according to its description to the users or its typical and expectable functionality.
- Location history and movement profiles: Based on the location data collected in the course of using our application, a location history is generated which shows the geographical movements of the devices used over a period of time (and can allow to draw conclusions about the movement profile of the users). The location history is only used to provide the respective functionality of our application, according to its description to the users, or its typical and expectable functionality.
Purchase of applications via Appstores
The purchase of our apps is done via special online platforms operated by other service providers (so-called "appstores"). In this context, the data protection notices of the respective appstores apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for webanalytics and for interest-related marketing as well as possible costs.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Apple App Store: App and software distribution platform; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.apple.com/app-store/. Privacy Policy: www.apple.com/privacy/privacy-policy/.
- Google Play: App and software distribution platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: play.google.com/store/apps. Privacy Policy: business.safety.google/privacy/.
Registration, Login and User Account
Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).
Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of information relevant to their user account, such as technical changes.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Registration with a real name: Due to the nature of our community, we ask users to use our services only with their real names. This means that the use of pseudonyms is not permitted; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Users' profiles are public: The users' profiles are not publicly visible or accessible.
- Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Contact and Inquiry Management
When contacting us (e.g. via mail, 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 to the extent necessary to respond to the contact requests and any requested measures.
- Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing and legitimate interests: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Further information on processing methods, procedures and services used:
- Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Communication via Messenger
We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.
You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.
In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed.
However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner's device used and, depending on the settings of their device, also location information (so-called metadata).
Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.
Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.
Reservation of reference to other means of communication: For your security, we kindly ask for your understanding that we may not respond to enquiries via messenger for specific reasons. This applies in situations where contract details require heightened confidentiality or a response via messenger does not meet formal requirements. In such cases, we recommend using more appropriate communication channels.
- Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing and legitimate interests: Communication. Direct marketing (e.g. by e-mail or postal).
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Microsoft Teams: Utilisation for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration functions are used; name, business contact details, work profile, participation as well as content (audio/video, speech, chat, files, speech transcription) are processed for purposes and interests in efficiency and productivity improvements, cost efficiency, flexibility, mobility, enhanced communication, IT security, use of a central platform as well as business operations by Microsoft. Audio signals are generally not stored unless recording is enabled. Meeting and conference recordings are stored by default for 90 days unless a different duration is specified. Chat and file contents are stored according to the policies determined by the administrator or user; there is no preset automatic deletion. Channels must be renewed every 180 days; otherwise contents are deleted. Additionally processed are system-generated logs, diagnostic and metadata as well as diagnostic data collected for product stability, security and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com/de-de/microsoft-365; Privacy Policy: www.microsoft.com/en-GB/privacy/privacystatement, Security information: www.microsoft.com/en-GB/trust-center. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Artificial Intelligence (AI)
We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term "AI system" as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.
When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.
To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
- Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
- Data subjects: Users (e.g. website visitors, users of online services). Third parties.
- Purposes of processing and legitimate interests: Artificial Intelligence (AI).
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information, and make predictions ("AI", meaning "Artificial Intelligence" shall be construed in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: openai.com/chatgpt/overview/; Privacy Policy: openai.com/policies/privacy-policy/. Opt-Out: privacy.openai.com/policies.
- DeepL: Translation of texts into various languages and provision of synonyms as well as context examples. Support with the correction and improvement of texts in different languages; Service provider: DeepL SE, Maarweg 165, 50825 Köln, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.deepl.com; Privacy Policy: www.deepl.com/en/privacy. Data Processing Agreement: Provided by the service provider.
- Microsoft Copilot: Microsoft Copilot: Assistance in the creation and editing of texts, spreadsheets, and presentations, data analysis, task automation, and integration into Office applications. Content data (files, conversations, metadata) as well as employee credentials (Org-ID/Entra ID) are processed for the purposes of increasing efficiency and productivity, cost efficiency, flexibility, mobility, and integration with M365. Chat histories are stored for up to 30 days; content is stored until deleted by the user. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com/en-us/microsoft-copilot/organizations; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Claude API: Service provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.anthropic.com; Privacy Policy: www.anthropic.com/legal/privacy; Data Processing Agreement: www.anthropic.com/legal/data-processing-addendum. Basis for third-country transfers: EEA - Standard Contractual Clauses (https://www.anthropic.com/legal/data-processing-addendum), Switzerland - Standard Contractual Clauses (https://www.anthropic.com/legal/data-processing-addendum).
- Google Vertex AI Platform: A cloud-based platform for building, training, deploying, and operating machine learning models. The platform provides managed services for data preparation, model training, model hosting, and model monitoring. It supports the use of pre-trained models as well as custom models via APIs (application programming interfaces). As part of the service operation, submitted input data, model artifacts, and technical metadata are processed to deliver the requested AI functionalities. Processing is carried out within the provider’s cloud infrastructure using technical and organizational measures to ensure availability, integrity, and confidentiality; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: cloud.google.com/vertex-ai; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: cloud.google.com/terms/data-processing-addendum. Basis for third-country transfers: EEA - Standard Contractual Clauses (https://cloud.google.com/terms/data-processing-addendum), Switzerland - Standard Contractual Clauses (https://cloud.google.com/terms/data-processing-addendum).
- Microsoft Azure OpenAI Service: Interface access (so-called "API") to AI-based services designed to understand and generate natural language and related inputs, analyze information, and make predictions ("AI", i.e., "Artificial Intelligence", is to be understood in the legal sense of the term as applicable). The provision of AI services includes the processing (including collection, storage, organization, and structuring) of personal data as part of a machine learning process based on natural language; conducting activities to verify or maintain the quality of the services; identifying and correcting errors that impair the existing intended functionality, as well as supporting efforts to ensure the security and integrity of the AI services; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: azure.microsoft.com/de-de/products/ai-foundry/models/openai/; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement; Data Processing Agreement: azure.microsoft.com/en-us/support/legal/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/de-de/support/legal/), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/de-de/support/legal/).
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 using the Conference Platforms and their services, we comply with the legal requirements.
Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. 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 processing for the purpose of conducting the conference, participants' Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), 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-related communication processes, 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 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 recording: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are recorded, this will be transparently communicated to the participants in advance and they will be asked - if necessary - for their consent.
Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy 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 Conference (e.g., by notifying roommates, locking doors, and using the background masking 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: Insofar as, in addition to the Conference Platforms, we also process users' data and ask users for their consent to use contents from the Conferences 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 fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing 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.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings; Log data (e.g. log files concerning logins or data retrieval or access times.); Contract data (e.g. contract object, duration, customer category). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Persons depicted; Service recipients and clients; Prospective customers. Participants.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organisational procedures. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Microsoft Teams: Utilisation for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration functions are used; name, business contact details, work profile, participation as well as content (audio/video, speech, chat, files, speech transcription) are processed for purposes and interests in efficiency and productivity improvements, cost efficiency, flexibility, mobility, enhanced communication, IT security, use of a central platform as well as business operations by Microsoft. Audio signals are generally not stored unless recording is enabled. Meeting and conference recordings are stored by default for 90 days unless a different duration is specified. Chat and file contents are stored according to the policies determined by the administrator or user; there is no preset automatic deletion. Channels must be renewed every 180 days; otherwise contents are deleted. Additionally processed are system-generated logs, diagnostic and metadata as well as diagnostic data collected for product stability, security and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com/en-us/microsoft-teams/; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- TeamViewer: Conference and communication software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.teamviewer.com/en/. Privacy Policy: www.teamviewer.com/en/privacy-notice/.
Cloud Services
We use Internet-accessible software services (so-called "cloud services", also referred to as "Software as a Service") provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).
Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.
If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users' devices for web analysis or to remember user settings (e.g. in the case of media control).
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Images and/ or video recordings (e.g. photographs or video recordings of a person). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Users (e.g. website visitors, users of online services). Third parties.
- Purposes of processing and legitimate interests: Office and organisational procedures; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)); Provision of contractual services and fulfillment of contractual obligations; Organisational and Administrative Procedures. Business processes and management procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Adobe Creative Cloud: Cloud storage, cloud infrastructure services, and cloud-based application software, among others for photo editing, video editing, graphic design, web development; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.adobe.com/creativecloud.html; Privacy Policy: www.adobe.com/privacy.html; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).
- Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, as well as the use of system-generated log, diagnostic, and metadata for contract execution by Microsoft. The data processed includes contact details (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), as well as log and metadata. The processing is carried out for purposes of improving efficiency and productivity, cost efficiency, flexibility, mobility, enhanced communication, integration of Microsoft services, IT security and business operations of Microsoft. Data retention is determined by the respective document and company policies: up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: microsoft.com; Privacy Policy: privacy.microsoft.com/de-de/privacystatement, Security information: www.microsoft.com/de-de/trustcenter; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Microsoft EU Data Boundary: Our use of Microsoft Cloud services takes place within the framework of the so-called "EU Data Boundary", which ensures that data is stored and processed within the European Union (EU) and the European Free Trade Association (EFTA).
The EU Data Boundary is a designated region where Microsoft commits to storing and processing customer data and personal data for certain online services (Microsoft 365, Azure, Dynamics 365, and the Power Platform). Companies using these services can ensure that their data remains within the EU/EFTA region. This includes both general customer data and support data generated as part of technical services. In many cases, pseudonymised data is also processed within this region.
The EU Data Boundary includes all EU countries as well as EFTA states (Liechtenstein, Iceland, Norway, and Switzerland). Microsoft operates data centres in several of these countries, including Germany, France, Ireland, the Netherlands, Sweden, Spain, and Switzerland. Additional locations may be added.
As part of operations, Microsoft automatically generates logs to ensure the security and functionality of its services. These logs mainly contain technical information but may include personal data in certain cases, such as when user actions are documented.
To protect this data, Microsoft employs techniques like encryption, masking, and tokenisation (replacing sensitive data with non-traceable strings). This ensures that Microsoft employees only see pseudonymised data without being able to directly infer individual users. Additionally, there are strict access rules and deletion deadlines for this data.
Are any transfers made outside of the EU? Microsoft has assured that transfers outside of the EU occur only in a few precisely defined cases. This may be necessary to implement global cybersecurity measures or ensure cloud service functionality. These transfers always take place under high-security standards such as encryption and pseudonymisation.
Further information on the EU Data Boundary and Microsoft's privacy measures can be found at the Microsoft EU Data Boundary Trust Center: www.microsoft.com/en-us/trust-center/privacy/european-data-boundary-eudb. - Microsoft Sharepoint: Support for collaboration through storage and access management for documents, spreadsheets, presentations, among others. Content data (files) and contact data (name, email address) are processed for purposes and out of interest in efficiency and productivity improvements, cost efficiency, flexibility, mobility, integration with M365, and enhanced collaboration. Retention is determined by the business function of the content; SharePoint pages must be renewed every 180 days; otherwise, content will be deleted. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Newsletter and Electronic Communications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users' consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to demonstrate previously given consent. The processing of these data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed. In case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions and offers.
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing and legitimate interests: Direct marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
- 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 otherwise use one of the contact options listed above, preferably e-mail.
Further information on processing methods, procedures and services used:
- Measurement of opening rates and click rates: The newsletters contain what is known as a "web beacon", i.e. a one-pixel file that is retrieved from our server, or the server of our Service Provider if we use a mailing service, when the newsletter is opened. During this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of retrieval are collected. This information is used to improve our newsletters technically based on the technical data or to analyse target groups and their reading behaviour according to their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The collected information is assigned to individual newsletter recipients and stored in their profiles until deletion. On this basis, user profiles are created in which usage behaviour and user characteristics are stored. The measurement of open and click rates, as well as the storage of measurement results in users’ profiles and further processing thereof, takes place on the basis of users’ consent. It is unfortunately not possible to separately withdraw consent for performance measurement; in this case, the entire newsletter subscription must be cancelled or objected to. In such cases, the stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
- Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, as well as the use of system-generated log, diagnostic, and metadata for contract execution by Microsoft. The data processed includes contact details (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), as well as log and metadata. The processing is carried out for purposes of improving efficiency and productivity, cost efficiency, flexibility, mobility, enhanced communication, integration of Microsoft services, IT security and business operations of Microsoft. Data retention is determined by the respective document and company policies: up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: microsoft.com; Privacy Policy: privacy.microsoft.com/de-de/privacystatement, Security information: www.microsoft.com/de-de/trustcenter; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Commercial communication by E-Mail, Postal Mail, Fax or Telephone
We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.
The recipients have the right to withdraw their consent at any time or to object to the advertising communication at any time free of charge using the contact options mentioned above.
After revocation or objection, we store the data required to prove the past authorization to contact or send up to three years from the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation, respectively objection of the users, we further store the data necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing and legitimate interests: Direct marketing (e.g. by e-mail or postal); Marketing. Sales promotion.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Surveys and Questionnaires
We conduct surveys and interviews to gather information for the survey purpose communicated in each case. The surveys and questionnaires ("surveys") carried out by us are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address to display the survey in the user's browser or to enable a resumption of the survey with the aid of a cookie).
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Participants; Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Polls and Questionnaires (e.g. surveys with input options, multiple choice questions).
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Soundscape-Befragungen: We conduct so-called "soundscape surveys" (surveys on the perception of ambient sounds) to determine how ambient sounds are perceived by people at specific locations. These surveys are conducted and evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the survey (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed with the aid of a temporary cookie (session cookie)). Furthermore, the answers given by the user as well as the age indicated by the user is processed, since people of different age groups evaluate acoustic environments differently and age can be used to better classify evaluations. In addition, user-specified attitudes towards noise and the rated environment are processed, as both change rating behavior. Furthermore, we process GPS coordinates to learn which location the rater has rated.
SSL encryption: The collection of data is secured by default via the TLS 1.2/1.3 procedure SHA256 and the data is also only available to us via an identically secured connection.
Voluntary participation: Participation in the survey is voluntary. You can cancel the survey at any time by closing the browser window. The answers submitted to date will be made available to the author.
Anonymous participation: Your participation in the survey is always anonymous. By default, we cannot establish a connection between you and the answers. If you are asked for personal data within the survey, it is your decision to provide this and to make it available to us with your answers.
Cookies: Cookies are small text files that are placed in your browser when you access the survey. These cookies enable the system to recognize whether you have already visited the survey and to reassign the answers you have already given (interruption and continuation of a survey). Likewise, the use of cookies can prevent multiple participation. The cookie is automatically deleted after 90 days, or if the survey is deleted prematurely.
Location of data storage: Your answers and data are stored in a Microsoft data center in the EU in accordance with applicable data protection regulations.
Notes on legal basis: If we ask participants for consent to process their data, this is the legal basis of the processing; otherwise, the processing of participants' data is based on our legitimate interests in conducting an objective survey.
• Types of data processed: inventory data (age), content data (soundscape ratings, location and time of rating), meta/communication data (e.g. device information, IP addresses), personal attitude towards noise, personal attitude towards location.
• Data subjects: Participants of the survey
• Purposes of processing: analysis of responses to determine how ambient noise is perceived by individuals in specific locations. Creation of "noise heat maps".
• Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. - easy feedback: Implementation of surveys, questionnaires and feedback management; Service provider: easyfeedback GmbH, Ernst-Abbe-Straße 4, 56070 Koblenz, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: easy-feedback.com; Privacy Policy: easy-feedback.com/privacy/data-protection/. Further Information: Server location in Germany.
- Microsoft Forms: Creation of online forms, collection of responses in real-time, analysis of results with integrated charts. Integration into other office applications for further data processing. Customisable forms with various question types and response options as well as data export; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: forms.office.com; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Web Analysis, Monitoring and Optimization
Web analytics (also referred to as "reach measurement") is used to evaluate the visitor flows of our online services and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age or gender. Through reach analysis, we can, for example, identify when our online services or their functions and content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas need optimization.
In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online services or their components.
Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these purposes, and information can be stored in and later retrieved from a browser or device. The data collected includes, in particular, visited websites and elements used on them, as well as technical information such as the browser used, the computer system, and information about usage times. If users have given consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.
Additionally, users' IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the respective procedures.
Legal basis information: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient, economic, and user-friendly services). In this context, we would also like to point out the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Remarketing; Affiliate Tracking; Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Google Analytics: We use Google Analytics to perform measurement and analysis of the use of our online services by users based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers.
In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses. Analytics does provide coarse geo-location data by deriving the following metadata from IP addresses: City (and the derived latitude, and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU-based traffic, IP-address data is used solely for geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers before forwarding traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP Masking (Pseudonymization of the IP address); Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( business.safety.google/adsprocessorterms); Opt-Out: Opt-Out-Plugin: tools.google.com/dlpage/gaoptout, Settings for the Display of Advertisements: myadcenter.google.com/personalizationoff. Further Information: business.safety.google/adsservices/ (Types of processing and data processed). - Google as a recipient of consent: The consent given by users in the context of a consent dialogue (also known as "Cookie Opt-In/Consent", "Cookie Banner", etc.) serves multiple purposes. Firstly, it helps us to fulfil our obligation to obtain consent for the storage and reading of information on and from the end-user's device (in accordance with ePrivacy Directives). Secondly, it covers the processing of users' personal data in accordance with data protection requirements. Additionally, this consent is also applicable to Google, as the company is required by the Digital Markets Act to obtain consent for personalised services. Therefore, we share the status of consents given by users with Google. Our consent management software informs Google about whether consents have been given or not. The aim is to ensure that user consents—or their absence—are taken into account when using Google Analytics and integrating features and external services. Thus, user consents and their revocation can be dynamically adjusted within our online offerings through Google Analytics and other Google services, depending on user selection; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: support.google.com/analytics/answer/9976101. Privacy Policy: business.safety.google/privacy/.
- Google Analytics (server-side use): We use Google Analytics to perform measurement and analysis of the use of our online services by users. In this process, data of users is processed, but not directly transmitted from the end device of the users to Google. In particular, the IP address of the user is not transmitted to Google. Instead, the data is first transmitted to our server, where the user data records are assigned to our internal user identification number. The subsequent transmission only takes place in such a pseudonymized manner from our server to Google. The identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: "city" (and the derived latitude and longitude of the city), "continent", "country", "region", "subcontinent" (and the ID-based equivalents); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms/), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( business.safety.google/adsprocessorterms/). Further Information: business.safety.google/adsservices/ (Types of processing and data processed).
- Google Signals (Google Analytics function): Google signals are session data from sites and apps that Google associates with users who have signed in to their Google accounts, and who have turned on Ads Personalization. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion export to Ads. These are the areas where more information is gathered when Google Signals is activated (but only for users with Ads Personalization enabled): Cross Platform reporting - Connection of data about devices and activities from different sessions using your User-ID or Google-signals data providing an understanding of user behavior at each step of the conversion process, from initial contact to conversion and beyond; Remarketing with Google Analytics - Creation of remarketing audiences from Google Analytics data, and sharing of those audiences with linked advertising accounts; Demographics & Interests: Google Analytics collects additional information about demographics and interests from users who are signed in to their Google accounts and who have turned on Ads Personalization; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: support.google.com/analytics/answer/7532985; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( business.safety.google/adsprocessorterms). Further Information: business.safety.google/adsservices/ (Types of processing and data processed).
- Google Analytics Audiences: We use Google Analytics to specifically present ads, placed through Google's advertising services and those of its partners, to users who have already shown interest in our online offering or exhibit certain characteristics (e.g., interests in specific topics or products determined based on the websites they have visited). We transmit this data to Google as part of what is known as "Remarketing" or "Google Analytics Audiences". The purpose of using Remarketing Audiences is to ensure that our ads align as closely as possible with the potential interests of the users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com; Legal Basis: business.safety.google/adsprocessorterms/; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF); Further Information: Types of processing and data processed: business.safety.google/adsservices/. Data Processing Conditions for Google Advertising Products and standard contractual clauses for data transfers to third countries: business.safety.google/adsprocessorterms .
- Google Tag Manager: We use Google Tag Manager, a software provided by Google, which enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that serve to record and analyse visitor activities. This technology assists us in improving our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies with user profiles, or perform any independent analyses. Its function is limited to simplifying and making the integration and management of tools and services we use on our website more efficient. Nevertheless, when using Google Tag Manager, users' IP addresses are transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in this process. However, this data processing only occurs if services are integrated via the Tag Manager. For more detailed information about these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( business.safety.google/adsprocessorterms).
- Google Tag Manager (server-side use): Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online services (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, neither user profiles nor cookies are stored. The integration of the other services is server-based. This means that the users' data is not transmitted directly from their end device to the respective service. In particular, the IP address of the users is not transmitted to the other service or Google. Instead, the data is first transmitted to our server, where the user's data records are assigned to our internal user identification number. Subsequent transmission takes place only in this pseudonymized form from our server to the servers of the respective service providers. The identification number does not contain any unique data, such as names or e-mail addresses; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms/), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( business.safety.google/adsprocessorterms/). Further Information: business.safety.google/adsservices/ (Types of processing and data processed).
- Matomo (without cookies): Matomo is a data protection friendly web analysis software, which is used without cookies and in which the recognition of returning users is carried out with the help of a so-called "digital fingerprint", which is stored anonymously and changed every 24 hours; in the case of the "digital fingerprint", user movements within our online services are recorded with the help of pseudonymised IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. User data collected through the use of Matomo is processed only by us and is not shared with third parties; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: matomo.org. Security measures: IP Masking (Pseudonymization of the IP address).
Online Marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.
The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user's by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of 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 similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.
Notes on revocation and objection:
We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called "opt-out"). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:
a) Europe: youronlinechoices.eu.
b) Canada: www.youradchoices.ca/choices.
c) USA: optout.aboutads.info.
d) Cross-regional: optout.aboutads.info.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services). Service recipients and clients.
- Purposes of processing and legitimate interests: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Affiliate Tracking; Marketing; Profiles with user-related information (Creating user profiles); Conversion tracking (Measurement of the effectiveness of marketing activities); Remarketing; Provision of our online services and usability; Clicktracking. A/B Tests.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Google Ads and Conversion Tracking: Online marketing process for purposes of placing content and advertisements within the provider's advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (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 Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR); Website: marketingplatform.google.com; Privacy Policy: business.safety.google/privacy/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF); Further Information: Types of processing and data processed: business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: business.safety.google/adscontrollerterms.
- Google Ads - Enhanced Conversions: A feature that extends conversion tracking by securely transmitting hashed first-party user data to Google to improve conversion attribution. Data transmission uses SHA-256 (a cryptographic one-way hashing algorithm), which irreversibly transforms personal data such as email addresses. The feature can be used for website conversions as well as lead conversions. Data is transmitted via Google Tag Manager, Google Tag, or server-side via an API. The purpose is to improve conversion measurement despite limitations caused by cookies or cross-device usage; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com; Privacy Policy: business.safety.google/privacy/; Further Information: Types of processing and data processed: business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that adds users who use an online service to a pseudonymous remarketing list so that users can 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 Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com; Privacy Policy: business.safety.google/privacy/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF); Further Information: Types of processing and data processed: business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: business.safety.google/adscontrollerterms. - Enhanced Conversions for Google Ads: When users click on our Google ads and subsequently use the advertised service (so-called "conversion"), the data entered by the user, such as 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 to better evaluate and improve their interaction with the ads (e.g., clicks or views) and thus their performance; Legal Basis: Consent (Article 6 (1) (a) GDPR). Website: support.google.com/google-ads/answer/9888656.
- LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions, as well as stores it in a profile (possible use cases: measuring campaign performance, optimizing ad delivery, building custom and similar target groups); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: www.linkedin.com; Privacy Policy: www.linkedin.com/legal/privacy-policy; Data Processing Agreement: www.linkedin.com/legal/l/dpa; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/l/dpa), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/l/dpa). Opt-Out: 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 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 (Article 6 (1) (f) GDPR).
- Google Tag Manager: We utilise the Google Tag Manager, a tool by Google, to manage website tags via a central user interface. Tags are small code elements on our website that serve, among other things, to measure and analyse visitor activities. This technology assists us in improving our website and the services offered on it.The Google Tag Manager itself does not create user profiles, store cookies, or perform any independent analyses. It is solely used to integrate the tools and services we use for our website more simply and efficiently. However, when using the Google Tag Manager, users' IP addresses are transmitted to Google, which is technically necessary to execute the various services we utilise.It is important to note that this data processing only occurs when services are integrated through the Tag Manager that require it. For details on these services and how they process data, we refer you to the subsequent sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms). Further Information: business.safety.google/adsservices/ (Types of processing and data processed).
- Google Analytics: Web AnalyticsWe use Google Analytics to perform measurement and analysis of the use of our online services by users based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses. Analytics does provide coarse geo-location data by deriving the following metadata from IP addresses: City (and the derived latitude, and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU-based traffic, IP-address data is used solely for geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers before forwarding traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: business.safety.google/privacy/; Data Processing Agreement: business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( business.safety.google/adsprocessorterms); Opt-Out: Opt-Out-Plugin: tools.google.com/dlpage/gaoptout, Settings for the Display of Advertisements: myadcenter.google.com/personalizationoff. Further Information: business.safety.google/adsservices/ (Types of processing and data processed).
Profiles in Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
- Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data, which is used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. It also includes details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as profile details of users, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: www.linkedin.com/legal/privacy-policy.
We have entered into a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum," legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must comply with and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of users (particularly the right to information, deletion, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by our agreements with LinkedIn. The joint responsibility is limited to the collection of data and its transmission to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly concerning the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.linkedin.com; Privacy Policy: www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/privacy-policy), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/privacy-policy). Opt-Out: www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: business.safety.google/privacy/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF). Opt-Out: myadcenter.google.com/personalizationoff.
Plugins and embedded functions and content
Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as "Content").
The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Integration of third-party software, scripts or frameworks: We incorporate into our online services software which we retrieve from servers of other providers (e.g. function libraries which we use for the purpose of displaying or user-friendliness of our online services). The respective providers collect the user's IP address and can process it for the purposes of transferring the software to the user's browser as well as for security purposes and for the evaluation and optimisation of their services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- Google Fonts (Provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
- OpenStreetMap: We integrate the maps from the "OpenStreetMap" service, which are provided based on the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). OpenStreetMap uses user data exclusively for the purpose of displaying map functions and caching the selected settings. This data may particularly include the IP addresses and location data of the users, which, however, are not collected without their consent (typically within the settings of their devices or browsers); Service provider: OpenStreetMap Foundation (OSMF); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.openstreetmap.de. Privacy Policy: osmfoundation.org/wiki/Privacy_Policy.
Job Application Process
The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information contained therein.
In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.
Where available, applicants are welcome to submit their applications via our online form, which is securely encrypted to the latest standards. Alternatively, applications can also be sent to us by email. However, we kindly remind you that emails are not inherently encrypted over the Internet. While emails are usually encrypted in transit, they are not encrypted on the servers from which they are sent and received. Therefore, we cannot assume responsibility for the security of the application during its transmission from the sender to our server.
Processing of special categories of data: To the extent that special categories of personal data (Article 9(1) GDPR, e.g., health data, such as disability status or ethnic origin) are requested from applicants or communicated by them during the application process, their processing is carried out so that the controller or the data subject can exercise rights arising from employment law and the law of social security and social protection, in the case of protection of vital interests of the applicants or other persons, or for purposes of preventive or occupational medicine, for the assessment of the employee's work ability, for medical diagnosis, for the provision or treatment in the health or social sector, or for the management of systems and services in the health or social sector.
Ereasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' data will also be deleted if an application is withdrawn, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, the deletion will take place at the latest after the expiry of a period of six months, so that we can answer any follow-up questions regarding the application and comply with our duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
Admission to a talent pool - Admission to a talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.
Duration of data retention in the applicant pool in months: 24
- Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Images and/ or video recordings (e.g. photographs or video recordings of a person). Audio recordings.
- Data subjects: Job applicants; Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Participants.
- Purposes of processing and legitimate interests: Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship); Communication. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
- Legal Basis: Job application process as a pre-contractual or contractual relationship (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Stepstone: Recruitment-related services (search for employees, communication, application process, contract negotiations); Service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.stepstone.com; Privacy Policy: www.stepstone.de/e-recruiting/en/legal/privacy-policy/. Data Processing Agreement: www.stepstone.de/e-recruiting/en/legal/dpa-universum/.
- Indeed: Recruitment-related services (search for employees, communication, application process, contract negotiations); Service provider: Indeed Ireland Operations Limited, 124 St. Stephen’s Green, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: de.indeed.com. Privacy Policy: www.indeed.com/legal.
- Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, as well as the use of system-generated log, diagnostic, and metadata for contract execution by Microsoft. The data processed includes contact details (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), as well as log and metadata. The processing is carried out for purposes of improving efficiency and productivity, cost efficiency, flexibility, mobility, enhanced communication, integration of Microsoft services, IT security and business operations of Microsoft. Data retention is determined by the respective document and company policies: up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: microsoft.com; Privacy Policy: privacy.microsoft.com/de-de/privacystatement, Security information: www.microsoft.com/de-de/trustcenter; Data Processing Agreement: www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Microsoft Teams: Utilisation for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration functions are used; name, business contact details, work profile, participation as well as content (audio/video, speech, chat, files, speech transcription) are processed for purposes and interests in efficiency and productivity improvements, cost efficiency, flexibility, mobility, enhanced communication, IT security, use of a central platform as well as business operations by Microsoft. Audio signals are generally not stored unless recording is enabled. Meeting and conference recordings are stored by default for 90 days unless a different duration is specified. Chat and file contents are stored according to the policies determined by the administrator or user; there is no preset automatic deletion. Channels must be renewed every 180 days; otherwise contents are deleted. Additionally processed are system-generated logs, diagnostic and metadata as well as diagnostic data collected for product stability, security and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.microsoft.com/en-us/microsoft-teams/; Privacy Policy: www.microsoft.com/en-us/privacy/privacystatement. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
- Bundesagentur für Arbeit (Jobbörse): Recruitment platform and applicant management services (job postings, candidate search, and application processes); Service provider: Bundesagentur für Arbeit (BA), Regensburger Straße 104, 90478 Nürnberg, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: www.arbeitsagentur.de. Privacy Policy: www.arbeitsagentur.de/datenschutz.
Changes and Updates
We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.
Supervisory authority competent for us:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2-4, 40213 Düsseldorf, Germany
Terminology and Definitions
In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.
- A/B Tests: A/B tests are designed to improve the usability and performance of online services. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. The behaviour of users, e.g. prolonged visits to the site or more frequent interaction with the elements, can then be used to determine which of these sites or elements are more responsive to users' needs.
- Affiliate Tracking: Custom Audiences refers to the process of determining target groups for advertising purposes, e.g. the display of advertisements. For example, a user's interest in certain products or topics on the Internet may be used to conclude that the user is interested in advertisements for similar products or the online store in which the user viewed the products. "Lookalike Audiences" is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences, cookies and web beacons are typically used.
- Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users' consent or based on legal authorisation grounds.
- Clicktracking: Clicktracking allows users to keep track of their movements within an entire website. Since the results of these tests are more accurate if the interaction of the users can be followed over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the computers of the users for these test purposes.
- Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
- Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
- Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
- Controller: "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.
- Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
- Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
- Location data: Location data is created when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the 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.
- Location history and mobility profiles: Location history (also referred to as " mobility profile") is the collection of location data over a certain period of time. The location history allows conclusions to be drawn about the geographical movements (i.e. changes in position) of devices and/or their users.
- Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
- Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
- Payment Data: Payment data comprise all information necessary for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
- Personal Data: "personal data" means any information relating to an identified or identifiable natural person ("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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind 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.
- Remarketing: Remarketing" or "retargeting" is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Targeting: "Tracking" is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
- Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
- Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize 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 their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.