Privacy policy

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 in the context 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 the “Online Offer”).

The terms used are not gender specific.

Status: August 15, 2023

Table of contents

Responsible

Lunor AG
Lunor avenue 1
75378 Bad Liebenzell

Authorized representatives:

Michael Fux

E-mail address:

mail@lunor.com

Phone:

+497052408960

Imprint:

https://lunor.com/impressum/

Contact data protection officer

datenschutz@lunor.com

Relevant legal bases

Relevant legal bases according to the GDPR: The following is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. 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 para. 1 p. 1 lit. b) DSGVO) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from job applicants in order for the controller or the data subject to exercise his or her rights under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (1) GDPR. 2 lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to. Art. 9 par. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for 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 par. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.
  • 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. This includes, 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 provisions 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.

Reference to applicability DSGVO and Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Schweizer DSG) and the General Data Protection Regulation (DSGVO). For this reason, please 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” and “legitimate interest” and “special categories of data” are used in the GDPR. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of its application.

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.
  • Image and/ or video recording.

Special categories of data

  • Health data.

Categories of persons concerned

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

Processing purposes

  • Provision of contractual services and fulfillment of contractual obligations.
  • Contact requests and communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organizational procedures.
  • Managing and responding to inquiries.
  • Application Procedure.
  • Conducting sweepstakes and contests.
  • Firewall.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Assessment of creditworthiness and credit standing.
  • Information Technology Infrastructure.

Automated decisions in individual cases

  • Credit Report.

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, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during 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 full IP address is not required, the IP address is shortened (also referred to as “IP masking”). 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 encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

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

Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. Insofar as this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.

Data transfers within the organization: We may transfer or provide access to personal data to other entities within our organization. Insofar as this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.

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.

Subject to express consent or contractually or legally required transfer (see Art. 49 GDPR), we process or allow the data to be processed only in third countries with a recognized level of data protection (Art. 45 GDPR), in the presence of and compliance with contractual obligation through so-called standard protection clauses of the EU Commission (Art. 46 GDPR) or in the presence of certifications or binding internal data protection regulations (see. Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

EU-US Trans-Atlantic Data Privacy Framework: Under the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the U.S. as safe under 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 notice which service providers we use are certified under the Data Privacy Framework.

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. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural person or legal entity.

As part of our privacy notices, we may provide users with additional information regarding the deletion as well as the retention of data that is specific to each processing operation.

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 Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to 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 relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request that it be transferred to another controller.
  • Complaint to 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.

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, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can further be used for various purposes, e.g. for the purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

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

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the aid of cookies depends on whether we ask users for consent. If the users consent, the legal basis of the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business management 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 offer and closed his end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the terminal 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/.

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

Further guidance on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure under which users’ consents to the use of cookies, or to the processing operations and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be repeated and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used; legal basis: consent (Art. 6 (1) p. 1 lit. a) DSGVO).
  • Cookie opt-out: In the footer of our website you will find a link that allows you to change your cookie settings and revoke corresponding consents; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Real Cookie Banner: Cookie consent management; Service provider: devowl.io GmbH, Tannet 12, 94539 Grafling, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://devowl.io/de/wordpress-real-cookie-banner/. Privacy policy: https://devowl.io/de/datenschutzerklaerung/.

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 to fulfill our contractual obligations. This includes, 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 purposes of the administrative tasks associated with these duties and the company organization. In addition, 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 scope 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. The 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 is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after 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 kept for legal archiving reasons. The statutory retention period for documents relevant under tax law and for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. 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 voucher 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, timestamps, identification numbers, consent status).
  • Affected persons: Customers; Interested parties. 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. Managing and responding to inquiries.
  • Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 p. 1 lit. (c) GDPR). 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, in short “customer account”). If registration of a customer account is required, customers will be advised of this as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers along 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 other purposes 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 when terminating the customer account; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Wishlist/ wish list: Customers can create a product/wish list. In this case, the products will be stored as part of the fulfillment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of different storage periods; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable purchase process and includes the information needed for delivery, or provision and billing, as well as contact information in order to be able to contact you if necessary; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Providers and services used in the course of business

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

  • Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Customers; prospective customers; users (e.g., website visitors, users of online services). Business and Contractual Partners.
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Credit check

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service providers (credit agencies) in order to protect our legitimate interests.

We process the information received from credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

In accordance with legal requirements, the decision as to whether we will make advance payments is made solely on the basis of an automated decision in the individual case, which is made by our software on the basis of the information provided by the credit agency.

Insofar as we obtain express consent from contractual partners, the legal basis for the credit check and the transmission of the customer’s data to the credit agencies is the consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the default security of our payment claims.

  • 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 the contract, term, customer category).
  • Affected persons: Customers.
  • Purposes of processing: assessment of creditworthiness and credit standing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Automated decisions in individual cases: credit information (decision based on a credit check).

Provision of the online offer and web hosting

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

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Content data (e.g. entries in online forms).
  • 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. Firewall.
  • 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 retrieved, the date and time of the retrieval, data volumes transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.The server log files 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 of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
  • Content Delivery Network: We use a content delivery network (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Hetzner: services in the field of provision of information technology infrastructure and related services (e.g., storage space and/or computing capacities); service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hetzner.com; Privacy policy: https: //www.hetzner.com/de/rechtliches/datenschutz. Order processing contract: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
  • Stackpath: Content delivery network (CDN) – service that enables the content of an online offering, in particular large media files such as graphics or program scripts, to be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet; Service Provider: StackPath, LLC, 2021 McKinney Avenue, Suite 1100, Dallas, Texas 75201, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.stackpath.com; Privacy policy: https://www.stackpath.com/legal/privacy-statement/; Order processing contract: https://www.stackpath.com/legal/. Basis for third country transfers: EU-US Data Privacy Framework (DPF).
  • Wordfence: Firewall and security and error detection functions to detect and prevent unauthorized access attempts as well as technical vulnerabilities that could allow such access. For these purposes, cookies and similar storage methods required for this purpose may be used and security logs may be created during the examination and, in particular, in the event of unauthorized access. In this context, the IP addresses of the users, a user identification number and their activities, including the time of access, are processed and stored and compared with the data provided by the firewall and security function provider and transmitted to the latter; Service Provider: Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.wordfence.com; Privacy policy: https://www.wordfence.com/privacy-policy/; Basis for third country transfers: Standard Contractual Clauses(https://www.wordfence.com/standard-contractual-clauses/). For more information: https://www.wordfence.com/help/general-data-protection-regulation/.

Blogs and publication media

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

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication, and procedural data (e.g., IP addresses, timestamps, 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. Managing and responding to inquiries.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security, in case someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.Furthermore, we reserve the right, based on our legitimate interests, to process the information of users for the purpose of spam detection.

    On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.

    The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

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 procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Affected persons: Communication partners. Users (e.g., website visitors, users of online services).
  • Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience. Provision of contractual services and fulfillment of contractual obligations.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Contract fulfillment 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 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).
  • reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). Processed data may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on web pages, previously visited web pages, interactions with ReCaptcha on other web pages, possibly cookies, and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our legitimate interest to protect our online offer from abusive automated crawling and spam; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: EU-US Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.

Chatbots and chat functions

We offer online chats and chatbot features (collectively, “Chat Services”) as a communication option. A chat is an online conversation conducted with a certain degree of timeliness. A chatbot is a software that answers users’ questions or informs them about 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 in accordance with legal requirements.

We would like to point out to users that the respective platform provider may learn 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 advertising tailored to users in accordance with their terms and conditions, to which we refer for further information.

If users agree to 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 messages. Unsubscribing from chatbot messages deletes user data from the list of message recipients.

We use the aforementioned information to operate our chat services, e.g., 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 bases: We use chat services on the basis of consent if we have previously obtained users’ permission to process their data as part of our chat services (this applies to cases where users are asked for consent, e.g., for a chatbot to send 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 enhancing 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. websites visited, interest in content, access times). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Affected persons: Communication partners. Users (e.g., website visitors, users of online services).
  • 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) GDPR); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • tawk.to: Chatbot and assistance software and related services; Service provider: tawk.to inc, 187 East Warm Springs Rd, SB298, Las Vegas, NV, 89119 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.tawk.to/. Privacy policy: https://www.tawk.to/privacy-policy/.

Video conferencing, online meetings, webinars and screen sharing

We use third-party platforms and applications (hereinafter referred to as “Conference Platforms”) for purposes of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as “Conference”). When selecting 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. specification of access data or clear names) and on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service 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 end devices of the participants, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). Contents of communications are encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, then further data may be processed according to the agreement with the respective conference provider.

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

Data protection measures of the participants: For details on the processing of your data by the conference platforms, please refer to their data protection notices and select the security and data protection 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 the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in lists of participants, in the case of processing of interview results, etc.). In addition, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data subjects: Communication partners; users (e.g., website 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:

Application procedure

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

Basically, the required information includes personal information, such as the name, address, a way to contact you, as well as evidence of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.

If provided, applicants may submit their applications to us using an online form. The data is transmitted to us encrypted according to the state of the art. Applicants can also send us their applications by e-mail. However, please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. Therefore, we cannot take 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 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: Insofar as special categories of personal data (Article 9 (1) of the GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, their processing is carried out so that the 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 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 not successful, 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 revocation by the applicants, the deletion takes 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 fulfill our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are 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 be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

Duration of data retention in the applicant pool in months:

6

  • 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 with regard to a specific position or voluntarily by applicants concerning their person or qualifications).
  • Affected Persons: Applicants.
  • 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 health care, occupation and social security (Art. 9(2) lit. h) GDPR); Consent to processing of special categories of personal data (Art. 9(2) lit. a) GDPR); Processing of special categories of personal data for the protection of vital interests (Art. 9(2) lit. c) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Stepstone: Services related to employee acquisition/recruitment (employee search, communication, application process, contract negotiations); Service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.stepstone.de. Privacy policy: https://www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/.
  • Third-party applicant management services: Services related to employee acquisition/recruitment (employee search, communication, application process, contract negotiations); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Service provider: Personio SE & Co. KG
    Broadcasting place 4
    80335 Munich; Website: https://www.personio.de. Privacy policy: https://www.personio.de/datenschutz/.

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, which they use 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). Image and/or video recordings (e.g. photographs or video recordings of a person).
  • Affected persons: Customers; Employees (e.g., employees, applicants, former employees); Interested parties. Communication partner.
  • Purposes of processing: office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).). Provision of contractual services and fulfillment of contractual obligations.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Adobe Creative Cloud: Applications and cloud storage for photo editing, video editing, graphic design, and web development; Service provider: Adobe Systems Software Ireland Companies, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.adobe.com/de/creativecloud.html; Privacy policy: https: //www.adobe.com/de/privacy.html; Order processing contract: Will be provided by the service provider. Basis of third country transfer: Standard Contractual Clauses (Provided by the service provider).
  • 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, Ireland; Parent Company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; 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 contract: 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).
  • Nextcloud (hosting on own server): Cloud storage service in which the operation and storage of processed data takes place on a server managed by us; service provider: Nextcloud GmbH, Hauptmannsreute 44a, 70192 Stuttgart, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://nextcloud.com/de/. Privacy policy: https://nextcloud.com/de/privacy/.

Newsletter and electronic notifications

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

To subscribe to our newsletters, it is generally sufficient to enter your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or other information, if 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. I.e., after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign 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 login 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 is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the 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 purposes 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 dispatch system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status). Usage data (e.g. web pages visited, interest in content, access times).
  • Special categories of personal data: Health data.
  • 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 use one of the contact options given above, preferably e-mail, for this purpose.

Further guidance on processing operations, procedures and services:

  • Measurement of open 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. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behavior on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the analyses 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-through rates as well as the 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).

  • Rapidmail: Email delivery and automation services; Service provider: rapidmail GmbH, Augustinerplatz 2, 79098 Freiburg i.Br., Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.rapidmail.de; Privacy policy: https: //www.rapidmail.de/datenschutz. Order processing contract: https://www.rapidmail.de/hilfe/datenschutzvertrag-nach-eu-dsgvo-abschliessen.

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.

The recipients have the right to revoke consent given at any time or to object to promotional communication 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 in permanently observing the user’s revocation or objection, we also store the data required to avoid contacting the user again (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 information (e.g., email, phone 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).

Sweepstakes and contests

We process personal data of participants of sweepstakes and contests only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, implementation and execution of the sweepstakes, the participants have consented to the processing or the processing serves our legitimate interests (e.g., in the security of the sweepstakes or the protection of our interests against misuse through possible collection of IP addresses when submitting sweepstakes entries).

If contributions from participants are published as part of the sweepstakes (e.g. as part of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we point out that the names of the participants may also be published in this context. Participants may object to this at any time.

If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection provisions of the respective platforms shall also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the sweepstakes and that inquiries with regard to the sweepstakes should be directed to us.

The participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries about the competition are to be expected. In principle, the participants’ data will be deleted no later than 6 months after the end of the competition. Data of the winners may be retained for a longer period, e.g. in order to be able to answer queries about the prizes or to fulfill the prize obligations; in this case, the retention period depends on the type of prize and is, for example, up to three years for goods or services, e.g. in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for a longer period of time, e.g. in the form of reporting on the sweepstakes in online and offline media.

If data was also collected for other purposes within the scope of the competition, its processing and the retention period will be governed by the data protection information on this use (e.g. in the case of registration for the newsletter within the scope of a competition).

  • Types of data processed: inventory data (e.g. names, addresses); content data (e.g. entries in online forms). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Affected persons: Sweepstakes and contest participants.
  • Purposes of processing: implementation of sweepstakes and contests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Surveys and polls

We conduct surveys and interviews to collect information for the purpose of the survey or interview as communicated. The surveys and interviews we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is 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 with the aid of a cookie).

  • 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 procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Affected persons: Communication partners. Participants.
  • Purposes of processing: feedback (e.g. collecting feedback via online form).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

Web analysis, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors 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, for example, identify at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need 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 method (i.e., pseudonymization by shortening the IP address) to protect users. In general, the data stored in the context of web analytics, A/B testing and optimization is not clear user data (such as e-mail addresses or names), but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the 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, timestamps, 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).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further guidance on processing operations, procedures and services:

  • Matomo: Matomo is software that is used for web analysis and reach measurement purposes. As part of the use of Matomo, cookies are generated and stored on the user’s terminal device. User data collected through the use of Matomo is processed only by us and is not shared with third parties. Cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO) .Deletion of data: The cookies have a maximum storage period of 13 months.

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 in the process, user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, it could make it more difficult to enforce users’ rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within and outside the networks that presumably correspond to the users’ interests. 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 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 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.

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

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication, and procedural data (e.g., IP addresses, timestamps, 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:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com. Privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “Fanpage”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e. g. B. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information,” https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can direct information or deletion requests to Facebook, for example). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further notes can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for Third Country Transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses(https://www.facebook.com/legal/EU_data_transfer_addendum). Additional information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Shared responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which includes in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //www.linkedin.com; Privacy policy: https: //www.linkedin.com/legal/privacy-policy; Order processing agreement: https: //legal.linkedin.com/dpa; 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.
  • Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.pinterest.com; Privacy policy: https: //policy.pinterest.com/de/privacy-policy. Further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
  • 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).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): https://adssettings.google.com/authenticated.
  • Social Media Wall / Social Media Newsroom: A “social media wall” or “social media newsroom” is a compilation of posts from various social networks that mention us or contain a hashtag with our name or the name of a campaign. This includes mentions of posts we publish on social networks and posts published by users. The content of the posts is automatically obtained from the respective social networks in accordance with the terms and permissions of the authors, and users may object to the display at any time. The authors are responsible for the content of the contributions. The providers of the respective social networks are responsible for processing the data in connection with the presentation of the posts and their content. We refer to the information on the respective social networks within the scope of this privacy policy. Without prejudice to the data protection rights of users, we recommend that users (also) contact the respective authors or providers of the respective social networks in the event of requests for information and complaints about posts that were not made by us, in order to remove the posts at the source or to assert your data protection rights; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Plugins and embedded functions and content

We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, 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 these contents or functions. We endeavor 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 evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering, as well as being linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers). Content data (e.g. entries in online forms).
  • 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). Feedback (e.g. collecting feedback via online form).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of display or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process this for the purpose of transmitting the software to the users’ browser and for security purposes, as well as for the evaluation and optimization of their offer. – We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or making our online offering user-friendly). In doing so, the respective providers collect the IP address of the users and may process it for the purpose of transmitting the software to the users’ browser and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • 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).
  • Font Awesome (provided on own server): Display of fonts and icons; Service provider: Font Awesome icons are hosted on our server, no data is transmitted to the Font Awesome provider; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Google Maps APIs and SDKs: Interfaces to Google’s map and location services that allow, for example, the addition of address input, location determination, distance calculations, or the provision of supplementary information on stand and other locations; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third country transfers: EU-US Data Privacy Framework (DPF).
  • Instagram Plugins and Content: Instagram Plugins and Content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this Online Offer within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the course of a transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of a transmission by means of Instagram features (e.g., content embedding features) running on our Online Service for the following purposes: a) Displaying content as well as advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be of interest to users). We have entered into a special agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data security conditions” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the U.S. based on standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com. Privacy Policy: https://instagram.com/about/legal/privacy.
  • Shariff: We use the privacy-safe “Shariff” buttons. “Shariff” was developed to allow more privacy on the web and replace the usual “share” buttons of social networks. In doing so, it is not the user’s browser but the server on which this online offering is located that establishes a connection with the server of the respective social media platforms and queries the number of likes, for example. The user remains anonymous. More information about the Shariff project can be found at the developers of the magazine c’t: https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html; Service provider: Heise Medien GmbH & Co KG, Karl-Wiechert-Allee 10, 30625 Hannover, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html. Privacy policy: https://www.heise.de/Datenschutzerklaerung-der-Heise-Medien-GmbH-Co-KG-4860.html.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website : https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Management, organization and auxiliary tools

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

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

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

  • Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Inventory data (e.g. names, addresses). Contact information (e.g., email, phone numbers).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services); customers. Employees (e.g., employees, applicants, former employees).
  • Purposes of processing: provision of contractual services and fulfillment of contractual obligations. 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:

Modification and update of the privacy policy

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

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

Definitions

This section provides you with an overview of the terms used in this privacy statement. Insofar as the terms are defined by law, their legal definitions shall apply. The following explanations, on the other hand, are intended primarily to aid understanding.

  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
  • Firewall: A firewall is a security system that protects a computer network or a single computer from unwanted network access.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists in using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors’ behavior or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Controller: a “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.