Preamble
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also briefly referred to as “data”) that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both within the scope of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offering”).
The terms used are not gender-specific
Status: July 1, 2025
Table of Contents
- Preamble
- Controller
- Overview of Processing
- Relevant Legal Bases
- Security Measures
- Transmission of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of the Data Subjects
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Special Notes on Applications (Apps)
- Obtaining Applications via App Stores
- Blogs and Publication Media
- Contact and Inquiry Management
- Communication via Messenger
- Chatbots and Chat Functions
- Push Notifications
- Artificial Intelligence (AI)
- Newsletter and Electronic Notifications
- Advertising Communication via Email, Post, Fax, or Telephone
- Web Analysis, Monitoring, and Optimization
- Online Marketing
- Presences in Social Networks (Social Media)
- Plug-ins and Embedded Functions and Content
- Management, Organization, and Auxiliary Tools
- Changes and Updates
- Definitions of Terms
Controller
Zantino GmbH
Ernst-Barlach-Str. 20
36041 Fulda, Germany
Authorized Representative: Achim Mehler
Email Address: info@zantino.de
Imprint: impressum
Overview of Processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of Processed Data
- Inventory data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Contact information (Facebook).
- Event data (Facebook).
- Log data.
Categories of Data Subjects
- Recipients of services and clients.
- Communication partners.
- Users.
- Members.
- Third parties.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Click tracking.
- Target group formation.
- A/B testing.
- Organizational and administrative procedures.
- Content Delivery Network (CDN).
- Feedback.
- Marketing.
- Profiles with user-related information.
- Cross-Device Tracking.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Sales promotion.
- Artificial Intelligence (AI).
Relevant Legal Bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations in your or our country of residence or seat may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 (1) sentence 1 lit. a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transfer as well as automated decision-making in individual cases including profiling. Furthermore, the state data protection laws of the individual federal states may apply.
Relevant Legal Bases under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (FADP). Unlike, for example, the GDPR, the Swiss FADP generally does not require a legal basis for the processing of personal data to be named and that the processing of personal data is carried out in good faith, lawfully and proportionately (Art. 6 (1) and (2) of the Swiss FADP). In addition, we only obtain personal data for a specific purpose recognizable to the data subject and only process it in a manner compatible with this purpose (Art. 6 (3) of the Swiss FADP).
Note on the applicability of the GDPR and Swiss FADP: These data protection notices serve both to provide information in accordance with the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that, due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss FADP, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined by the Swiss FADP within the scope of its applicability.
Security Measures
In accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances, and purposes of the processing, as well as the different likelihoods of occurrence and the severity of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, entry, disclosure, securing of availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and reactions to the endangerment of data. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.
Transmission of Personal Data
In the context of our processing of personal data, it may happen that they are transmitted or disclosed to other bodies, companies, legally independent organizational units, or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
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 happens in the context of using third-party services or disclosing or transferring data to other persons, bodies, or companies (which can be recognized by the postal address of the respective provider or if the privacy policy expressly refers to the data transfer to third countries), this is always done in accordance with the 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 an adequacy decision of the EU Commission dated 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This dual protection ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should there be changes within the framework of the DPF, the standard contractual clauses will step in as a reliable fallback option. This is how we ensure that your data is always adequately protected even in the event of political or legal changes.
For the individual service providers, we inform you whether they are certified according to the DPF and whether standard contractual clauses exist. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
Disclosure of personal data abroad: According to the Swiss FADP, we only disclose personal data abroad if an adequate level of protection for the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined an adequate level of protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take 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 an adequacy decision of Switzerland dated 07.06.2024. In addition, we have concluded standard data protection clauses with the respective providers that have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations for the protection of your data.
This dual protection ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard data protection clauses serve as additional security. Should there be changes within the framework of the DPF, the standard data protection clauses will step in as a reliable fallback option. This is how we ensure that your data is always adequately protected even in the event of political or legal changes.
For the individual service providers, we inform you whether they are certified according to the DPF and whether standard data protection clauses exist. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, corresponding security measures apply, including international agreements, specific guarantees, standard data protection clauses approved by the FDPIC, or pre-approved corporate binding rules by the FDPIC or a competent data protection authority of another country.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or no further legal basis for the processing exists. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be kept for commercial or tax law reasons or whose storage is necessary for the prosecution of legal claims or the protection of the rights of other natural or legal persons must be archived accordingly.
Our data protection notices contain additional information on the retention and deletion of data that specifically apply to certain processing processes.
If there are multiple specifications for the retention period or deletion periods for a piece of data, the longest period is always decisive. Data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons will be processed by us exclusively for the reasons that justify their retention.
Retention and Deletion of Data: The following general deadlines apply to retention and archiving under German law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required for their understanding (§ 147 (1) no. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) no. 1 in conjunction with (4) HGB).
- 8 years – Accounting vouchers, such as invoices and expense receipts (§ 147 (1) no. 4 and 4a in conjunction with (3) sentence 1 AO and § 257 (1) no. 4 in conjunction with (4) HGB).
- 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are of importance for taxation, e.g. hourly wage slips, internal cost allocation sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting vouchers and cash register strips (§ 147 (1) nos. 2, 3, 5 in conjunction with (3) AO, § 257 (1) nos. 2 and 3 in conjunction with (4) HGB).
- 3 years – Data required to take into account potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and customary industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Retention and Deletion of Data: The following general deadlines apply to retention and archiving under Swiss law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices, as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (OR)).
- 10 years – Data necessary for taking into account potential compensation claims or similar contractual claims and rights, as well as for processing related inquiries, based on previous business experiences and customary industry practices, are stored for the period of the statutory limitation period of ten years, unless a shorter period of five years is relevant, which applies in certain cases (Art. 127, 130 OR). Claims for rent, lease and capital interest as well as other periodic payments, for the supply of foodstuffs, for board and lodging debts, and from craft work, small-scale sales of goods, medical care, professional work of lawyers, legal agents, attorneys and notaries, and from the employment relationship of employees expire after five years (Art. 128 OR).
Start of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the time the termination or other ending of the legal relationship takes effect.
Rights of the Data Subjects
Rights of the Data Subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 (1) lit. e or f GDPR, including profiling based on those provisions. If personal data concerning you are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw given consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with legal requirements, to demand the completion of the data concerning you or the rectification of the inaccurate data concerning you.
- Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be erased without delay, or alternatively, in accordance with legal requirements, to demand a restriction of the processing of the data.
- Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements or to demand the transmission of those data to another controller.
- Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Rights of the Data Subjects under the Swiss FADP:
As a data subject, you have the following rights in accordance with the provisions of the Swiss FADP:
- Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed, and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing.
- Right to data disclosure or transfer: You have the right to request the disclosure of your personal data that you have provided to us in a common electronic format.
- 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 and to request that the personal data concerning you be deleted or destroyed.
Provision of the Online Offering and Web Hosting
We process user data to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.
- Types of processed data: Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons); Log data (e.g., log files regarding logins or the retrieval of data or access times). Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures. Content Delivery Network (CDN).
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the retrieved web pages and files, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the utilization and stability of the servers; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes are excluded from deletion until the final clarification of the respective incident.
- Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed and Internet-connected servers; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
- Hetzner: Services in the field of providing information technology infrastructure and associated services (e.g., storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit.f) GDPR);
Website: https://www.hetzner.com;
Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz
Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/. - Cloudflare: Content Delivery Network (CDN) – a service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed and Internet-connected servers; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.cloudflare.com; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/).
- Namecheap: Services in the field of providing information technology infrastructure and associated services (e.g., storage space and/or computing capacities); Service provider: Namecheap Inc., 4600 East Washington Street, Suite 305, Phoenix, AZ 85034, USA; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.namecheap.com; Privacy Policy: https://www.namecheap.com/legal/general/privacy-policy/. Data Processing Agreement: https://www.namecheap.com/legal/universal/data-processing-addendum/.
- gstatic.com: Content Delivery Network (CDN) – a service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed and Internet-connected servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.google.de/. Privacy Policy: https://policies.google.com/privacy.
- JSDelivr: Content Delivery Network (CDN), which helps to deliver media and files, especially under high load, quickly and efficiently; Service provider: ProspectOne, Królewska 65A/1, 30-081, Kraków, Poland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.jsdelivr.com. Privacy Policy: https://www.jsdelivr.com/terms/privacy-policy.
Use of Cookies
The term “cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal requirements. To do this, we obtain the user’s consent in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies when the storage and reading of information is essential to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We clearly inform about their scope and which cookies are used.
Notes on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.
General notes on revocation and objection (Opt-out): Users can revoke their given consent at any time and also declare an objection to the processing in accordance with legal requirements, including via the privacy settings of their browser.
- Types of processed data: Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR). Consent (Art. 6 (1) sentence 1 lit. a) GDPR).
Further information on processing processes, procedures, and services:
- Processing of cookie data based on consent: We use a consent management solution, in which the user’s consent to the use of cookies or to the procedures and providers named in the context of the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read out, and process information on the users’ end devices. In the context of this procedure, the users’ consent for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored to avoid a renewed query and to be able to prove consent in accordance with legal requirements. The storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. If there is no specific information about the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, the details of the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and end device used; Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR).
- CookieYes: Consent management: procedure for obtaining, logging, managing, and revoking consent, in particular for the use of cookies and similar technologies for storing, reading out, and processing information on users’ end devices as well as their processing; Service provider: CookieYes Limited, 3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, Great Britain; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.cookieyes.com; Privacy Policy: https://www.cookieyes.com/privacy policy/. Data Processing Agreement: https://www.cookieyes.com/dpa/.
Special Notes on Applications (Apps)
We process the data of the users of our application to the extent that this is necessary to provide the users with the application and its functionalities, to monitor their security, and to further develop them. We may also contact users in compliance with legal requirements, if communication is necessary for the purposes of the administration or use of the application. In all other respects, we refer to the data protection notices in this privacy policy with regard to the processing of user data.
Legal bases: The processing of data that is necessary for the provision of the functionalities of the application serves the fulfillment of contractual obligations. This also applies if the provision of the functions requires authorization from the users (e.g., releases 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 purposes of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.
- Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons); Payment data (e.g., bank details, invoices, payment history). Contract data (e.g., subject of the contract, term, customer category).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- 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 be able to provide our contractual services to them and on the basis of legitimate interests to be able to ensure the security of our application and to further develop it. The required information is identified as such in the context of the usage, order, purchase, or comparable contract conclusion and may include the information required for the provision of services and for any invoicing, as well as contact information to be able to hold any consultations; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR).
- Device permissions for access to functions and data: The use of our application or its functionalities may require user permissions for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these permissions must be granted by the users 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 device and software of the users. If clarification is needed, users can contact us. We point out that the denial or revocation of the respective permissions can affect the functionality of our application.
- Use of customer data for marketing and advertising
We may use certain customer data (such as email addresses) in a secure, hashed, and anonymized form to create audience lists for online advertising platforms, including, but not limited to, Google Ads, Meta, and Display & Video 360 (DV360).
This enables us to show relevant advertising to people who may be interested in our products or services.
All processing is carried out in accordance with applicable data protection laws (GDPR), and no personal data is shared in a form that allows direct identification.
You can object to this data use at any time by contacting us via the channels specified in this privacy policy.
Obtaining Applications via App Stores
Our application is obtained via special online platforms operated by other service providers (so-called “App Stores”). In this context, the privacy policies of the respective app stores apply in addition to our data protection notices. This applies in particular with regard to the procedures used on the platforms for reach measurement and interest-based marketing as well as any fees.
- Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Recipients of services and clients. Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Apple App Store: App and software sales platform; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/app-store/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Play: App and software sales platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://play.google.com/store/apps?hl=de. Privacy Policy: https://policies.google.com/privacy.
Blogs and Publication Media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Reader data is processed for the purposes of the publication medium only to the extent necessary for its display and communication between authors and readers or for security reasons. In all other respects, we refer to the information on the processing of visitors to our publication medium in the context of these data protection notices.
- Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Contact and Inquiry Management
When contacting us (e.g., by post, contact form, email, telephone, or via social media) and in the context of existing user and business relationships, the information of the inquiring persons is processed, insofar as this is necessary to answer the contact inquiries and any requested measures.
- Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Communication partners; Users (e.g., website visitors, users of online services). Members.
- Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form); Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Direct marketing (e.g., via email or post).
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR). Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR).
Further information on processing processes, procedures, and services:
- Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information, and possibly further information that is provided to us and is necessary for adequate processing. We only use this data for the specified purpose of contact and communication; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
- WhatsApp Groups: We use the WhatsApp platform to create interest groups within which WhatsApp users can contact each other or us and exchange information; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- WhatsApp: Text messages, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- Telegram: Sending and receiving messages, voice and video calls; creating groups and channels; sharing files and media; using bots for automation; end-to-end encryption for secret chats; synchronization across multiple devices; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://telegram.org/. Privacy Policy: https://telegram.org/privacy/de.
- Telegram Groups: We use the Telegram platform to create interest groups within which Telegram users can contact each other or us and exchange information; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy; Further information: We only process the personal data of the group members to the extent that we can manage the group members, i.e., add, delete, restrict the use of the group, and moderate the content. Furthermore, i.e., in particular for the provision of technical functions, the evaluation and provision of anonymous sending statistics for the group operators, and the management of the users, Telegram is responsible.
- Telegram Channels: We use the Telegram platform to send messages to subscribers of our Telegram channel; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy/de; Further information: We only process the personal data of the subscribers to the extent that we can view and delete the subscribers as recipients of the channel. Furthermore, i.e., in particular for sending the messages, the evaluation and provision of anonymous sending statistics for the channel operators, and the management of the subscribers, Telegram is responsible under data protection law.
Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, encryption, the use of communication metadata, and your options for objection.
You can also contact us via alternative means, e.g., via telephone or email. Please use the contact options communicated to you or the contact options specified within our online offering.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption activated so that the encryption of the message content is ensured.
However, we also point out to our communication partners that the providers of the messengers cannot view the content, but can find out that and when communication partners communicate with us, and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) are processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. In all other respects, if we do not ask for consent and they contact us voluntarily, for example, we use messengers in relation to our contractual partners and in the context of initiating a contract as a contractual measure, and in the case of other interested parties and communication partners on the basis of our legitimate interests in quick and efficient communication and fulfilling the needs of our communication partners for communication via messenger. Furthermore, we point out that we do not initially transmit the contact data communicated to us to the messengers without your consent.
Revocation, Objection, and Deletion: You can revoke any consent given at any time and object to communication with us via messenger at any time. In the event of communication via messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information requests from the communication partners, if no reference to a previous conversation is expected and the deletion is not opposed by statutory retention obligations.
Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that we may not be able to answer inquiries via messenger for certain reasons. This applies to situations in which, for example, contract details must be treated particularly confidentially or a response via messenger does not meet the formal requirements. In these cases, we recommend that you use more suitable communication channels.
- Types of processed data: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Communication partners.
- Purposes of processing: Communication. Direct marketing (e.g., via email or post).
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Instagram: Sending messages via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/.
- Facebook Messenger: Sending and receiving text messages, making voice and video calls, creating group chats, sharing files and media, transmitting location information, synchronizing contacts, encrypting messages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Telegram: Sending and receiving messages, voice and video calls; creating groups and channels; sharing files and media; using bots for automation; end-to-end encryption for secret chats; synchronization across multiple devices; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://telegram.org/. Privacy Policy: https://telegram.org/privacy/de.
- WhatsApp: Text messages, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
Chatbots and Chat Functions
We offer online chats and chatbot functions as communication options (together referred to as “Chat Services”). A chat is an online conversation conducted with a certain immediacy. A chatbot is software that answers user questions or informs them via messages. When you use our chat functions, we may process your personal data.
If you use our chat services within an online platform, your identification number within the respective platform will also be stored. We can also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes to be able to prove them in accordance with legal requirements.
We point out to users that the respective platform provider can find out that and when users communicate with our chat services, and can collect technical information about the device used by the users and, depending on the settings of their device, location information (so-called metadata) for the purposes of optimizing the respective services and for security purposes. The metadata of communication via chat services (i.e., for example, the information about who communicated with whom) could also be used by the respective platform providers, in accordance with their provisions, to which we refer for further information, for marketing purposes or for displaying advertising tailored to users.
If users agree to activate information with regular messages from a chatbot, they have the option to unsubscribe from the information for the future at any time. The chatbot informs users how and with which terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, the user’s data is deleted from the directory of message recipients.
We use the aforementioned information to operate our chat services, e.g., to address users personally, to answer their inquiries, to transmit any requested content, and also to improve our chat services (e.g., to “teach” chatbots answers to frequently asked questions or to recognize unanswered inquiries).
Notes on legal bases: We use the chat services based on consent if we have previously obtained the users’ permission to process their data within the scope of our chat services (this applies to cases in which users are asked for consent, e.g., so that a chatbot regularly sends them messages). If we use chat services to answer user inquiries about our services or our company, this is done for contractual and pre-contractual communication. In all other respects, we use chat services based on our legitimate interests in optimizing the chat services, their economic efficiency, and increasing the positive user experience.
Revocation, objection, and deletion: You can revoke any consent given at any time or object to the processing of your data within the scope of our chat services.
- Types of processed data: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Communication partners.
- Purposes of processing: Communication.
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Push Notifications
With the users’ consent, we can send so-called “push notifications” to the users. These are messages that are displayed on the users’ screens, end devices, or browsers, even if our online service is not currently being actively used.
To register for push notifications, users must confirm the request from their browser or end device to receive push notifications. This consent process is documented and stored. The storage is necessary to recognize whether users have agreed to receive push notifications and to be able to prove consent. For these purposes, a pseudonymous identifier of the browser (so-called “push token”) or the device ID of an end device is stored.
The push notifications may be necessary for the fulfillment of contractual obligations (e.g., technical and organizational information relevant to the use of our online offering) and are otherwise sent on the basis of user consent, unless specifically mentioned below. Users can change the reception of push notifications at any time using the notification settings of their respective browsers or end devices.
- Types of processed data: Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Communication partners.
- Purposes of processing: Communication; Provision of our online offering and user-friendliness; Reach measurement (e.g., access statistics, recognition of recurring visitors). Direct marketing (e.g., via email or post).
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”. Deletion after termination.
- Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Push notifications with advertising content: The push notifications sent by us may contain advertising information. The advertising push notifications are processed on the basis of user consent. If the content of the advertising push notifications is specifically described in the context of a consent to receive them, the descriptions are decisive for the user’s consent. In all other respects, our newsletters contain information about our services and us; Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR).
- Analysis and success measurement: We statistically evaluate push notifications and can thus recognize whether and when push notifications were displayed and clicked. This information is used for the technical improvement of our push notifications based on the technical data or the target groups and their retrieval behavior or retrieval times. This analysis also includes determining whether the push notifications are opened, when they are opened, and whether users interact with their content or buttons. Although this information can be assigned to the individual push notification recipients for technical reasons. However, it is neither our endeavor nor, if used, that of the push notification service provider to observe individual users. Rather, the evaluations serve us to recognize the usage habits of our users and to adapt our push notifications to them or to send different push notifications according to the interests of our users. The evaluation of the push notifications and the success measurement are carried out on the basis of the user’s explicit consent, which is given with the consent to receive the push notifications. Users can object to the analysis and success measurement by unsubscribing from the push notifications. A separate revocation of the analysis and success measurement is unfortunately not possible; Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR).
Artificial Intelligence (AI)
We use Artificial Intelligence (AI), whereby personal data is processed. The specific purposes and our interest in the use of AI are named below. By AI, we mean, in accordance with the term of an “AI system” according to Article 3 No. 1 of the AI Regulation, a machine-based system that is designed for a varying degree of autonomous operation, can be adaptable after its introduction, and generates output such as predictions, content, recommendations, or decisions from the received input 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 control, purpose limitation, data minimization, and integrity as well as confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can either be the consent of the data subjects or a legal permission.
When using external AI systems, we carefully select their providers (hereinafter “AI Providers”). In accordance with our legal obligations, we ensure that the AI Providers comply with the applicable provisions. We also observe the obligations incumbent on us when using or operating the acquired AI services. The processing of personal data by us and the AI Providers takes place exclusively on the basis of consent or legal authorization. We attach particular importance to transparency, fairness, and maintaining human control over AI-supported decision-making processes.
To protect the processed data, we implement appropriate and robust technical and organizational measures. These ensure the integrity and confidentiality of the processed data and minimize potential risks. Through regular reviews of the AI Providers and their services, we ensure continued compliance with current legal and ethical standards.
- Types of processed data: Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g., website visitors, users of online services). Third parties.
- Purposes of processing: Artificial Intelligence (AI).
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- ChatGPT: AI-based service designed to understand and generate natural language and associated inputs and data, analyze information, and make predictions (“AI”, i.e., “Artificial Intelligence”, is to be understood in the respective applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://openai.com/de-DE/chatgpt/overview/; Privacy Policy: https://openai.com/de-DE/policies/privacy-policy/. Option to object (Opt-Out): https://privacy.openai.com/policies?modal=select-subject.
Newsletter and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipients or on the basis of a legal foundation. If the content of the newsletter is named in the context of a registration for the newsletter, this content is decisive for the user’s consent. For registration for our newsletter, providing your email address is usually sufficient. However, to be able to offer you a personalized service, we may ask for your name for a personal address in the newsletter or for other information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent that was previously given. The processing of this data is restricted to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address for this purpose alone in a blocking list (so-called “blocklist”).
The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with sending emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Content:
Information about us, our services, promotions, and offers.
- Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., via email or post).
- Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
- Option to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e., revoke your consent, or object to further receipt. You can find a link to cancel the newsletter either at the end of every newsletter or you can use one of the contact options specified above, preferably email, for this purpose.
Further information on processing processes, procedures, and services:
- Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server or its server when the newsletter is opened, provided we use a shipping service provider. In the context of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval are collected first. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user’s consent. A separate revocation of the success measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR).
- Mailchimp: Email marketing, automation of marketing processes, collection. storage and management of contact data, measurement of campaign performance, collection and analysis of recipient interaction with content, personalization of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/; Data Processing Agreement: https://mailchimp.com/legal/; Basis for third-country transfers: EU/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). Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.
Advertising Communication via Email, Post, Fax, or Telephone
We process personal data for the purposes of advertising communication, which can take place via various channels, such as email, telephone, post, or fax, in accordance with the legal requirements.
The recipients have the right to revoke any consent given at any time or to object to advertising communication at any time.
After revocation or objection, we store the data necessary to prove the previous authorization for contact or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is restricted to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the users’ revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information relating to them, such as details on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Communication partners; Users (e.g., website visitors, users of online services). Members.
- Purposes of processing: Direct marketing (e.g., via email or post); Marketing; Sales promotion; Communication; Provision of our online offering and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Retention and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
- Legal bases: Consent (Art. 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- WhatsApp Groups: We use the WhatsApp platform to create interest groups within which WhatsApp users can contact each other or us and exchange information; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- WhatsApp: Text messages, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy Policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- Telegram: Sending and receiving messages, voice and video calls; creating groups and channels; sharing files and media; using bots for automation; end-to-end encryption for secret chats; synchronization across multiple devices; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR); Website: https://telegram.org/. Privacy Policy: https://telegram.org/privacy/de.
- Telegram Channels: We use the Telegram platform to send messages to subscribers of our Telegram channel; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy/de; Further information: We only process the personal data of the subscribers to the extent that we can view and delete the subscribers as recipients of the channel. Furthermore, i.e., in particular for sending the messages, the evaluation and provision of anonymous sending statistics for the channel operators, and the management of the subscribers, Telegram is responsible under data protection law.
- Telegram Groups: We use the Telegram platform to create interest groups within which Telegram users can contact each other or us and exchange information; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Website: https://telegram.org/; Privacy Policy: https://telegram.org/privacy; Further information: We only process the personal data of the group members to the extent that we can manage the group members, i.e., add, delete, restrict the use of the group, and moderate the content. Furthermore, i.e., in particular for the provision of technical functions, the evaluation and provision of anonymous sending statistics for the group operators, and the management of the users, Telegram is responsible.
Web Analysis, Monitoring, and Optimization
Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and may include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or content are most frequently used, or invite people to reuse them. We can also understand which areas need optimization.
In addition to web analysis, we can also use testing procedures to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e., data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and then read out. The collected information includes, in particular, visited websites and elements used there, as well as technical information, such as the browser used, the computer system used, and information on usage times and functions used. If users have agreed to the collection of their location data vis-à-vis us or vis-à-vis the providers of the services we use, the processing of location data is also possible.
In addition, the IP addresses of the users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) are stored in the context of web analysis, A/B testing, and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Notes on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for data processing is the consent. Otherwise, the user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to point out the information on the use of cookies in this privacy policy.
- **Types of Data Processed:** Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- **Data Subjects:** Users (e.g., website visitors, users of online services).
- **Purposes of Processing:** Audience measurement (e.g., access statistics, recognition of recurring visitors); Profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
- **Retention and Deletion:** Deletion according to information in the section “General Information on Data Storage 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 Bases:** Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- **Google Analytics:** We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number contains no unique data such as names or email addresses. It serves to assign analysis information to an end device to recognize what content users have accessed within one or different usage processes, what search terms they have used, revisited, or interacted with our online offering. The time and duration of use, as well as the sources of users who refer to our online offering and technical aspects of their end devices and browsers, are also stored. Pseudonymous user profiles are created with information from the use of different devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. Analytics provides coarse geographic 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 traffic, IP address data is used exclusively for this geolocation data derivation before being immediately deleted. They are not logged, are not accessible, and are not used for any further purposes. When Google Analytics collects measurement data, all IP lookups are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security Measures: IP Masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for Third Country Transfers: EU/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); Opt-Out Option (Objection): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for Ad Display: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).
- **Google Tag Manager:** We use Google Tag Manager, a Google software that allows us to centrally manage so-called website tags via a user interface. Tags are small code elements on our website used to capture and analyze visitor activities. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, does not store cookies with user profiles, and does not conduct independent analyses. Its function is limited to simplifying and making more efficient the integration and management of tools and services we use on our website. Nevertheless, when using Google Tag Manager, the user’s IP address is transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set. However, this data processing only occurs when services are integrated via the Tag Manager. For more precise information on these services and their data processing, we refer to the further sections of this privacy policy; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms. Basis for Third Country Transfers: EU/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).
- **Matomo (without Cookies):** Matomo is a privacy-friendly web analysis software that is used without cookies and where the recognition of recurring users takes place 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 offering are recorded using pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected as part of the use of Matomo is only processed by us and is not shared with third parties; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://matomo.org/. Security Measures: IP Masking (pseudonymization of the IP address).
Online Marketing
We process personal data for the purpose 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 the users and the measurement of their effectiveness.
For these purposes, so-called **user profiles** are created and stored in a file (the so-called “**cookie**”) or similar procedures are used, by means of which the information relevant to the user for the display of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
In addition, the **IP addresses** of the users are stored. However, we use available **IP masking procedures** (i.e., pseudonymization by shortening the IP address) for user protection. Generally, no **clear data** of the users (such as email addresses or names) are stored within the online marketing procedure, but **pseudonyms**. This means that neither we nor the providers of the online marketing procedures know the actual user identity, but only the information stored in their profiles.
The statements in the profiles are generally stored in the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing procedure provider.
In exceptional cases, it is possible to assign **clear data** to the profiles, primarily when users are, for example, members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users can enter into additional agreements with the providers, for example, through consent as part of registration.
We generally only receive access to **aggregated information** about the success of our advertisements. However, in the context of so-called **conversion measurement**, we can check which of our online marketing procedures have led to a so-called **conversion**, i.e., for example, to a contract conclusion with us. The conversion measurement is used solely for the success analysis of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
**Notes on Legal Bases:** If we ask users for their consent to the use of third-party providers, the legal basis for data processing is **permission**. Otherwise, user data is processed on the basis of our **legitimate interests** (i.e., interest in efficient, economic, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
**Notes on Revocation and Objection:**
We refer to the data protection notices of the respective providers and the objection options specified for the providers (so-called “**Opt-Out**”). If no explicit opt-out option has been specified, there is the option, on the one hand, that you can disable cookies in your browser settings. However, this may restrict functions of our online offering. We therefore also recommend the following Opt-Out options, which are offered summarized for respective areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-territorial: https://optout.aboutads.info.
- **Types of Data Processed:** Content data (e.g., textual or visual messages and contributions as well as the information related to them, such as authorship details or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons); Event Data (Facebook) (“Event Data” are information that is sent to the provider Meta, for example, via Meta Pixel (whether via apps or other channels) and relates to persons or their actions. This data includes, for example, details on website visits, interactions with content and functions, app installations, and product purchases. The processing of Event Data takes place with the aim of creating target groups for content and advertising messages (**Custom Audiences**). It is important to note that Event Data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or telephone numbers. “Event Data” is deleted by Meta after a maximum of two years, and the target groups created from it disappear with the deletion of our Meta user accounts.); Contact Information (Facebook) (“Contact Information” is data that clearly identifies data subjects, such as names, email addresses, and telephone numbers, which can be transmitted to Facebook, e.g., via Facebook Pixel or upload for matching purposes for the purpose of forming Custom Audiences. After matching for the purpose of forming target groups, the contact information is deleted).
- **Data Subjects:** Users (e.g., website visitors, users of online services).
- **Purposes of Processing:** Audience measurement (e.g., access statistics, recognition of recurring visitors); Tracking (e.g., interest-/behavior-based profiling, use of cookies); Conversion measurement (measurement of the effectiveness of marketing measures); Target group formation; Marketing; Profiles with user-related information (creation of user profiles); Provision of our online offering and user-friendliness; Remarketing; Click tracking; A/B tests. Cross-Device Tracking (cross-device processing of user data for marketing purposes).
- **Retention and Deletion:** Deletion according to information in the section “General Information on Data Storage 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 Bases:** Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- **Meta Pixel and Target Group Formation (Custom Audiences):** With the help of the Meta Pixel (or comparable functions, for the transmission of Event Data or contact information via interfaces in apps), the Meta company is able, on the one hand, to determine the visitors to our online offering as a target group for the display of advertisements (so-called “**Meta-Ads**”). Accordingly, we use the Meta Pixel to display the Meta-Ads placed by us only to those users on Meta’s platforms and within the services of partners cooperating with Meta (so-called “**Audience Network**” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g., interest in certain topics or products that become apparent based on the visited websites) that we transmit to Meta (so-called “**Custom Audiences**”). With the help of the Meta Pixel, we also want to ensure that our Meta-Ads correspond to the potential interest of the users and do not appear annoying. With the help of the Meta Pixel, we can also track the effectiveness of the Meta-Ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta-Ad (so-called “**Conversion Measurement**”); Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further Information: User Event Data, i.e., behavior and interest details, are processed for the purposes of targeted advertising and target group formation based on the agreement on **joint controllership** (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transmission of the data to the parent company Meta Platforms, Inc. in the USA (based on the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- **Advanced Matching for the Meta Pixel:** In addition to the processing of Event Data in the context of using the Meta Pixel (or comparable functions, e.g., in apps), contact information (data identifying individual persons, such as names, email addresses, and phone numbers) is also collected by Meta within our online offering or transmitted to Meta. The processing of contact information serves to form target groups (so-called “**Custom Audiences**”) for the display of content and advertising information oriented to the presumed interests of the users. The collection, transmission, and matching with data existing at Meta do not take place in clear text, but as so-called “**hash values**,” i.e., mathematical images of the data (this method is used, for example, for storing passwords). After the matching for the purpose of forming target groups, the contact information is deleted; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Privacy Policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further Information: https://www.facebook.com/legal/terms/data_security_terms.
- **Facebook Advertisements:** Placement of advertisements within the Facebook platform and evaluation of the advertisement results; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Opt-Out Option (Objection): We refer to the privacy and advertising settings in the user profile on the Facebook platforms as well as Facebook’s consent procedure and contact options for exercising rights of access and other data subject rights, as described in Facebook’s privacy policy; Further Information: User Event Data, i.e., behavior and interest details, are processed for the purposes of targeted advertising and target group formation based on the agreement on **joint controllership** (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transmission of the data to the parent company Meta Platforms, Inc. in the USA (based on the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- **Google Ad Manager:** We use the service “**Google Ad Manager**” to place advertisements in the Google advertising network (e.g., in search results, in videos, on websites, etc.). Google Ad Manager is characterized by the fact that advertisements are displayed in real-time based on the presumed interests of the users. This allows us to display advertisements for our online offering to users who might have a potential interest in our offer or who had previously been interested in it, as well as to measure the success of the advertisements; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing terms for Google Advertising Products: Information on the services data processing terms between controllers and standard contractual clauses for third country data transfers: https://business.safety.google/adscontrollerterms. if Google acts as a processor, data processing terms for Google Advertising Products and standard contractual clauses for third country data transfers: https://business.safety.google/adsprocessorterms.
- **Google Ads and Conversion Measurement:** Online marketing procedure for the purpose of placing content and advertisements within the advertising network of the service provider (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the advertisements. Furthermore, we measure the **conversion** of the advertisements, i.e., whether the users took them as an opportunity to interact with the advertisements and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third country data transfers: https://business.safety.google/adscontrollerterms.
- **Google Ads Remarketing:** Google Remarketing, also called Retargeting, is a technology with which users who use an online service are included in a pseudonymous remarketing list, so that advertisements can be displayed to the users on other online offers based on their visit to the online service; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third country data transfers: https://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 the email address, name, residential address, or telephone number, can be transmitted to Google. The hash values are then matched with existing Google accounts of the users to better evaluate and improve the users’ interaction with the ads (e.g., clicks or views) and thus their performance; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
- **Instagram Advertisements:** Placement of advertisements within the Instagram platform and evaluation of the advertisement results; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Opt-Out Option (Objection): We refer to the privacy and advertising settings in the user profile on the Instagram platform as well as within Instagram’s consent procedure and Instagram’s contact options for exercising rights of access and other data subject rights in Instagram’s privacy policy; Further Information: User Event Data, i.e., behavior and interest details, are processed for the purposes of targeted advertising and target group formation based on the agreement on **joint controllership** (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transmission of the data to the parent company Meta Platforms, Inc. in the USA.
- **Microsoft Advertising:** Online marketing procedure for the purpose of placing content and advertisements within the advertising network of the service provider (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the advertisements. Furthermore, we measure the **conversion** of the advertisements, i.e., whether the users took them as an opportunity to interact with the advertisements and use the advertised offers (so-called Conversion). However, we only receive anonymous information and no personal information about individual users; Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://about.ads.microsoft.com/en-us; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Opt-Out Option (Objection): https://account.microsoft.com/privacy/ad-settings/.
- **UTM Parameters:** 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=plattformX&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 Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- **Reddit Pixel:** Audience and conversion measurement, target group formation, ad placement, profile formation; Service Provider: Reddit Ireland Limited, Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, D02 T292, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.reddit.com/; Legal Bases: Audience and conversion measurement, target group formation, ad display, profile formation. Privacy Policy: https://www.reddit.com/policies/privacy-policy.
- **Reddit Advertisements:** Placement of advertisements within the Reddit platform and evaluation of the advertisement results; Service Provider: Reddit Ireland Limited, Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, D02 T292, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.reddit.com/. Privacy Policy: https://www.reddit.com/policies/privacy-policy.
- **Reddit:** Social network / community and discussion platform; Service Provider: Reddit Ireland Limited, Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, D02 T292, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.reddit.com/. Privacy Policy: https://www.reddit.com/policies/privacy-policy.
- **Stackadapt:** StackAdapt 500 – 210 King St. East Toronto, ON, Canada M5A 1J7, a Demand-Side Platform, uses technologies to collect and process data for the following purposes: optimization, retargeting, marketing, analytics. In addition, it collects personal data such as: IP address, cookie ID, user agent, and referrer URL. Consent applies only to the specified purposes; Website: https://www.stackadapt.com/. Further information and details on the right to object can be found at: https://www.stackadapt.com/privacy-policy.
- **Advanced Analytics:** Analysis software with the help of which we measure the use and interaction with our offers on or in connection with Meta platforms (using so-called **events**, such as viewing posts or clicking “Like” buttons) and to obtain demographic data about our users (e.g., average age, place of residence, language used). The user data is processed by Meta for the purpose of displaying content and advertisements based on the presumed interests of the users based on user profiles. The data is only provided to us in aggregated, i.e., summarized form, so that we do not see the data of individual users. We use the results to design our content and services in a user-oriented manner; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://about.meta.com/; Data Processing Agreement: Provided by the service provider. Basis for Third Country Transfers: EU/EEA – Standard Contractual Clauses (Provided by the service provider), Switzerland – Standard Contractual Clauses (Provided by the service provider).
Presences in Social Networks (Social Media)
We maintain **online presences** within social networks and process user data in this context to communicate with the users active there or to offer information about us.
We point out that user data may be processed outside the area of the European Union. This can result in risks for the users because, for example, the enforcement of user rights could be made more difficult.
Furthermore, the data of the users within social networks are generally processed for **market research and advertising purposes**. For example, **usage profiles** can be created based on the usage behavior and resulting interests of the users. The latter may in turn be used to place advertisements inside and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are generally stored on the users’ computers, in which the usage behavior and interests of the users are stored. In addition, data independent of the devices used by the users can also be stored in the usage profiles (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the objection options (**opt-out**), we refer to the privacy policies and information of the operators of the respective networks.
Also, in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.
- **Types of Data Processed:** Contact information (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or visual messages and contributions as well as the information related to them, such as authorship details or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- **Data Subjects:** Users (e.g., website visitors, users of online services).
- **Purposes of Processing:** Communication; Feedback (e.g., collecting feedback via online form). Public relations.
- **Retention and Deletion:** Deletion according to information in the section “General Information on Data Storage and Deletion.”
- **Legal Bases:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- **Instagram:** Social network, enables sharing of photos and videos, commenting on and favoring posts, sending messages, subscribing to profiles and pages; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- **Facebook Pages:** Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of the visitors to our Facebook page (so-called “**Fanpage**”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analysis services, so-called “**Page Insights**,” to page operators so that they can gain insights into how people interact with their pages and with the content associated with them. We have concluded a special agreement with Facebook (“Information about Page Insights,” https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, address requests for information or deletion directly to Facebook). The rights of users (in particular to access, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “**Information about Page Insights**” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transmission of the data to the parent company Meta Platforms, Inc. in the USA; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- **Facebook Groups:** We use the “**Groups**” function of the Facebook platform to create interest groups within which Facebook users can contact each other or us and exchange information. In this context, we process personal data of the users of our groups to the extent necessary for the purpose of group use and their moderation. Our guidelines within the groups may contain further requirements and information on the use of the respective group. This data includes details on first and last names, as well as published or privately communicated content, as well as values on the status of group membership or group-related activities, such as joining or leaving, as well as the time information for the aforementioned data. Furthermore, we refer to the processing of user data by Facebook itself. This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analysis services, so-called “**Insights**,” to group operators so that they can gain insights into how people interact with their groups and with the content associated with them; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
Plug-ins and Embedded Functions and Content
We integrate function and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “**third-party providers**”). These can be, for example, graphics, videos, or city maps (hereinafter uniformly referred to as “**content**”).
The integration always requires that the third-party providers of this content process the **IP address** of the users, as they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to only use such content whose respective providers only use the IP address for the delivery of the content. Third-party providers can also use so-called **pixel tags** (invisible graphics, also referred to as “**web beacons**”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in **cookies** on the users’ device and may contain technical information about the browser and the operating system, referring websites, visit time, and further details on the use of our online offering, but can also be combined with such information from other sources.
Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is **permission**. Otherwise, the user data is processed on the basis of our **legitimate interests** (i.e., interest in efficient, economic, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- **Types of Data Processed:** Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons). Event Data (Facebook) (“Event Data” are information that is sent to the provider Meta, for example, via Meta Pixel (whether via apps or other channels) and relates to persons or their actions. This data includes, for example, details on website visits, interactions with content and functions, app installations, and product purchases. The processing of Event Data takes place with the aim of creating target groups for content and advertising messages (**Custom Audiences**). It is important to note that Event Data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or telephone numbers. “Event Data” is deleted by Meta after a maximum of two years, and the target groups created from it disappear with the deletion of our Meta user accounts.).
- **Data Subjects:** Users (e.g., website visitors, users of online services).
- **Purposes of Processing:** Provision of our online offering and user-friendliness.
- **Retention and Deletion:** Deletion according to information in the section “General Information on Data Storage 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 Bases:** Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- **Google Fonts (Retrieval from Google Server):** Retrieval of fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and consideration of possible license restrictions. The **IP address** of the user is communicated to the font provider so that the fonts can be provided in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, used hardware) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the font provider in the USA – When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the **IP address** used by the respective user to access the internet, (2) the requested **URL** on the Google server, and (3) the **HTTP headers**, including the User-Agent, which describes the browser and operating system versions of the website visitors, and the **referrer URL** (i.e., the website on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, User-Agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a specific font family is requested. With the Google Fonts Web API, the User-Agent must adapt the font that is generated for the respective browser type. The User-Agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the page “Analytics” of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. Google uses according to its own statement none of the information collected by Google Fonts to create profiles of end-users or to display targeted advertisements; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Further Information: https://developers.google.com/fonts/faq/privacy?hl=de.
- **Facebook Plugins and Content:** Facebook Social Plugins and content – This can include, for example, content such as images, videos, or texts and buttons with which users can share content of this online offering within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of “**Event Data**” that Facebook collects via the Facebook social plugins (and content embedding functions) executed on our online offering or receives as part of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, address requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., contain no information about individual users and are anonymous for us), then this processing does not take place within the scope of joint controllership, but on the basis of a **data processing agreement** (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “**Data Security Terms**” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the USA on the basis of **Standard Contractual Clauses** (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to access, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for Third Country Transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
- **Google Hosted Libraries:** Google Hosted Libraries is a globally available **Content Delivery Network (CDN)** for the most popular open-source JavaScript libraries. These serve to provide web libraries to optimize website loading times, reduce bandwidth usage, and improve performance by using shared, public resources; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://developers.google.com/speed/libraries/. Privacy Policy: https://policies.google.com/privacy.
- **Font Awesome (Retrieval from the Provider’s Server):** Retrieval of fonts (as well as symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and consideration of possible license restrictions. The **IP address** of the user is communicated to the font provider so that the fonts can be provided in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, used hardware) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment; Service Provider: Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fontawesome.com/. Privacy Policy: https://fontawesome.com/privacy.
Management, Organization and Auxiliary Tools
We use services, platforms, and software from other providers (hereinafter referred to as “**third-party providers**”) for the purposes of organizing, administering, planning, and providing our services. In the selection of third-party providers and their services, we observe the legal requirements.
In this context, **personal data** can be processed and stored on the servers of the third-party providers. Various data that we process according to this privacy policy may be affected by this. This data may include, in particular, master data and contact data of the users, data on transactions, contracts, other processes, and their contents.
If users are referred to the third-party providers or their software or platforms in the context of communication, business, or other relationships with us, the third-party providers can process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask that you observe the privacy notices of the respective third-party providers.
- **Types of Data Processed:** Content data (e.g., textual or visual messages and contributions as well as the information related to them, such as authorship details or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- **Data Subjects:** Communication partners. Users (e.g., website visitors, users of online services).
- **Purposes of Processing:** Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
- **Retention and Deletion:** Deletion according to information in the section “General Information on Data Storage and Deletion.”
- **Legal Bases:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Amendment and Update
We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or another individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that the addresses may change over time and ask you to check the information before contacting them.
Definitions of Terms
In this section, you will receive an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.
- **A/B Tests:** A/B tests serve to improve the user-friendliness and performance of online offerings. For example, users are presented with different versions of a website or its elements, such as input forms, where the placement of the content or the labels of the navigation elements may differ. Subsequently, based on the behavior of the users, e.g., longer dwell time on the website or more frequent interaction with the elements, it can be determined which of these websites or elements better meet the needs of the users.
- **Master Data:** Master data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unambiguous assignment and communication.
- **Content Delivery Network (CDN):** A “**Content Delivery Network**” (CDN) is a service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed and internet-connected servers.
- **Cross-Device Tracking:** Cross-Device Tracking is a form of **tracking** in which user behavior and interest information is recorded across devices in so-called **profiles** by assigning an online identifier to the users. This allows the user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). The online identifier is not linked to clear data, such as names, postal addresses, or email addresses, for most providers.
- **Content Data:** Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not only limited to the actual content but also includes **metadata** that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
- **Click Tracking:** Click tracking allows monitoring user movements within an entire online offering. Since the results of these tests are more accurate if user interaction can be tracked over a certain period of time (e.g., so that we can find out whether a user likes to return), **cookies** are generally stored on the users’ computers for these test purposes.
- **Contact Information:** Contact information is essential information that enables communication with individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- **Conversion Measurement:** Conversion measurement (also referred to as “visit action evaluation”) is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a **cookie** is generally stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements placed by us on other websites were successful.
- **Artificial Intelligence (AI):** The purpose of processing data by Artificial Intelligence (AI) includes the automated analysis and processing of user data to recognize patterns, make predictions, and improve the efficiency and quality of our services. This includes the collection, cleansing, and structuring of the data, the training and application of AI models, as well as the continuous review and optimization of the results and takes place exclusively with the user’s **consent** or on the basis of legal permission bases.
- **Meta, Communication, and Procedural Data:** Meta, communication, and procedural data are categories that contain information about the way in which data is processed, transmitted, and managed. **Meta-data**, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include information on file size, creation date, the author of a document, and change histories. **Communication data** records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the people involved, time stamps, and transmission paths. **Procedural data** describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify processes.
- **Usage Data:** Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages, and the paths they navigate through 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 analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in recognizing trends, preferences, and potential problem areas within digital offerings.
- **Personal Data:** “**Personal Data**” means any information relating to an identified or identifiable natural person (hereinafter “**data subject**”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- **Profiles with User-Related Information:** The processing of “**profiles with user-related information**,” or “**profiles**” for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include different information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website, or location). **Cookies** and **web beacons** are often used for the purpose of profiling.
- **Log Data:** Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as time stamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to generate performance reports.
- **Audience Measurement:** Audience measurement (also referred to as **Web Analytics**) serves to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of audience analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. Pseudonymous **cookies** and **web beacons** are often used for the purpose of audience analysis to recognize recurring visitors and thus obtain more accurate analyzes of the use of an online offering.
- **Remarketing:** “**Remarketing**” or “**Retargeting**” is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g., in advertisements.
- **Tracking:** “**Tracking**” is when the behavior of users can be tracked across several online offerings. As a rule, behavior and interest information is stored in **cookies** or on the servers of the providers of the tracking technologies with regard to the online offerings used (so-called **profiling**). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
- **Controller:** The “**Controller**” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- **Processing:** “**Processing**” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it the collection, evaluation, storage, transmission, or deletion.
- **Contract Data:** Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This data category is essential for the administration and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include start and end dates of the contract, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
- **Payment Data:** Payment data includes all information required to process payment transactions between buyers and sellers. This data is of crucial importance for electronic commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and billing information. Payment data can also contain information about the payment status, chargebacks, authorizations, and fees.
- **Target Group Formation:** “**Target Group Formation**” (English “**Custom Audiences**”) is when target groups for advertising purposes, e.g., displaying advertisements, are determined. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he viewed the products. “**Lookalike Audiences**” (or similar target groups) is when the content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. **Cookies** and **web beacons** are generally used for the purpose of forming Custom Audiences and Lookalike Audiences.