Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly 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 in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the "online offering").
The terms used are not gender-specific.
As of: 11 May 2026
Table of Contents
- Preamble
- Controller
- Data Protection Officer Contact
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transmission of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of Data Subjects
- Business Services
- Payment Methods
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Registration, Login and User Account
- Contact and Enquiry Management
- Newsletters and Electronic Notifications
- Promotional Communication via Email, Post, Fax or Telephone
- Surveys and Questionnaires
- Web Analytics, Monitoring and Optimisation
- Presence on Social Networks (Social Media)
- Privacy Information for Whistleblowers
- Changes and Updates
- Definitions
Controller
FORSIT Industrial GmbH
In der Raste 12
53129 Bonn
Authorised representatives: Matthias Piksa
Email address: datenschutz@forsit.de
Imprint: https://luupin.app/imprint
Data Protection Officer Contact
Nico Hartlieb-Weigner
datenschutz@forsit.de
Overview of Processing Activities
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of Data Processed
- Master data.
- Employee data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Log data.
Special Categories of Data
- Health data.
Categories of Data Subjects
- Service recipients and clients.
- Employees.
- Prospective customers.
- Communication partners.
- Users.
- Business and contractual partners.
- Participants.
- Third parties.
- Whistleblowers.
Purposes of Processing
- Provision of contractual services and fulfilment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Office and organisational procedures.
- Organisational and administrative procedures.
- Feedback.
- Surveys and questionnaires.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Whistleblower protection.
- Public relations.
- Sales promotion.
- Business processes and operational procedures.
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 provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Should more specific legal bases be applicable in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6(1)(a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual enquiries (Article 6(1)(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.
- Legal obligation (Article 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Article 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests or fundamental rights and freedoms of the data subject which require protection of personal data do not override those interests.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include in particular the Act on Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains specific provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of individual German federal states may apply.
Security Measures
In accordance with legal requirements and taking into account the state of the art, implementation costs, and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input of, disclosure of, ensuring availability of, and segregation of the data. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection by design and by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorised access, we use 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 unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transfers comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and in encrypted form.
Transmission of Personal Data
In the course of our processing of personal data, it may be transmitted to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of such data may include, for example, service providers tasked with IT duties, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and in particular conclude appropriate contracts or agreements serving to protect your data with the recipients of your data.
Data transmission within the organisation: We may transmit personal data to other departments or units within our organisation or grant them access to it. Where data is shared for administrative purposes, it is based on our legitimate business and operational interests, or is carried out where necessary for the performance of our contractual obligations, or where there is consent from the data subjects or a legal authorisation to do so.
International Data Transfers
Data processing in third countries: Where we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in the course of using third-party services or disclosing or transferring data to other persons, bodies or companies (as identifiable from the postal address of the respective provider, or where the privacy policy expressly refers to data transfers to third countries), this is always done in compliance with legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, while the standard contractual clauses serve as an additional safeguard. Should changes arise within the DPF framework, the standard contractual clauses act as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.
For individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about 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, appropriate safeguards 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.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is 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 needed. Exceptions to this rule exist where statutory obligations or special interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the assertion of legal claims or the protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.
Where multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always prevails. Data that is no longer retained for its originally intended purpose but is retained due to statutory requirements or other reasons is processed exclusively for the reasons justifying its 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, and the operating instructions and other organisational 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 records, such as invoices and cost receipts (§ 147(1) Nos. 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, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, cost accounting records, calculation documents, price labels, as well as payroll documents insofar as they are not already accounting records and cash register receipts (§ 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 damage claims or similar contractual claims and rights, and to process related enquiries, based on prior business experience and standard industry practice, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Start of period at end of year: Where a period does not explicitly begin on a specific date and is at least one year long, 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 the context of which data is stored, the triggering event is the time at which the termination takes effect or when the legal relationship otherwise ends.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right, on grounds relating to your particular situation, to object at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent given at any time.
- Right of access: You have the right to obtain confirmation as to whether data concerning you is being processed, and to access such data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with legal requirements.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.
Business Services
We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively referred to as "contractual partners"), for the purpose of initiating, performing and handling contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures taken at their request, as well as communication in connection with the respective contractual relationship.
The processing serves in particular the fulfilment of our primary and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the handling of warranty claims and other service disruptions, the processing of withdrawals, terminations of ongoing obligations, reversal of transactions, refunds, and the handling of other contract-related declarations and enquiries. Both one-off contracts and ongoing contractual relationships are covered.
Data processed includes in particular master data such as name, address and, where applicable, company name, contact data such as email address and telephone number, contract and service data such as the subject matter of the contract, contract duration, order or transaction number, usage and service data, payment and billing data, as well as the content and history of communications. Where necessary, we also process data disclosed or transmitted to us in the course of performing an assignment.
We also process the data to protect our rights and to fulfil legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations, and where applicable, obligations to provide evidence and to account. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as the protection of our business operations and our contractual partners from misuse, threats to data, trade secrets and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, to the extent this is necessary for the performance of the contract or for the fulfilment of legal obligations.
Personal data is only disclosed to third parties to the extent necessary for the performance of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests or for the fulfilment of legal obligations. We provide separate information about any further processing, in particular for marketing purposes, within this privacy policy.
We inform contractual partners of which data is required in each individual case during the data collection process, for example in online forms by means of appropriate labelling or in personal contact.
Data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations preclude deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific assignment is deleted after completion of the assignment and expiry of any retention periods, unless further statutory or contractual obligations to retain the data exist.
The legal basis for the processing is Article 6(1)(b) GDPR for the implementation of pre-contractual measures and performance of the respective contractual relationship, and Article 6(1)(c) GDPR for the fulfilment of legal obligations. Where processing is based on legitimate interests, it is carried out on the basis of Article 6(1)(f) GDPR. Where processing is based on Article 6(1)(f) GDPR, it is carried out to protect our legitimate interests in proper and efficient business organisation, internal administration and documentation of business transactions, the enforcement and defence of legal claims, ensuring IT and data security, preventing misuse and fraud, as well as the economic management and further development of our business operations. These interests lie in particular in ensuring secure and legally compliant business operations as well as in maintaining our operational capacity.
- Types of data processed: Master data (e.g. full name, home 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 matter of contract, duration, customer category).
- Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Communication; Office and organisational procedures; Organisational and administrative procedures. Business processes and operational procedures.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR); Legal obligation (Article 6(1)(c) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- Project and development services: We process the data of our customers and clients (hereinafter collectively referred to as "customers") in order to enable them to select, acquire or commission the chosen services or works and related activities, as well as to pay for and receive or have executed or performed such services.
The required information is identified as such in the context of the assignment, order or comparable contract conclusion and includes the information required to provide the services and for billing purposes, as well as contact information to enable any follow-up queries. To the extent we gain access to information of end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR).
Payment Methods
In the context of contractual and other legal relationships, on the basis of statutory obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, in addition to banks and credit institutions, use further service providers for this purpose (collectively "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected from unauthorised access during transmission.
Data processed by the payment service providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is necessary to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. That is, we do not receive any account- or credit card-related information, but only information confirming or declining the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is intended to verify identity and creditworthiness. In this regard, we refer to the terms and conditions and privacy notices of the payment service providers.
The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions, and these can be accessed on the respective websites or transaction applications. We also refer to these for further information and for exercising the right of withdrawal, rights of access and other data subject rights.
- Types of data processed: Master data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of contract, duration, customer category); Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations. Business processes and operational procedures.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- Stripe: Payment services (technical integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
Provision of the Online Offering and Web Hosting
We process users' data in order 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 device.
- Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved); Log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or pictorial messages and posts, as well as related information such as details of authorship or time of creation).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: 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.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- Provision of the 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 referred to as a "web host"); Legal bases: Legitimate interests (Article 6(1)(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". 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 retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), and generally IP addresses and the requesting provider. Server log files can be used for security purposes, e.g. to avoid overloading the servers (in particular in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Article 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
- Email sending and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of recipients and senders, as well as further information regarding the email transmission (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails on the internet are generally not sent in encrypted form. While emails are typically encrypted during transmission, they are generally not encrypted on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore not take responsibility for the transmission path of emails between the sender and receipt on our server; Legal bases: Legitimate interests (Article 6(1)(f) GDPR).
Use of Cookies
The term "cookies" refers to functions that store and retrieve information on users' devices. Cookies may also be used for different purposes, such as to ensure the functionality, security and convenience of online offerings and to create analyses of visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain users' prior consent. Where consent is not required, we rely on our legitimate interests. This applies where the storage and retrieval of information is essential in order to provide content and functions that have been expressly requested. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We provide clear information about its scope and the cookies used.
Notes on the legal bases under data protection law: Whether we process personal data using cookies depends on consent. Where consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are set out above in this section and in the context of the respective services and procedures.
Storage duration: The following types of cookies are distinguished with regard to storage duration:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest once a user has left an online offering and closed their device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device has been closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Similarly, user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), they should assume that cookies are permanent and that the storage period may be up to two years.
General information on withdrawal and objection (opt-out): Users may withdraw the consent they have given at any time and also object to processing in accordance with legal requirements, including by means of their browser's privacy settings.
- Types of data processed: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Article 6(1)(f) GDPR). Consent (Article 6(1)(a) GDPR).
Further notes on processing activities, procedures and services:
- Processing of cookie data on the basis of consent: We use a consent management solution by which the consent of users for the use of cookies, or for the procedures and providers referred to in the consent management solution, is obtained. This procedure is used to obtain, record, manage and withdraw consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' devices. As part of this procedure, users' consents are obtained for the use of cookies and the related processing of information, including the specific processing activities and providers referred to in the consent management procedure. Users also have the option to manage and withdraw their consents. Consent declarations are stored in order to avoid the need for repeat queries and to be able to demonstrate consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies, in order to assign consent to a specific user or their device. Where no specific information is available about the providers of consent management services, the following general notes apply: The storage duration of the consent is up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information about the scope of consent (e.g. categories of cookies and/or service providers concerned) and information about the browser, system and device used; Legal bases: Consent (Article 6(1)(a) GDPR).
Registration, Login and User Account
Users may create a user account. In the course of registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligations. The data processed includes in particular login information (username, password and an email address).
In the course of using our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. Storage takes place on the basis of our legitimate interests, as well as those of users, in protection from misuse and other unauthorised use. This data is generally not disclosed to third parties unless it is necessary to pursue our claims or there is a statutory obligation to do so.
Users may be informed by email of events relevant to their user account, such as technical changes.
- Types of data processed: Master data (e.g. full name, home 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 posts, as well as related information such as details of authorship or time of creation); Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Security measures; Organisational and administrative procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion". Deletion upon termination.
- Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- Registration with pseudonyms: Users may use pseudonyms as usernames instead of their real names; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR).
- User profiles are not public: User profiles are not publicly visible or accessible.
- Deletion of data upon termination: If users have terminated their user account, their data relating to the user account will be deleted subject to a legal authorisation, obligation or consent of the users; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR).
- No obligation to retain data: It is the users' responsibility to back up their data before the end of the contract upon termination. We are entitled to irreversibly delete all data stored by the user during the contract period; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR).
Contact and Enquiry Management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the enquiring persons is processed to the extent necessary to respond to the contact enquiries and any requested measures.
- Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts, as well as related information such as details of authorship or time of creation). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; Organisational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Article 6(1)(f) GDPR). Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR).
Further notes on processing activities, 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 in order to respond to and handle the respective enquiry. This generally includes information such as name, contact details and, where applicable, further information provided to us and required for appropriate handling. We use this data exclusively for the stated purpose of making contact and communicating; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1)(b) GDPR), Legitimate interests (Article 6(1)(f) GDPR).
Newsletters and Electronic Notifications
We send newsletters, emails and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or on a statutory basis. Where the contents of the newsletter are specifically described during sign-up, those contents are decisive for users' consent. To sign up for our newsletter, it is normally sufficient to provide your email address. However, in order to offer you a personalised service, we may ask for your name for a personal salutation in the newsletter, or for further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may retain 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 demonstrate previously given consent. The processing of this data is restricted to the purpose of potential defence 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 email address for this purpose alone in a block list (so-called "blocklist").
The logging of the sign-up process takes place on the basis of our legitimate interests for the purpose of demonstrating that it proceeded correctly. Where we engage a service provider to send emails, 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: Master data (e.g. full name, home address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Special categories of personal data: Health data.
- Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post). Provision of contractual services and fulfilment of contractual obligations.
- Legal bases: Consent (Article 6(1)(a) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
- Opt-out option: You may unsubscribe from our newsletter at any time, i.e. withdraw your consent, or object to receiving it further. A link to unsubscribe from the newsletter can be found either at the end of each newsletter, or you may otherwise use one of the contact options provided above, preferably by email.
Further notes on processing activities, 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 the server of our sending service provider if we use one, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of retrieval, are first collected. This information is used for the technical improvement of our newsletter based on technical data or target groups and their reading behaviour based on their retrieval locations (the; Legal bases: Consent (Article 6(1)(a) GDPR).
- Consent to free services as a prerequisite: Consent to receive mailings may be made a prerequisite for using free services (e.g. access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
- Rapidmail: Sending emails to recipient lists (lists of email addresses), managing and maintaining these lists, creating and designing email templates, analysing delivery and open rates (how often an email was opened or clicked); Service provider: Positive Group Deutschland GmbH, Ingeborg-Krummer-Schroth-Straße 18a, 79106 Freiburg im Breisgau, Germany; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.rapidmail.de; Privacy policy: https://www.rapidmail.de/datenschutz. Data processing agreement: https://www.rapidmail.de/hilfe/datenschutzvertrag-nach-eu-dsgvo-abschliessen.
Promotional Communication via Email, Post, Fax or Telephone
We process personal data for the purposes of promotional communication, which may take place via various channels such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw consent given at any time or to object to promotional communication at any time free of charge using the contact options listed above.
Following withdrawal or objection, we may store the data required to demonstrate the previous authorisation to make contact or send communications for up to three years after the end of the year of withdrawal or objection, on the basis of our legitimate interests. The processing of this data is restricted to the purpose of potential defence against claims. On the basis of our legitimate interest in permanently observing the withdrawal or objection by users, we also store the data required to avoid renewed contact (e.g. depending on the communication channel: email address, telephone number, name).
- Types of data processed: Master data (e.g. full name, home 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 posts, as well as related information such as details of authorship or time of creation).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post); Marketing. Sales promotion.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Consent (Article 6(1)(a) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
Surveys and Questionnaires
We conduct surveys and questionnaires in order to gather information for the respective communicated survey or questionnaire purpose. The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed to the extent necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed using a cookie).
- Types of data processed: Master data (e.g. full name, home 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 posts, as well as related information such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Participants.
- Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Surveys and questionnaires (e.g. surveys with input options, multiple choice questions).
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- LimeSurvey: Conducting online surveys; Service provider: LimeSurvey GmbH Umfragedienste & Beratung, Papenreye 63, 22453 Hamburg, Germany; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.limesurvey.org/de. Privacy policy: https://www.limesurvey.org/de/datenschutzhinweise.
Web Analytics, Monitoring and Optimisation
Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. Using reach analysis, we can for example recognise at what time our online offering or its functions or content is most frequently used, or which areas are in need of optimisation.
In addition to web analytics, we may also use testing procedures in order to test and optimise different versions of our online offering or its components, for example.
Unless stated otherwise below, profiles – i.e. data aggregated relating to a usage process – may be created for these purposes, and information may be stored in a browser or on a device and read from it. The information collected includes in particular websites visited and elements used therein, as well as technical information such as the browser used, the computer system used and details of usage times. If users have agreed to the collection of their location data with us or with the providers of the services we use, location data may also be processed.
Furthermore, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, 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 purposes of the respective procedures.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is the consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-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 time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of up to two years).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Article 6(1)(a) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyse the use of our online offering 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 a device in order to recognise which content users have accessed within one or more usage processes, which search terms they used, whether they accessed the content again, or interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used for this purpose. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides approximate 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. It is not logged, is not accessible and is not used for any further purposes. 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 bases: Consent (Article 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed). - Microsoft Clarity: We use Microsoft Clarity to analyse user behaviour on our online offering. Clarity records pseudonymous usage data — including clicks, mouse movements, scrolling behaviour, page views as well as technical information about device and browser — and provides this in the form of session recordings and heatmaps. This enables us to identify usability problems and improve our offering. Microsoft Clarity uses cookies and similar technologies to recognise returning users. IP addresses are processed in anonymised form; input in form fields is masked by default. Through the integration with Google Analytics, Clarity identifiers may flow into Google Analytics as a pseudonymous dimension in order to link both analysis perspectives; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA; Legal bases: Consent (Article 6(1)(a) GDPR); Website: https://clarity.microsoft.com; Privacy policy: https://privacy.microsoft.com/en-us/privacystatement; Basis for third-country transfers: Data Privacy Framework (DPF), Standard contractual clauses; Further information: https://learn.microsoft.com/en-us/clarity/setup-and-installation/cookie-list.
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags (small pieces of code) via a central interface and integrate them into our online offering — e.g. for the integration of analytics and marketing services. Google Tag Manager itself does not create user profiles, does not store cookies and does not perform any independent analyses. It is used solely to manage and deliver the services integrated via it; their data processing follows the consent status (Consent Mode). When the page is loaded, technically required connection data is transmitted to Google. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://marketingplatform.google.com/about/tag-manager/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard contractual clauses.
Presence on Social Networks (Social Media)
We maintain online presences within social networks and, in this context, process user data in order to communicate with 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 may give rise to risks for users, as it could, for example, make it more difficult to enforce users' rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on user behaviour and the interests derived from it. These profiles may in turn be used to display advertisements within and outside the networks that are presumed to correspond to users' interests. For these purposes, cookies are generally stored on users' computers in which the usage behaviour and interests of the users are saved. Moreover, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subjects' rights, we also point out that these can most effectively be asserted with the providers. Only the providers have access to users' data and can directly take appropriate measures and provide information. Should you nonetheless require assistance, you are welcome to contact us.
- Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts, as well as related information such as details of authorship or time of creation). Usage data (e.g. page views and time spent, 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).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Article 6(1)(f) GDPR).
Further notes on processing activities, procedures and services:
- Instagram: Social network, enables sharing of photos and videos, commenting on and liking posts, sending messages, following profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
- Facebook Pages: Profiles within the social network Facebook – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook Page ("Fanpage"). This includes in particular information about user behaviour (e.g. content viewed or interacted with, actions taken) and device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further details can be found in Facebook's data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the "Page Insights" service, which provide information about how people interact with our page and its content. The basis for this is an agreement with Facebook ("Page Insights information": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subjects' rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users may therefore submit requests for access or deletion directly to Facebook. The rights of users (in particular the right of access, erasure, objection and complaint to a supervisory authority) are not affected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Sole responsibility for further processing, including any possible transfer to Meta Platforms Inc. in the USA, lies with Meta Platforms Ireland Limited; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors that is used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, and the actions they take. Details of the devices used are also collected, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job function, country, industry, seniority level, company size and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn's privacy notices: https://www.linkedin.com/legal/privacy-policy.
We have concluded a specific agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which in particular sets out the security measures that LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users may, for example, submit requests for access or deletion directly to LinkedIn). The rights of users (in particular the right of access, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company established in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/personalizationoff.
Privacy Information for Whistleblowers
In this section you will find information about how we handle data from persons who report issues (whistleblowers), as well as from affected and involved parties within the scope of our whistleblowing procedure. Our aim is to provide an uncomplicated and
Legal bases (Germany): To the extent we process data to fulfil our legal obligations under the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6(1)(c) GDPR and, in the case of special categories of personal data, Article 9(2)(g) GDPR, § 22 BDSG, each in conjunction with § 10 HinSchG. This relates to the obligation to establish and operate an internal whistleblowing reporting office, the fulfilment of its statutory tasks and, in the event that data collected in the reporting procedure is used, the taking of further
Types of data processed: In the course of receiving and processing reports and in the subsequent whistleblower procedure, we may collect various data. These include in particular the data provided by a whistleblower, such as: name, contact details and location of the person making the report, names and data relating to possible witnesses or persons affected by the report, names and data relating to the persons against whom the report is directed, data about the alleged misconduct, further relevant details, where provided by the
Special categories of personal data: It may occur that in the course of our activities we collect special types of personal data, in particular when these are communicated by a whistleblower. These include: health-related data of a person, data on racial or ethnic origin
Use of our online forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in the so-called 'incognito mode' of your browser. Here is how to open an incognito window: a) On a Windows PC: open your browser and press Ctrl+Shift+N; b) On a Mac: open your browser and press Command+Shift+N; c) On mobile devices: switch to private mode via the tab menu.
When accessing our website in normal mode, your
Providing your name: You have the option of submitting reports anonymously. However, insofar as it is not prohibited by national legislation, we recommend providing your name and contact details. This enables us to follow up on the report more effectively and to contact you directly if necessary.
If you provide your name and contact details, your identity will be treated in strict confidence
Disclosure of data to third parties: Data relating to the reports submitted will only be passed on to third parties by us under certain circumstances. This occurs either a) where you have given us your explicit consent to do so, or b) where there is a legal obligation to disclose the data. Possible third parties include public authorities, government, regulatory or tax authorities, where disclosure is necessary to comply with a legal or regulatory obligation. We may also engage lawyers and other specialist advisors as permitted by law. They are authorised to examine suspected misconduct and to take any necessary measures following an investigation, such as initiating disciplinary or court proceedings. Furthermore, service providers carefully selected and monitored by us may receive data for these purposes (for example, operators of a web-based reporting system). However, these service providers are contractually obliged to comply with applicable data protection regulations as part of a data processing agreement.
Data retention and deletion: Personal data is only processed for as long as necessary to fulfil the processing purposes described above. Where such data is no longer required for the stated purposes, it is deleted. In certain situations
Technical and organisational measures: We have implemented the necessary contractual, technical and organisational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. Incoming reports are handled by designated
- Types of data processed: Master data (e.g. full name, home address, contact information, customer number,); Employee data (information about employees and other persons in a); Contact data (e.g. postal and email addresses or); Content data (e.g. textual or pictorial messages and posts, as well as related information such as details of authorship). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with).
- Data subjects: Employees (e.g. employed staff, applicants, temporary workers and other); Third parties. Whistleblowers.
- Purposes of processing and legitimate interests: Whistleblower protection.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Consent (Article 6(1)(a) GDPR); Legal obligation (Article 6(1)(c) GDPR). Legitimate interests (Article 6(1)(f) GDPR).
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy policy. We update the privacy policy as soon as changes to the data processing activities we carry out make this necessary. We will inform you as soon as the changes require any action on your part (e.g. consent) or any other individual notification.
Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and ask you to verify the details before making contact.
Definitions
This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, their statutory definitions apply. The following explanations are primarily intended to aid understanding.
- Employees: Employees are persons who are in an employment relationship, whether as workers, salaried staff or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It entails the employer's obligation to pay remuneration to the employee, while the employee provides their labour. The employment relationship encompasses various phases, including its establishment, in which the employment contract is concluded, its performance, in which the employee carries out their work, and its termination, when the employment relationship ends, whether by notice, mutual termination agreement or otherwise. Employee data is all information relating to these persons in the context of their employment. This encompasses aspects such as personal identification data, identification numbers, salary and bank data, working hours, holiday entitlements, health data and performance appraisals.
- Master data: Master data comprises essential information required for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions or systems, by enabling unambiguous assignment and communication.
- Content data: Content data encompasses information generated in the course of the creation, editing and publication of content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates.
- Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
- Meta, communication and process data: Meta, communication and process data are categories that contain information about the manner in which data is processed, transmitted and managed. Metadata, also known as data about data, includes information describing the context, origin and structure of other data. It may include details such as file size, date of creation, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Process data describes the processes and procedures within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to trace and review processes.
- Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which functions they prefer, how long they spend on certain pages, and the paths through which they navigate an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in recognising 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, encompasses any type of automated processing of personal data that consists of using such personal data to evaluate, analyse, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
- Log data: Log data is information about events or activities logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
- Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offering and may encompass the behaviour or interests of visitors in certain information, such as the content of web pages. Using reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and which content they are interested in. This enables them, for example, to better tailor the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to recognise returning visitors and thus obtain more accurate analyses of the use of an online offering.
- Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means 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 encompasses practically any handling of data, whether the collection, evaluation, storage, transmission or deletion thereof.
- Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the terms under which services or products are to be provided, exchanged or sold. This data category is essential for the management and fulfilment of contractual obligations and encompasses both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of agreed services or products, pricing arrangements, payment terms, termination rights, renewal options and specific conditions or clauses. It serves as the legal basis for the relationship between the parties and is decisive for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
- Payment data: Payment data encompasses all information required to process payment transactions between buyers and sellers. This data is of decisive importance for e-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 may also include information about payment status, chargebacks, authorisations and fees.
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