Privacy Policy

knowing.finance by fctb. GmbH

As knowing.finance by fctb GmbH is registered in Germany/Aachen HRB 24126. We are committed and compliant with German law.

Below is a translated Privacy Police, which can be found in the original version here:

https://www.knowing.finance/datenschutz

Preamble

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender specific.

 

Table of contents

  • Preamble
  • Responsible
  • Processing overview
  • Relevant legal bases
  • Security measures
  • International data transfers
  • Data deletion
  • Rights of the data subjects
  • Cookies use
  • Business services
  • Payment method
  • Provision of the online offer and web hosting
  • Registration, login and user account
  • Blogs and publication media
  • Contact and request management
  • Communication via messenger
  • Chatbots and chat functions
  • Video conferencing, online meetings, webinars and screen sharing
  • Application procedure
  • Cloud services
  • Newsletter and electronic notifications
  • Promotional communication via e-mail, mail, fax or telephone
  • Web analysis, monitoring and optimisation
  • Digital badges
  • Presence in social networks (social media)
  • Plugins and embedded functions and content

Responsible

knowing.finance by fctb. GmbH
Dirk Emminger
Kaisersruher Str. 95
52146 Wuerselen
Germany

E-mail address:

admin@knowing.finance

Imprint:

https://www.knowing.finance/imprint

Processing Overview

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

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Applicant Data.

Categories of persons concerned

  • Customers
  • Employees.
  • Interested parties.
  • Communication partner.
  • Users.
  • Applicants.
  • Business and Contractual Partners.
  • Persons depicted.

Processing purposes

  • Provision of contractual services and fulfilment of contractual obligations.
  • Contact requests and communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organisational procedures.
  • Managing and responding to inquiries.
  • Application Procedure.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information Technology Infrastructure.
  • Public relations and information purposes.

Relevant legal bases

Relevant legal bases according to the DSGVO/GDPR: The following is an overview of the legal basis of the DSGVO/GDPR based on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 (1) p. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Contract performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 6 (1) p. 1 lit. b) DSGVO) – Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the data controller or the data subject can exercise the rights accruing to him or her under labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. DSGVO.
  • Processing of special categories of personal data relating to healthcare, occupation and social security (Art. 9(2)(h) GDPR).
  • Consent to processing of special categories of personal data (Art. 9(2)(a) GDPR).
  • Processing of special categories of personal data for the protection of vital interests (Art. 9(2)(c) GDPR).

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Applicable legal basis under the Swiss Data Protection Act: If you are in Switzerland, we process your data on the basis of the Federal Data Protection Act (in short “Swiss DPA”). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss DPA does not require (unlike the GDPR, for example) that a legal basis for the processing of personal data must be stated. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 (1) and (2) of the Swiss DPA). Furthermore, we obtain personal data only for a specific purpose that is identifiable to the data subject and process it only in a way that is compatible with those purposes (Art. 6 para. 3 of the Swiss FADP).

Note on applicability DSGVO and Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (DSGVO). 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 DPA, 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 in accordance with the Swiss DPA within the scope of its application.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

IP address shortening: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not required, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.

TLS/SSL encryption (https): To protect user data transmitted through our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing Internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) appears in the URL when a website is secured by an SSL/TLS certificate.

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 DSGVO), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular by standard contractual clauses (Art. 46(2)(c) DSGVO), explicit consent or in the case of contractual or legally required transfers (Art. 49(1) DSGVO). In all other respects, we will inform you of the basis for third-country transfers in the case of individual third-country providers, with the adequacy decisions taking precedence as the basis. Information on third country transfers and existing adequacy decisions can be found in the EU Commission’s information offer: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.

EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/. We will inform you in the privacy notices which service providers we use are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DSG). If the Federal Council has not determined that adequate protection is provided (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country.

According to Art. 16 of the Swiss FADP, exceptions may be allowed for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person. Within the scope of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that applies specifically to the respective processing operations.

Rights of the data subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another responsible party.
  • Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:

  • Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive such information as is necessary to enable you to exercise your rights under this law and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data that you have disclosed to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data, as well as to request that the personal data concerning you be erased or destroyed.

Cookies use

Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the telemedia service (i.e., our online offering) expressly requested by users. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer , load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent will be clearly communicated to the users and will contain the information regarding the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: In terms of 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 his or her end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (so-called “opt-out”): Users can revoke the consents they have given at any time and object to processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Compliance: Cookie consent management; Service provider: Hosted locally on our server, no data sharing with third parties; Website: https://complianz.io/; Privacy Policy: https://complianz.io/legal/. Additional Information: An individual user ID, language, as well as types of consents and the time of their submission are stored on the server side and in the cookie on the users’ device.

Business services

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

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

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

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

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

  • Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., e-mail, telephone numbers); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Affected persons: Customers; prospective customers. Business and contractual partners.
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures. Management and response to requests.
  • Legal basis: Contract fulfillment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Customer account: Customers can create an account within our online offer (e.g. customer or user account, “customer account” for short). If registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be deleted after the termination date, unless they are kept for purposes other than the provision in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the responsibility of the customers to secure their data upon termination of the customer account; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Consulting: We process the data of our clients, customers as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

    If it is necessary for the fulfillment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as public authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the requirements of professional law;
    Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

  • Management consulting: We process the data of our customers, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.

    If it is necessary for our contract fulfillment or required by law, or if we have the customer’s consent, we disclose or transfer the customer’s data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with the requirements of professional law;
    Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Payment method

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively, “payment service providers”).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy policy of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

  • Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status).
  • Affected persons: Interested parties.
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

  • PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third country transfers: EU-US Data Privacy Framework (DPF).

Provision of the online offer and web hosting

We process the users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).). Security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
  • ALL-INKL: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://all-inkl.com/; Privacy policy: https://all-inkl.com/datenschutzinformationen/. Order processing agreement: Provided by the service provider.

Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes.

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • 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; management and response to requests. Provision of our online offer and user friendliness.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Registration with clear name: Due to the nature of our community, we ask users to use our offer only by using clear names. I.e. the use of pseudonyms is not permitted; Legal basis: Contract fulfillment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Setting the visibility of profiles: Users can use settings to determine the extent to which their profiles are visible or accessible to the public or only to certain groups of people; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • No obligation to retain data: It is the responsibility of the users to save their data upon termination before the end of the contract. We are entitled to irretrievably delete all of the user’s data stored during the term of the contract; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Blogs and publication media

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

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness. Security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Akismet Anti-Spam Check: Akismet Anti-Spam Check – We use the service “Akismet” based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.

    Users are welcome to use pseudonyms or to refrain from entering their name or email address. They can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any alternatives that work as effectively;
    Service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy. Basis for third country transfers: EU-US Data Privacy Framework (DPF).

  • UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd, 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://updraftplus.com/. Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.

Contact and request management

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

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online offer and user friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

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

Communication via messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.

You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note 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 Messenger with encryption enabled to ensure that message content is encrypted.

However, we additionally point out to our communication partners that the providers of the messengers cannot view the content, but can learn that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

Notes on legal basis: 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. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke any consent given and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., 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 provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.

Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case if, for example, internal contractual information requires special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (e.g. .by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third country transfers: EU-US Data Privacy Framework (DPF).

Chatbots and chat functions

We offer online chats and chatbot functions (collectively referred to as “chat services”) as a communication option. A chat is an online conversation conducted with some timeliness. A chatbot is software that answers users’ questions or notifies them of messages. When you use our chat features, we may process your personal data.

If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may 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 in order to be able to prove them according to legal requirements.

We would like to point out to users that the respective platform provider can find out that and when users communicate with our chat services as well as collect technical information about the device used by the users and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e., e.g., information about who communicated with whom) may be used by the respective platform providers for marketing purposes or to display advertisements tailored to users in accordance with their terms and conditions, to which we refer for further information.

If users agree with a chatbot to activate information with regular messages, they have the option to unsubscribe from the information at any time in the future. The chatbot instructs users how and with which terms they can unsubscribe from the messages. Unsubscribing from chatbot messages deletes users’ data from the list of message recipients.

We use the aforementioned information to operate our chat services, for example, to personally address users, to respond to their inquiries, to deliver 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 basis: We use chat services on the basis of consent if we have previously obtained 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 sends them messages on a regular basis). If we use chat services to answer users’ inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services based on our legitimate interests in optimizing the chat services, their operational efficiency, and increasing the positive user experience.

Revocation, objection and deletion: You can revoke a given consent or object to the processing of your data within the scope of our chat services at any time.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. web pages visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (e.g. .by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • HubSpot: Chatbot and assistance software and associated services; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Third country transfer basis: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.hubspot.com/dpa).

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

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

Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent – if necessary.

Data privacy measures of the participants: Please observe the data privacy notices of the conference platforms regarding the details of the processing of your data and select the security and data privacy settings that are optimal for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g., by notifying roommates, locking doors, and using the background obscuring function, if technically possible). Links to the conference rooms as well as access data, may not be disclosed to unauthorized third parties.

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

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Communication partners; users (e.g., Web site visitors, users of online services). Persons depicted.
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations; contact requests and communication. Office and organizational procedures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Google Hangouts / Meet: conferencing and communication software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://hangouts.google.com/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
  • Microsoft Teams: Conferencing and communication software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
  • Zoom: Conferencing and communication software; Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Order Processing Agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA). Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA)).

Application procedure

The application process requires applicants to provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.

Basically, the required information includes personal information such as the name, address, a means of contact and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information about which details are required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services of third-party providers in compliance with the legal requirements.

Applicants are welcome to contact us regarding the method of application submission or to send us the application by mail.

Processing of special categories of data: If special categories of personal data (Art. 9(1) GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, they are processed so that the data controller or the data subject can exercise the rights accruing to him or her under employment law and social security and social protection law and fulfill his or her obligations in this regard. In the case of the protection of the vital interests of applicants or other persons, or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, for health or social care or treatment, or for the management of health or social care systems and services.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, the deletion will take place at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and comply with our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided by applicants voluntarily or with regard to a specific position or their qualifications).
  • Affected Persons:
  • Purposes of the processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 (1) p. 1 lit. b) GDPR); processing of special categories of personal data related to healthcare, occupation and social security (Art. 9 (2) h) GDPR); consent to processing of special categories of personal data (Art. 9 (2) a) GDPR). Processing of special categories of personal data for the protection of vital interests (Art. 9 (2) (c) GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

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

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

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Customers; employees (e.g., employees, applicants, former employees); prospective customers; communication partners; users (e.g., website visitors, users of online services).
  • Purposes of processing: office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Google Cloud Storage: Cloud storage, cloud infrastructure services and cloud-based application software; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Grounds: Legitimate Interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Order Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Basis Third Country Transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.
  • Google Workspace: Cloud-based application software (e.g. text and spreadsheet editing, appointment and contact management), cloud storage and cloud infrastructure services; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://workspace.google.com/; Privacy Policy: https://policies.google.com/privacy; Order Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Basis Third Country Transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.
  • Microsoft Cloud Services: cloud storage, cloud infrastructure services and cloud-based application software; Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter; Order processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Newsletter and electronic notifications

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

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

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

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

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status); usage data (e.g., websites visited, interest in content, access times).
  • Affected persons: Communication partners.
  • Purposes of processing: direct marketing (e.g. .by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • 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 will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Further guidance on processing operations, procedures and services:

  • Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

    This information is used
    for the technical improvement of our newsletter 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 the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the evaluations to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

     The measurement of opening rates and click rates as well as storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent.

     A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription
    must be cancelled, or it must be contradicted. In this case, the stored profile information will be deleted;
    Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

  • HubSpot: Email sending and automation services; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.hubspot.com/dpa).

Promotional communication via e-mail, mail, fax or telephone

We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.

After revocation or objection, we store the data required to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g., depending on the communication channel, the e-mail address, telephone number, name).

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
  • Affected persons: Communication partners.
  • Purposes of processing: direct marketing (e.g. .by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Web analysis, monitoring and optimization

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

In addition to web analytics, we may also use testing procedures, for example, 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 a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, we do not store any clear user data (such as e-mail addresses or names) for the purposes of web analysis, A/B testing and optimization, but rather pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offer and user friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: City (and the 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 derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for any other purpose. When Google Analytics collects measurement data, all IP queries 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 basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad Display Settings: https://adssettings.google.com/authenticated. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

Digital badges

Digital badges, also referred to as open badges (hereinafter “badges” for short), are digital certificates that confirm the skills, achievements, and interests of individuals or organizations. They are issued by credible organizations. Badges are accompanied by metadata and information about the skills and achievements acquired. Typically, badges are represented by an image or a digital certificate that contains details about the recipient, issuer, metadata, and other relevant information.

When badges are issued individually to specific individuals, the metadata stored in the badges and used for attribution purposes regarding the skills, achievements and interests of the individuals concerned are processed.

If cookies and comparable technologies are used in the context of the badges that are not required and therefore or otherwise require the consent of the users, we obtain the appropriate consent of the users and inform them accordingly.

  • Types of data processed: inventory data (e.g., names, addresses); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and process data (e.g., IP addresses, time data, identification numbers, consent status).
  • Data subjects: Business and contractual partners; users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations; public relations and information purposes. Provision of our online offer and user friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Embedding of digital badges: As part of our online offer, we integrate badges from other sources (so-called “embedding”). This means that both the representation of the badge and the associated metadata are output within our offer. In doing so, they are loaded in real time from the servers of the respective badge provider in order to always present the most current content of the badge. To realize this, a data connection is established between our online offer and the server of the badge provider. The technical data that the badge provider receives includes the IP address, details and metadata of the badge, information about the website visited, the time of the call and technical details about the browser and system as they are transmitted from the end device to the server. This data transmission also informs the badge provider that a user has accessed our online offer; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Presence in social networks (social media)

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

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

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

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

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. web pages visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Basis third country transfer: Standard Contractual Clauses (https://legal.linkedin.com/dpa). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO). Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer as well as be combined with such information from other sources.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness; marketing. Profiles with user-related information (creation of user profiles).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • LinkedIn Plugins and Content: LinkedIn plugins and content- This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Basis third country transfer: standard contractual clauses (https://legal.linkedin.com/dpa). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • X plugins and content: Plugins and buttons of the platform “X” – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within X; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://twitter.com/de; Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization); Order processing agreement: https://privacy.twitter.com/en/for-our-partners/global-dpa. Basis third country transfer: Standard Contractual Clauses (https://privacy.twitter.com/en/for-our-partners/global-dpa).
 
Status: Febuary 3, 2024

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