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Privacy policy

Preamble

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

The terms used are not gender-specific.

Status: 21 June 2024

Table of contents

Responsible

Patrick Ruppelt
On the egg meadow 20
82031 Grünwald
Germany

E-mail address: patrick@ThinkCareAct.org

Overview of the processing

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

Types of data processed

  • Inventory data.
  • Employee data.
  • Payment data.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Social data.
  • Applicant data.
  • Picture and/or video recordings.
  • Event data (Facebook).
  • Protocol data.
  • Performance and behaviour data.
  • Working time data.
  • Creditworthiness data.
  • Salary data.

Special categories of data

  • Health data.
  • Religious or ideological beliefs.
  • Trade union membership.

Categories of persons concerned

  • Beneficiary and client.
  • Employees.
  • Interested parties.
  • Communication partner.
  • Users.
  • Applicants.
  • Business and contractual partners.
  • Third parties.
  • Whistleblower.
  • Customers.

Purposes of the processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organisational procedures.
  • Organisational and administrative procedures.
  • Application procedure.
  • Content Delivery Network (CDN).
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Assessment of creditworthiness and credit standing.
  • Establishment and implementation of employment relationships.
  • Information technology infrastructure.
  • Whistleblower protection.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.

Relevant legal bases

Relevant legal basis according to the GDPR: Below you will find an overview of the legal basis 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. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO) - The data subject has given consent to the processing of personal data relating to him or her for a specific purpose or purposes.
  • Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO) - The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject's request.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) - 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 applicants as part of the application procedure so that the controller or the data subject can exercise the rights arising from labour law and social security and social protection law and fulfil their obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive healthcare or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. GDPR. In the case of 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, employment and social security (Art. 9 (2) (h) GDPR) - Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of an employee's fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services on the basis of Union or Member State law or on the basis of a contract with a health professional.

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

Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection ("Swiss FADP" for short). Unlike the GDPR, for example, the Swiss FADP does not require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss FADP). In addition, personal data is only obtained by us for a specific purpose recognisable to the data subject and only processed in a way that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).

Reference to the applicability of the GDPR and the Swiss DPA: This data protection notice serves to provide information in accordance with both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

Security measures

We take appropriate technical and organisational 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. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signalled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organisational units or persons or disclosed to them. 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 observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the organisation: 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 it. If the data transfer is for administrative purposes, it is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual 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, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

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

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

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

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive.

If a period does not expressly begin on a specific date and is at least one year, it shall automatically start at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the cancellation or other termination of the legal relationship takes effect.

We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.

Further guidance on processing operations, procedures and services:

  • Storage and deletion of data: The following general time limits apply to storage and archiving in accordance with German law:
    • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organisational documents, accounting documents and invoices required for their understanding (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
    • 6 years - Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents, insofar as they are of significance for taxation, e.g. Hourly wage slips, company accounting sheets, calculation documents, price labelling, but also payroll accounting documents, insofar as they are not already accounting documents and cash register slips (§ 147 para. 3 in conjunction with para. 1 no. 2, 3, 5 AO, § 257 para. 1 no. 2 and 3, para. 4 HGB).
    • 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related enquiries based on past business experience and standard industry practice will be stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).
  • Storage and deletion of data: The following general time limits apply to storage and archiving in accordance with Swiss law:
    • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
    • 10 years - Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on past business experience and standard industry practices, are stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO). Claims for rent, lease and capital interest as well as other periodic services, from the supply of food, for catering and for debts to landlords, as well as from handicraft work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries and from the employment relationship of employees expire after five years (Art. 128 CO).

Rights of the data subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are 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 withdrawal for consents: You have the right to revoke any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right of rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data relating to you be deleted immediately or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
  • 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 person responsible.
  • Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

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

  • Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing.
  • Right to data output or transfer: You have the right to request that the personal data you have provided to us be returned to you in a commonly used electronic format.
  • Right of rectification: You have the right to request the correction of incorrect personal data concerning you.
  • Right to object, cancellation and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be deleted or destroyed.

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 and associated measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to enquiries.

We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organisation. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, jeopardising their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, as part of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Persons concerned: Service recipients and clients; interested parties. Business and contractual partners.
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; security measures; communication; office and organisational procedures; organisational and administrative procedures. Business processes and business management procedures.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services:

  • Online shop, order forms, e-commerce and delivery: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or fulfilment. If necessary for the fulfilment of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or fulfilment for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is labelled as such in the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultations; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business processes and procedures

Personal data of service recipients and clients - including customers, clients or, in special cases, clients, patients or business partners as well as other third parties - are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected is used to fulfil contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organisation of the company.

Personal data may be passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); log data (e.g. log files relating to logins or retrieval of data or access times); usage data (e.g. page views and duration, clicks, usage intensity and frequency, devices used or access times). log files relating to logins or the retrieval of data or access times); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behaviour); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Employee data (information on employees and other persons in an employment relationship).
  • Persons concerned: Service recipients and clients; interested parties; communication partners; business and contractual partners; customers; third parties; users (e.g. website visitors, users of online services). Employees (e.g. employees, applicants, temporary staff and other employees).
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; assessment of creditworthiness and credit standing; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further guidance on processing operations, procedures and services:

  • Customer management and customer relationship management (CRM): Procedures required as part of customer management and customer relationship management (CRM) (e.g. customer acquisition in compliance with data protection requirements, measures to promote customer loyalty and retention, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, administration of CRM systems, secure account management, customer segmentation and target group formation); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Contact management and contact maintenance: Procedures required to organise, maintain and secure contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adapting contact strategies); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Customer loyalty programme/ customer card: As part of the customer loyalty programme, the controller processes the data of participating customers for the purpose of providing the services offered under this programme. For this purpose, the controller stores the information provided by the customers, where necessary and labelled as such, in a customer profile. Within this profile, information about the use of the customer loyalty programme and the use of the associated services and benefits is also processed. This information is only passed on to third parties (e.g. service providers) if this is necessary for the aforementioned purposes. The customer profiles are deleted after participation in the programme has ended. The respective data is only archived to the extent that this may be necessary for statutory retention purposes or for the fulfilment of statutory (up to eleven years from the end of the year in which it was created in the case of tax information) or contractual claims (up to three years from the end of the year of termination). This is recorded in the register of processing activities; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • General payment transactions: Procedures required for carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, processing direct debits, checking account statements, monitoring incoming and outgoing payments, return debit management, account reconciliation, cash management); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Bookkeeping, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. creation and checking of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Procedures required for the recording, administration and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Purchasing: Procedures required in the procurement of goods, raw materials or services (e.g. supplier selection and evaluation, price negotiations, order placement and monitoring, verification and control of deliveries, invoice verification, administration of orders, inventory management, creation and maintenance of purchasing guidelines); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Distribution: Procedures required for the planning, implementation and control of measures for the marketing and sale of products or services (e.g. customer acquisition, quotation preparation and tracking, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and company websites, support of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Use of online platforms for offer and sales purposes

We offer our services on online platforms that are operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms to measure reach and for interest-based marketing.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Persons concerned: Service recipient and client. Business and contractual partners.
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; marketing. Business processes and business management procedures.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services:

  • shopify: Platform via which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online shops, websites, their offers and content, community elements, purchase and payment processes, customer communication, analyses and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.shopify.com/de/; Privacy Policy: https://www.shopify.com/de/legal/datenschutz. Basis for third country transfers: Switzerland - Adequacy decision (Ireland).

Providers and services used in the course of business activities

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
  • Persons concerned: Service recipients and clients; interested parties; business and contractual partners. Communication partners.
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and business management procedures. Communication.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Loox: Creation of testimonials, customer experience and test reports as well as a reward system for customers; Service provider: Loox Online Ltd, Rehov Har Sinai 2, 6581602 Tel Aviv-Yafo, Israel; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://loox.app/; Privacy Policy: https://loox.io/legal/privacy_policy_users.pdf. Basis for third country transfers: EU/EEA - adequacy decision (Israel), Switzerland - adequacy decision (Israel).
  • PageFly: Support in the creation and optimisation of Shopify shops and associated websites; Service provider: BraveBits JSC, 2nd floor Ecolife Capitol, 58 To Huu, Me Tri, Nam Tu Liem District, Hanoi, Vietnam 100000; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://pagefly.io/; Privacy Policy: https://pagefly.io/pages/privacy-policy. Basis for third country transfers: EU/EEA - adequacy decision (Great Britain), Switzerland - adequacy decision (Uruguay).
  • TrackingMore - Order Tracking: Parcel tracking package for Shopify - Automatic shipment tracking, delivery notifications, delivery status display on the order page, support for multiple shipping service providers; Service provider: Execution on servers from shopify..; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://apps.shopify.com/trackingmore. Privacy Policy: https://www.trackingmore.com/privacy.html.

Payment procedure

As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively referred to as "payment service providers").

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of cancellation, information and other data subject rights.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Persons concerned: Service recipients and clients; business and contractual partners. Interested parties.
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations. Business processes and business management procedures.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services:

  • PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. Basis for third country transfers: Switzerland - Adequacy decision (Luxembourg).
  • Shop Pay (Shopify): Payment services (technical connection of online payment methods); Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.shopify.de; Privacy Policy: https://www.shopify.de/legal/datenschutz. Basis for third country transfers: Switzerland - Adequacy decision (Ireland).

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. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Content Delivery Network (CDN).
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • 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 offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and also to ensure the utilisation 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 anonymised. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • Host Europe: Services in the area of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Host Europe GmbH, Hansestrasse 111, 51149 Cologne, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hosteurope.de; Privacy Policy: http://www.hosteurope.de/AGB/Datenschutzerklaerung/; Order processing contract: https://www.hosteurope.de/Dokumente/. Basis for third country transfers: Switzerland - Adequacy decision (Germany).
  • Cloudflare: Content Delivery Network (CDN) - Service with the help of which the contents of an online offer, in particular large media files such as graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.cloudflare.com; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Order processing contract: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/).

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to you and contains the information on the respective use of cookies.

Information on the legal basis for data protection: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask for their consent. If users accept, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, 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 service and closed their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on cancellation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further guidance on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which the user's consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • GDPR Legal Cookie: Consent management: Procedures for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and their processing; Service provider: beeclever GmbH, Friedrich-Mohr-Straße 1, 56070 Koblenz, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://gdpr-legal-cookie.myshopify.com/; Privacy Policy: https://gdpr-legal-cookie.myshopify.com/pages/datenschutzerklarung. Basis for third country transfers: Switzerland - Adequacy decision (Germany).

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and this information is processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (user name, password and an e-mail address).

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

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; security measures; organisational and administrative procedures. Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Deletion after cancellation.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services:

  • Register with your real name: Due to the nature of our community, we ask users to use our services only by using their real names. This means that the use of pseudonyms is not permitted; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • User profiles are not public: User profiles are not publicly visible or accessible.
  • Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • No obligation to retain data: It is the responsibility of the users to save their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Persons concerned: Communication partner.
  • Purposes of the processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further guidance on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Cloud services

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

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

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Persons concerned: Interested parties; communication partners; business and contractual partners. Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Office and organisational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipient or on the basis of a legal basis. If the content of the newsletter is mentioned when registering for the newsletter, this content is decisive for the user's consent. To subscribe to our newsletter, it is normally sufficient to provide your email address. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. 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. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Persons concerned: Communication partner.
  • Purposes of the processing: Direct marketing (e.g. by e-mail or post).
  • Storage and deletion: 3 years - Contractual claims (AT) (Data necessary to consider potential warranty claims and claims for damages or similar contractual claims and rights, as well as to process related enquiries, based on past business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB)). 10 years - Contractual claims (CH) (Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on past business experience and standard industry practice, will be stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is relevant in certain cases (Art. 127, 130 CO)).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail.

Further guidance on processing operations, procedures and services:

  • Measurement of open and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or its server, if we use a dispatch service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The analyses are used to recognise 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 and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of user consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Reminder emails about the ordering process: If users do not complete an order process, we can remind them of the order process by email and send them a link to continue it. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight or forgetting. Sending is based on consent, which users can revoke at any time; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Advertising communication via e-mail, post, fax or telephone

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

Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.

After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
  • Persons concerned: Communication partner.
  • Purposes of the processing: Direct marketing (e.g. by e-mail or post); marketing. Sales promotion.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Web analysis, monitoring and optimisation

Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. It also enables us to understand which areas require optimisation.

In addition to web analysis, we may also use test procedures, for example to test and optimise different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the 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 consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); inventory data (e.g. full name, place of residence, contact information, customer number, etc.); payment data (e.g. bank details, bank details, persons involved). IP addresses, time data, identification numbers, persons involved); inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
  • Persons concerned: Users (e.g. website visitors, users of online services). Service recipients and clients.
  • Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of contractual services and fulfilment of contractual obligations.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Safety measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services:

  • shopify: Platform via which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online shops, websites, their offers and content, community elements, purchase and payment processes, customer communication, analyses and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.shopify.com/de/; Privacy Policy: https://www.shopify.com/de/legal/datenschutz. Basis for third country transfers: Switzerland - Adequacy decision (Ireland).

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 the users active there or to offer information about us.

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

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on users' computers, in which the user behaviour and interests of the users are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

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

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Instagram: Social network, allows you to share photos and videos, comment on and favourite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
  • 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 from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see "Device information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). 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 information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint 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 in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).

Plug-ins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to analyse 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, but may also be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data, identification numbers, persons involved); inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and contributions, etc.). full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and the information relating to them, such as information on authorship or time of creation). Event data (Facebook) ("Event data" is information that is sent to the provider Meta via Meta pixels (whether via apps or other channels), for example, and relates to people or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations and product purchases. Event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as comments written, login information or contact information such as names, email addresses or telephone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are deleted).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online services and user-friendliness; marketing. Profiles with user-related information (creation of user profiles).
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services:

  • Facebook plugins and content: Facebook social plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible withMeta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects or receives in the context of a transmission by means of the Facebook social plugins (and embedding functions for content) that are executed on our online offer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improvement of ad delivery and personalisation of functions and content (e.g. improvement of the recognition of which content or advertising information presumably corresponds to the interests of the users). (e.g. addressing users via Facebook Messenger); c) improving the delivery of ads and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of an order processing contract ("data processing conditions"), https://www.facebook.com/legal/terms/dataprocessing) the "data security conditions" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
  • Instagram plugins and content: Instagram plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects using Instagram functions (e.g. embedding functions for content) that are executed on our online offer or receives in the context of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger). (e.g. addressing users via Facebook Messenger); c) improving the delivery of ads and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measured values, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of an order processing contract ("data processing conditions"), https://www.facebook.com/legal/terms/dataprocessing) the "data security conditions" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Switzerland - Adequacy decision (Ireland).
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.

Management, organisation and support tools

We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organising, managing, planning and 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 third-party providers. This may affect 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 content.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation 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. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Persons concerned: Communication partner. Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Processing of data in the context of employment relationships

In the context of employment relationships, personal data is processed with the aim of effectively organising the establishment, implementation and termination of such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relations.

Data processing covers various aspects ranging from contract initiation to contract cancellation. This includes the organisation and administration of daily working hours, the administration of access rights and authorisations as well as the handling of personnel development measures and employee appraisals. The processing is also used for payroll accounting and the administration of wage and salary payments, which are critical aspects of contract fulfilment.

Data processing also takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data to evaluate and optimise operational processes. Data processing also includes the disclosure of employee data as part of external communication and publication processes, where this is necessary for operational or legal purposes.

This data is always processed in compliance with the applicable legal framework, whereby the aim is always to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymisation or deletion of data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.

  • Types of data processed: Employee data (information on employees and other persons in an employment relationship); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); social data (data subject to social confidentiality, e.g. data from social security organisations); data on the use of data by third parties (e.g. data on the use of data). content data (e.g. textual or pictorial messages and contributions and the information relating to them, such as details of authorship or time of creation); social data (data subject to social confidentiality and processed, for example, by social insurance providers, social welfare providers or pension authorities); log data (e.g. log files relating to logins or the retrieval of data or access times); performance and behavioural data (e.g. performance and behavioural aspects). performance and behavioural aspects such as performance evaluations, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behavioural assessments); working time data (e.g. start of working hours, end of working hours, actual working hours, target working hours, break times, overtime, holidays, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, bonuses, premiums). basic salary, bonus payments, premiums, tax class information, supplements for night work/overtime, tax deductions, social security contributions, net amount paid out); image and/or video recordings (e.g. photographs or video recordings of a person); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Special categories of personal data: Health data; Religious or philosophical beliefs. Trade union membership.
  • Persons concerned: Employees (e.g. salaried employees, applicants, temporary staff and other employees).
  • Purposes of the processing: Establishment and implementation of employment relationships (processing of employee data in the context of the establishment and implementation of employment relationships); business processes and business management procedures; provision of contractual services and fulfilment of contractual obligations; public relations; security measures. Office and organisational procedures.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further guidance on processing operations, procedures and services:

  • Working time recording: Procedures for recording employees' working hours include both manual and automated methods, such as the use of time clocks, time recording software or mobile apps. This involves activities such as entering clock-in and clock-out times, break times, overtime and absences. Checking and validating the recorded working times includes comparing them with shift schedules, checking absences and authorising overtime by supervisors. Reports and analyses are created based on the recorded working times to provide timesheets, overtime reports and absence statistics for management and the HR department; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Authorisation management: Procedures required in the definition, management and control of access rights and user roles within a system or organisation (e.g. creation of authorisation profiles, role and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Special categories of personal data: Special categories of personal data are processed as part of the employment relationship or to fulfil legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data may be passed on to health insurance companies, for example, or processed to assess employees' ability to work or for occupational health management or for information provided to the tax office; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Sources of the processed data: Personal data is processed that was obtained as part of the employee's application and/or employment relationship. In addition, if required by law, personal data is collected from other sources. These may be tax authorities for tax-relevant information, the respective health insurance company for information on incapacity for work, third parties such as employment agencies or publicly accessible sources such as professional social networks in the context of application procedures; Legal basis: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Purposes of data processing: The personal data of employees is primarily processed to establish, implement and terminate the employment relationship. In addition, the processing of this data is necessary to fulfil legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfil regulatory and supervisory requirements, to optimise electronic data processing processes and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the assertion of legal claims and for defence in legal disputes; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transfer of employee data to third countries: The transfer of employee data to third countries, i.e. countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the fulfilment of the employment relationship, is required by law or if employees have given their consent. Where required by law, employees will be informed separately about the details; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Transmission of employee data: Employee data is only processed internally by those departments that require it to fulfil operational, contractual and legal obligations.
    Data is only passed on to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller may forward personal data to other recipients if this is necessary to fulfil its contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance funds, pension insurance providers, pension providers and other social insurance providers c) Authorities, courts (e.g. tax authorities, labour courts, other supervisory authorities as part of the fulfilment of reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the event of wage and salary garnishment f) Other bodies to which legally binding declarations must be made.
    In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples of this are details in the sender area of emails or letterhead and the creation of profiles on external platforms; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Business trips and travel expense accounting: Procedures required for the planning, execution and accounting of business trips (e.g. booking trips, organising accommodation and transport, managing travel expense advances, submitting and checking travel expense reports, checking and accounting for costs incurred, complying with travel guidelines, handling travel expense management); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).
  • Payroll accounting and payroll accounting: Procedures required for the calculation, payment and documentation of wages, salaries and other remuneration of employees (e.g. recording of working hours, calculation of deductions and bonuses, payment of taxes and social security contributions, preparation of wage and salary statements, management of payroll accounts, reporting to the tax office and social security institutions); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
  • Deletion of employee data: Employee data is deleted in accordance with German law if it is not required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or due to the interests of the employer. The following retention and archiving obligations are observed:
    • General personnel documents - General personnel documents (such as employment contract, employment reference, supplementary agreements) are kept for up to three years after termination of the employment relationship (§ 195 BGB).
      Tax-relevant documents - Tax-relevant documents in the personnel file are kept for six years (§ 147 AO, § 257 HGB).
      Information on wages and hours worked - Information on wages and hours worked for (accident) insured persons with proof of wages is kept for five years (§ 165 I 1, IV 2 SGB VII).
    • Salary lists including lists for special payments - Salary lists including lists for special payments, if an accounting document is available, are kept for ten years (§ 147 AO, § 257 HGB).
    • Payroll lists for interim, final and special payments - Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
    • Employee insurance documents - Employee insurance documents, if accounting records are available, are kept for ten years (§ 147 AO, § 257 HGB).
    • Contribution statements to social insurance institutions - Contribution statements to social insurance institutions are kept for ten years (§ 165 SGB VII).
      Payroll accounts - Payroll accounts are kept for six years (§ 41 I 9 EStG).
    • Applicant data - Retained for a maximum of six months from receipt of the rejection.
    • Working time records (for more than 8 hours on working days) - Are kept for two years (§ 16 II Working Hours Act (ArbZG)).
    • Application documents (after online job advertisement) - Will be kept for three to a maximum of six months after receipt of the rejection (§ 26
    • Federal Data Protection Act (BDSG) as amended, Section 15 IV General Equal Treatment Act (AGG)).
    • Certificates of incapacity for work (AU) - Are kept for up to five years (Section 6 I of the Act on Equalisation of Expenses (AAG)).
    • Documents relating to company pension schemes - are kept for 30 years (Section 18a of the German Act on the Improvement of Company Pension Schemes (BetrAVG)).
    • Employee sickness data - Retained for twelve months after the start of the illness if the absences do not exceed six weeks in a year.
    • Maternity protection documents - are kept for two years (§ 27 para. 5 MuSchG).
    Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).
  • Deletion of employee data: Employee data in Switzerland is deleted when it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or due to the interests of the employer. The following retention and archiving obligations are observed:
    • 10 years - retention period for books and records, annual financial statements, inventories, annual reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
    • 10 years - Data required for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on past business experience and common industry practices, are stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO). Claims expire after five years for rent, lease and capital interest payments and other periodic services, for the supply of food, for catering and hospitality debts as well as from craft services, retail sale of goods, medical care, professional work of lawyers, legal agents, attorneys and notaries and from the employment relationship of employees (Art. 128 CO).
  • Personnel file management: Procedures required for the organisation, updating and management of employee data and documents (e.g. recording of personnel master data, storage of employment contracts, references and certificates, updating of data in the event of changes, compilation of documents for employee interviews, archiving of personnel files, compliance with data protection regulations); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).
  • Personnel development, performance evaluation and employee appraisals: Procedures required in the area of employee promotion and development, performance appraisal and performance reviews (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, implementation of target agreement and feedback meetings, career planning and talent management, succession planning); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).
  • Obligation to provide data: The controller shall inform employees that it is necessary to provide their data. This is generally the case if the data is required for the establishment and performance of the employment relationship or if its collection is required by law. It may also be necessary to provide data if employees assert claims or if employees are entitled to claims. The implementation of these measures or fulfilment of benefits is dependent on the provision of this data (for example, the provision of data for the purpose of receiving wages); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Publication and disclosure of employee data: Employee data is only published or disclosed to third parties if this is necessary for the fulfilment of work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website or in public registers following consultation or an agreed job description, or if the area of responsibility includes representative functions. This may also be the case if a presentation or communication with the public takes place as part of the fulfilment of tasks, such as photographs taken as part of public relations work. Otherwise, employees' data will only be published with their consent or on the basis of the employer's legitimate interests, for example in the case of stage or group photos taken as part of a public event; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Application procedure

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

In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for the position. On request, we will be happy to provide additional information on what details are required.

If available, applicants are welcome to submit their applications via our online form, which is encrypted using state-of-the-art technology. Alternatively, it is also possible to send us applications by e-mail. However, we would like to point out that e-mails sent via the Internet are generally not encrypted. Although e-mails are generally encrypted in transit, this does not take place on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the security of the application on its transmission path between the sender and our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.

Applicants are welcome to contact us about how to submit their application or send it to us by post.

Processing of special categories of data: Insofar as special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants or communicated by them in the context of the application procedure, their processing is carried out so that the controller or the data subject can exercise the rights arising from labour law and social security and social protection law and fulfil his or her obligations in this regard, in the case of the protection of 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 diagnostics, for medical diagnostics or for the purpose of the processing of personal data. 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 fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicant's 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 cancellation by the applicant, the deletion will take place at the latest after a period of six months so that we can answer any follow-up questions about the application and fulfil our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax regulations.

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). 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, CV, certificates and other information relating to a specific position or voluntarily provided by applicants regarding their person or qualifications).
  • Persons concerned: Applicants.
  • Purposes of the processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Data protection information for whistleblowers

In this section, you will find information on how we handle data from people who provide information (whistleblowers) and from affected and involved parties as part of our whistleblowing procedure. Our aim is to provide an uncomplicated and secure way to report possible misconduct by us, our employees or service providers, especially for actions that violate laws or ethical guidelines. We also ensure that reports are processed and handled appropriately.

Legal basis (Germany): Insofar as we process data to fulfil our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6 (1) sentence 1 lit. c) GDPR and, in the case of special categories of personal data, Article 9 (2) lit. g) GDPR, Section 22 BDSG, in each case in conjunction with Section 10 HinSchG. This relates to the obligation to set up and operate an internal whistleblower reporting office, the fulfilment of its statutory duties and, in the case of the use of the data collected in the reporting procedure, the taking of further investigations or steps under labour law against persons who have been found guilty of an infringement.

Insofar as we process data (in particular in the event of identified misconduct) in the context of or in preparation for legal defence, this is done on the basis of our legitimate interests in legally compliant and ethical action in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.

If you have given us your consent to process personal data for specific purposes, the processing is based on this consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR and, in the case of special categories of personal data, Art. 9 para. 2 lit. a) GDPR. An example of this would be the disclosure of the identity of the whistleblower or the preparation of a verbatim record during a personal meeting. Any consent given can be revoked at any time with effect for the future.

Types of data processed:

We may collect various data in the course of receiving and processing reports and in the subsequent whistleblowing procedure. This includes, in particular, the data provided by a whistleblower, such as

  • Name, contact details and location of the person providing the information,
  • Names and details of possible witnesses or persons affected by the tip-off,
  • Names and details of the persons against whom the notice is directed,
  • Data on the alleged misconduct,
  • Further relevant details, if provided by the whistleblower.

We also process the following personal data for the purposes of analysing the facts and further proceedings:

  • Clear labelling of the message,
  • Contact details of the person providing the information, if specified,
  • Personal data of persons named in the notice, if provided,
  • Personal data of persons indirectly affected by the examination of the facts, if applicable,
  • Personal data of persons from other participating companies (e.g. in the context of legal advice), if relevant,
  • Other data related to the facts of the case.

Special categories of personal data:

In the course of our activities, we may collect special types of personal data, especially if these are provided by a whistleblower. This includes

  • Health-related data of a person,
  • Data on the racial or ethnic origin of persons,
  • Information about a person's religious or philosophical beliefs,
  • Information on a person's sexual orientation.

This data is only processed if it is relevant for the processing of the respective report and has been expressly provided by the whistleblower.

Use of our online forms: Please note that it is possible to submit comments anonymously. To ensure the security of your data when using our online forms, we recommend that you access them in the so-called 'incognito mode' of your browser. You can open an incognito window as follows: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

When you access our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your end device. This data is temporarily stored in a log file and automatically deleted after 30 days at the latest.

The IP address is processed for technical and administrative purposes to establish a connection to our website. It ensures the security, stability and functionality of the whistleblower form and is an important part of our measures to ensure the confidential submission of information.

The processing of the logged data is based on Article 6(1)(1)(f) GDPR. Our legitimate interest here lies in the need for security and the need to ensure the technical requirements for smooth and trouble-free notification.

Indication of names: You have the option of submitting comments anonymously. However, unless prohibited by national legislation, we recommend that you provide your name and contact details. This enables us to investigate the report more effectively and contact you directly if necessary.

If you provide your name and contact details, your identity will be kept strictly confidential. Exceptions to this confidentiality only exist if we are legally obliged to disclose your identity. This may be necessary to protect or defend our rights or the rights of our employees, customers, suppliers or business partners. A further exception exists if it is established that the allegations were made with malicious intent.

Provision of data to third parties: We will only pass on data in connection with the information provided to third parties under certain circumstances. This happens either a) if you have given us your express consent to do so, or b) if there is a legal obligation to pass on the data. Possible third parties include public authorities, government, regulatory or tax authorities if the disclosure is necessary to fulfil a legal or regulatory obligation. In addition, we may instruct lawyers and other professional advisors within the framework of statutory provisions. They are authorised to investigate suspected misconduct and take any necessary action following an investigation, such as initiating disciplinary or legal proceedings. In addition, service providers carefully selected and monitored by us may receive data for these purposes (e.g. operators of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection regulations as part of commissioned data processing.

Data retention and erasure: Personal data is only processed for as long as is necessary to fulfil the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. In certain situations, however, the data may be kept for longer to fulfil legal requirements, as long as this is necessary and proportionate. In such cases, the data will be deleted as soon as it is no longer required for these purposes.

Technical and organisational measures: We have implemented the necessary contractual, technical and organisational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. Incoming reports are processed by authorised persons who are given access to the respective reports and carry out the subsequent review of the facts. Our employees are specially trained to carry out the factual checks properly and are obliged to maintain the strictest confidentiality.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); employee data (information on employees and other persons in an employment relationship); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Persons concerned: Employees (e.g. salaried employees, applicants, temporary staff and other employees); third parties. Whistleblowers.
  • Purposes of the processing: Whistleblower protection.
  • Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Change and update

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

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

Definitions of terms

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

  • Employees: Employees are defined as persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is defined by an employment contract or agreement. It involves the employer's obligation to pay remuneration to the employee while the employee performs work. The employment relationship comprises various phases, including the establishment phase, in which the employment contract is concluded, the performance phase, in which the employee carries out their work activities, and the termination phase, when the employment relationship ends, whether by termination, cancellation agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
  • Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
  • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service with the help of which the contents of an online offer, especially large media files such as graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
  • Content data: Content data comprises information that is generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
  • Contact details: Contact data is essential information that enables communication with people or organisations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Performance and behaviour data: Performance and behavioural data refers to information related to how people perform tasks or behave in a particular context, such as an educational, work or social environment. This data can include metrics such as productivity, efficiency, quality of work, attendance and compliance with policies or procedures. Behavioural data could include interactions with colleagues, communication styles, decision-making processes and reactions to different situations. These types of data are often used for performance appraisals, training and development and decision making within organisations.
  • Meta, communication and process data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information about the file size, the creation date, the author of a document and the change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and procedures within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review processes.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they favour, how long they stay on certain pages and which paths they take to navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in recognising trends, preferences and potential problem areas within digital offerings
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Protocol data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online services can, for example, recognise at what time users visit their websites and what content they are interested in. This enables them, for example, to better customise the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Responsible: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
  • Contract data: Contract data is specific information that relates to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, cancellation rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
  • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorisations and fees.