Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of 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 providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as ‘online offering’).
The terms used are not gender-specific.
As of 17 September 2025
Created with Datenschutz-Generator.de by Dr Thomas Schwenke.
Table of contents
Preamble
Responsible
Overview of processing
Relevant legal bases
Security measures
Transfer of personal data
International data transfers
General information on data storage and deletion
Rights of data subjects
Business services
Business processes and procedures
Providers and services used in the course of business activities
Payment procedures
Provision of the online offering and web hosting
Blogs and publication media
Communication via messenger
Video conferences, online meetings, webinars and screen sharing
Cloud services
Newsletters and electronic notifications
Advertising communication via email, post, fax or telephone
Presence on social networks (social media)
Plug-ins and embedded functions and content
Changes and updates
Definition of terms
Controller
Dr Anna Pickhan
Rathausstraße 63
69126 Heidelberg
Germany
Email address: anna@uiji-do.com
Legal notice: https://uiji-do.com/imprint
Overview of 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.
Payment data.
Location data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication and procedural data.
Image and/or video recordings.
Sound recordings.
Event data (Facebook).
Log data.
Special categories of data
Health data.
Categories of data subjects
Service recipients and clients.
Employees.
Prospective customers.
Communication partners.
Users.
Business and contractual partners.
Depicted persons.
Third parties.
Customers.
Purposes of processing
Provision of contractual services and fulfilment of contractual obligations.
Communication.
Security measures.
Direct marketing.
Reach measurement.
Tracking.
Office and organisational procedures.
Target group formation.
Organisational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.
Finance and payment management.
Public relations.
Sales promotion.
Business processes and business management procedures.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG) . The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.
Security measures
In accordance with legal requirements, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, 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 varying likelihood and severity of the threat to the rights and freedoms of natural persons.
These 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, input, transfer, availability and separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and responses are made to data threats. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorised access. 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 transfers meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transferred securely and encrypted.
Transfer of personal data
In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.
International data transfers
Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, agencies or companies (which can be identified by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission on 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and stipulate contractual obligations for the protection of your data.
This double safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.
We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there are no further legal grounds for 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 retained 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 storage and deletion of data that applies specifically to certain processing procedures.
If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.
Storage and deletion of data: The following general periods apply to storage and archiving under German law:
10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) No. 1 in conjunction with (4) HGB).
8 years – Accounting documents, such as invoices and expense receipts (Section 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).
6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant to taxation, e.g. hourly wage slips, operating statements, calculation documents, price tags, but also payroll documents, unless they are already accounting documents, and cash register receipts (Section 147 (1) Nos. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) Nos. 2 and 3 in conjunction with (4) HGB).
3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related enquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).
Start of the period at the end of the year: If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 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) GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw your consent at any time.
Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.
Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which 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 relating to you infringes the GDPR.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as ‘contractual partners’), within the framework of contractual and comparable legal relationships and related measures and with regard to communication with 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 update obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of administrative tasks associated with these obligations and company organisation. We also process the data on the basis of our legitimate interests in both proper and economic business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only 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, within the framework of this data protection declaration.
We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (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 archiving for legal reasons (e.g. for tax purposes, usually ten years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, 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, term, customer category).
Special categories of personal data: Health data.
Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; 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(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing procedures, methods and services:
Personal training: The procedures involved in personal training include the acquisition and management of client data, including the collection, storage and use of contact information, training preferences and individual goals. At the beginning of a training relationship, extensive health information, such as allergies, pre-existing conditions, medications and injury history, in order to develop safe and effective training programmes. The creation of tailor-made training plans is based on the analysis of personal fitness data, goal setting and progress measurements of clients. Personal data is used to coordinate training appointments and locations to ensure smooth organisation and communication. Conducting regular fitness assessments and performance tests requires the collection and evaluation of individual performance data to monitor progress and adjust training plans. For the provision of complementary services, such as nutritional advice or lifestyle coaching, additional personal data is processed in order to offer holistic support. For the continuous improvement of training quality and customer satisfaction, regular feedback discussions and evaluations are carried out, which may also include personal data. Communication with clients takes place via various channels, such as email, telephone or messenger services, whereby personal data is exchanged in order to arrange appointments, answer questions and offer support. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Event management: We process the data of participants in the events, functions and similar activities that we offer or organise (hereinafter referred to uniformly as ‘participants’ and ‘events’) in order to enable them to participate in the events and make use of the services or activities associated with participation.
If we process health-related data, religious, political or other special categories of data in this context, this is done within the scope of public disclosure (e.g. at thematically oriented events or for the purpose of health care, safety or with the consent of the persons concerned).
The required information is marked as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information for the purpose of any necessary consultations. Insofar as we obtain access to information from end customers, employees or other persons, we process this information in accordance with the legal and contractual requirements. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR).
Sports and leisure activities: We process our customers' data in order to offer sports and leisure activities. This includes the organisation and implementation of events and courses. The required information is used for registration, participation and billing. We process this data in accordance with legal and contractual requirements; Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR) , legitimate interests (Art. 6(1)(f) GDPR).
Business processes and procedures
Personal data of service recipients and clients – including customers, clients or, in special cases, patients or business partners and other third parties – are processed within the framework 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 to design operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the safeguarding of internal invoicing and financial processes. In addition, the data supports the protection of the rights of the controller and facilitates administrative tasks and the organisation of the company.
Personal data may be passed on to third parties if this is necessary to fulfil the aforementioned purposes or legal obligations. The data will be deleted after the expiry of the statutory retention periods or when the purpose of the processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.
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 posts, as well as information relating to them, such as details of 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 the retrieval of data or access times); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Service recipients and clients; Prospective customers; Communication partners; Business and contractual partners; Third parties; Users (e.g. website visitors, users of online services); Employees (e.g. employees, applicants, temporary staff and other staff). Customers.
Purposes of 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; finance 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(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR). Legal obligation (Art. 6(1)(c) GDPR).
Further information on processing operations, procedures and services:
Customer management and customer relationship management (CRM): Procedures required in the context 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 regard to data protection, data management and analysis to support customer relations, administration of CRM systems, secure account management, customer segmentation and target group formation); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Contact management and contact maintenance: Procedures necessary for the organisation, maintenance and security of 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 adjusting contact strategies); Legal bases: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
General payment transactions: Procedures necessary for the execution of payment transactions, monitoring of bank accounts and control of payment flows (e.g. creation and verification of transfers, processing of direct debits, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and checking business transactions in the area of accounts payable and accounts receivable (e.g. creation and verification of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, handling of the dunning process, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable) ; Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Financial accounting and taxes: Procedures required for the recording, management and control of financially relevant business transactions and 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 reminders, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(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 determination, 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(1)(f) GDPR).
Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and implementation 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, corporate branding support); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Providers and services used in the course of business activities
In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (hereinafter referred to as ‘services’) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economical 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 posts, as well as information relating to them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
Data subjects: Service recipients and clients; interested parties; business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other employees).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational 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: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing procedures, processes and services:
DATEV: Software for accounting, communication with tax advisors and authorities, and document storage; Service provider: DATEV eG, Paumgartnerstr. 6 - 14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/. Data processing agreement: Provided by the service provider.
Payment procedures
Within the framework of contractual and other legal relationships, on the basis of legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use banks, credit institutions and other service providers (collectively referred to as ‘payment service providers’) for this purpose.
The data processed by the payment service providers includes inventory data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. This information is necessary to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or rejecting 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 verify identity and creditworthiness. For more information, please refer to the terms and conditions and privacy policy of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which can be found on their websites or in their transaction applications. We also refer to these for further information and to assert rights of revocation, information and other rights of data subjects.
Types of data processed: Master 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 dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Contact data (e.g. postal and email addresses or telephone numbers).
Data subjects: Service recipients and clients. Business and contractual partners.
Purposes of 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(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing procedures, methods and services:
GoCardless: Payment services (technical connection of online payment methods); Service provider: GoCardless GmbH, Herzogspitalstr. 24, 80331 Munich, Germany; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://gocardless.com/. Privacy policy: https://gocardless.com/de-de/rechtliches/datenschutz/.
Provision of online services and web hosting
We process user 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 end device.
Types of data processed: Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time stamps, 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. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures. 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’.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a ‘web host’). Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Collection of access data and log files: Access to our online offering is logged in the form of so-called ‘server log files’. Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilisation and stability; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Email dispatch and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information relating to the sending of emails (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the Internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of emails between the sender and the recipient on our server; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/vereinbarung-zur-auftragsverarbeitung-avv-mit-ionos-abschliessen/.
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter referred to as ‘publication medium’). Readers' data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication medium in this privacy policy.
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 image-based messages and posts, as well as information relating to them, such as details of authorship or time of creation) ; usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
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(1)(f) GDPR).
Communication via messenger
We use messengers for communication purposes and therefore ask you to note the following information on the functionality of messengers, encryption, the use of communication metadata and your options for objection.
You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options provided to you or the contact options specified within our online offering.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata).
Information on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Furthermore, if we do not ask for consent and you contact us on your own initiative, for example, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of our communication partners' needs for communication via messenger. Furthermore, we would like to point out that we will not transfer the contact details provided to us to Messenger without your consent.
Revocation, objection and deletion: You may revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any questions from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.
Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that we may not be able to respond to enquiries via Messenger for certain reasons. This applies to situations in which, for example, contract details must be treated as particularly confidential or a response via messenger does not meet formal requirements. In these cases, we recommend that you use more suitable communication channels.
Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers) ; content data (e.g. text or image messages and posts, as well as information relating to them, such as details of 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). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing: Communication. Direct marketing (e.g. by email or post).
Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
Legal basis: Consent (Art. 6(1)(a) GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
Threema: Encrypted messaging, voice and video calls, file and media exchange, surveys and polls, group chat functionality, contact verification via QR codes, no telephone number or email address required; Service provider: Threema GmbH, Churerstrasse 82, 8808 Pfäffikon SZ, Switzerland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://threema.ch/en. Privacy policy: https://threema.ch/de/privacy.
WhatsApp: Text messages, voice and video calls, sending images, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third country transfers: Data Privacy Framework (DPF).
Video conferences, online meetings, webinars and screen sharing
We use platforms and applications from other providers (hereinafter referred to as ‘conference platforms’) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as ‘conferences’). We comply with legal requirements when selecting conference platforms and their services.
Data processed by conference platforms: When participants take part in a conference, the conference platforms process the personal data of the participants as described below. The scope of the processing depends, on the one hand, on what data is required for a specific conference (e.g. access data or real names) and, on the other hand, on what optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the conference platforms may also process participants' data for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e. entries in chats as well as audio and video data, and the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users on the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, participants will be informed of this in advance in a transparent manner and, where necessary, asked for their consent.
Data protection measures for participants: Please refer to the conference platforms' data protection information for details on how your data is processed and select the security and data protection settings that are best for you in the conference platform settings. Please also ensure that your data and privacy are protected in the background of your recording for the duration of a video conference (e.g. by informing housemates, locking doors and, where technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.
Information on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of processing conversation results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
Types of data processed: Inventory data (e.g. 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, as well as information relating to them, such as details of 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); Image and/or video recordings (e.g. photographs or video recordings of a person); Sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times).
Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication. 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(1)(f) GDPR).
Further information on processing procedures, methods and services:
Microsoft Teams: Used to conduct online events, conferences and communication with internal and external participants. Voice transmission, direct messaging, group communication and collaboration functions are used; names, business contact details, work profiles, participation and content (audio/video, voice, chat, files, voice transcription) are processed for the purposes of and in the interests of increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform and Microsoft business processing. Audio signals are not stored unless recording is activated. Meeting and conference recordings are stored for 90 days by default, unless a different duration is specified. Chat and file content is stored according to the guidelines specified by the administrator or user; automatic deletion is not set by default. Channels must be renewed every 180 days, otherwise content will be deleted. In addition, system-generated log, diagnostic and metadata are processed, and diagnostic data on product stability, security and improvement is collected; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
Cloud services
We use software services accessible via the Internet and executed 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 specific recipients, or publication of content and information).
In this context, personal data may be processed and stored on the providers' servers if it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimise their services.
If we use cloud services to provide forms or similar items for other users or publicly accessible websites documents and content for other users or publicly accessible websites with the help of cloud services, the providers may store cookies on users' devices for web analysis purposes 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. text or image messages and posts, as well as information relating to them, such as details of 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).
Data subjects: Prospective customers; communication partners. Business and contractual partners.
Purposes of processing: Office and organisational procedures. 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: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing procedures, processes and services:
Dropbox: Cloud storage service; Service provider: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.dropbox.com/de; Privacy policy: https://www.dropbox.com/privacy; Data processing agreement: https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf).
Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, and use of system-generated log, diagnostic and metadata for contract execution by Microsoft. The following data is processed: contact details (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), and log and metadata. The processing is carried out for the purposes of increasing efficiency and productivity, cost efficiency, flexibility, mobility, improved communication, integration of Microsoft services, IT security and business processing by Microsoft. Data retention is based on the respective documents and company policies, up to 12 months for Defender (protection of data and IT systems) and 10 days for print management. In addition, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Newsletters and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter referred to as ‘newsletters’) exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually 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 potential defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called ‘blocklist’) for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing 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 details (e.g. postal and email addresses or telephone numbers). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g. by email or post).
Legal basis: Consent (Art. 6(1)(a) GDPR).
Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with the legal requirements.
Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.
After revocation or objection, we store the data necessary to prove previous authorisation for contact 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 users, we also store the data necessary to avoid renewed contact (e.g. depending on the communication channel, the email address, telephone number, name).
Types of 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 pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g. by email 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(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Presence on social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users, for example because 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, usage profiles can be created based on the usage behaviour and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users' computers, in which the usage behaviour and interests of users are stored. In addition, data may also be stored in the usage profiles independently of the devices used by 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 options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted 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 details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts, as well as information relating to them, such as details of 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).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
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(1)(f) GDPR).
Further information on processing operations, procedures and services:
Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.instagram.com; privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
Facebook pages: Profiles within the Facebook social network - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page (‘fan page’). This includes, in particular, information about user behaviour (e.g. content viewed or interacted with, actions performed) and device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical analyses via the ‘Page Insights’ service, which provide information about how people interact with our page and its content. This is based on an agreement with Facebook (‘Information about Page Insights’: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transfer to 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(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF), https://www.facebook.com/legal/EU_data_transfer_addendum.
Facebook groups: We use the ‘Groups’ feature of the Facebook platform to create interest groups within which Facebook users can connect with each other or with us and exchange information. In doing so, we process the personal data of the users of our groups to the extent necessary for the purpose of group use and moderation. Our guidelines within the groups may contain further specifications and information on the use of the respective group. This data includes first and last names, published or privately communicated content, as well as values relating to group membership status or group-related activities, such as joining or leaving, as well as the time details for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content that 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 ‘Insights’, to group operators so that they can gain insights into how people interact with their groups and the content associated with them; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
Facebook events: Event profiles within the Facebook social network – We use the ‘Events’ function of the Facebook platform to draw attention to events and dates, to get in touch with users (participants and interested parties) and to exchange information. In doing so, we process the personal data of users of our event pages to the extent necessary for the purpose of the event page and its moderation. This data includes first and last names, published or privately shared content, participation status, and the time of the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content users view or interact with, or the actions they take (see ‘Things you and others do and share’ 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 ‘Insights’, to event organisers so that they can gain insights into how people interact with their event pages and related content; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/personalizationoff.
Plug-ins and embedded functions and content
We integrate 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 users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, but may also be linked to such information from other sources.
Information 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, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved); Location data (information about the geographical position of a device or person). 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 persons or their actions. This data includes details about 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 written comments, login information, or contact information such as names, email addresses, or telephone numbers. ‘Event data’ is deleted by Meta after a maximum of two years, and the target groups formed from it disappear when our Meta user accounts are deleted.
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offering and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-based profiling, use of cookies); target group formation; marketing; provision of contractual services and fulfilment of contractual obligations. 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 specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing procedures, methods and services:
Facebook plugins and content: Facebook social plugins and content – This may include content such as images, videos or text and buttons that allow users to 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/ - Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt in the context of a transfer (but not the further processing) of ‘event data’ which Facebook collects or receives as part of a transfer for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) delivering commercial and transaction-related messages (e.g. contacting users via Facebook Messenger); c) improving ad delivery and personalising features and content (e.g. improving the recognition of which content or advertising information is likely to correspond to the interests of users). We have entered into a special agreement with Facebook (‘Addendum for Controllers’, https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with data subject rights (i.e. users can, for example, send requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. no information about individual users is received and they are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement (‘Data Processing Terms’, https://www.facebook.com/legal/ terms/dataprocessing) , the ‘Data Security Terms’ (https://www.facebook.com/legal/terms/data_security_terms) 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 the right 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(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
Google Fonts (provision on our own server): Provision of font files for the purpose of user-friendly presentation of our online offering; Service provider: Google Fonts are hosted on our server; no data is transferred to Google; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Google Fonts (obtained from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform display and consideration of possible licensing restrictions. The IP address of the user is communicated to the font provider so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e. the website on which the Google font is to be displayed). . IP addresses are neither logged nor stored on Google servers, and they are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must customise the font that is generated for the respective browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts ‘Analytics’ page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
Font Awesome (hosted on our own server): Display of fonts and symbols; Service provider: The Font Awesome icons are hosted on our server; no data is transmitted to the provider of Font Awesome; Legal basis: legitimate interests (Art. 6(1)(f) GDPR).
Google Maps: We integrate maps from the ‘Google Maps’ service provided by Google. The data processed may include, in particular, IP addresses and location data of users; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
Google Maps APIs and SDKs: Interfaces to Google's map and location services, which allow, for example, the completion of address entries, location determinations, distance calculations or the provision of additional information on locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
Instagram plugins and content: Instagram plugins and content – This may include content such as images, videos or text and buttons that allow users to share content from this online offering within Instagram. - Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt in the context of a transfer (but not the further processing) of ‘event data’ that Facebook collects or receives in the context of a transfer for the following purposes using Instagram functions (e.g. embedding functions for content) that are executed on our online offering: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g. contacting users via Facebook Messenger); c) Improving ad delivery and personalising functions and content (e.g. improving the recognition of which content or advertising information is likely to correspond to the interests of users). We have entered into a special agreement with Facebook (‘Addendum for Controllers’, https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with data subject rights (i.e. users can, for example, send requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. no information about individual users is received and they are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement (‘Data Processing Terms’, https://www.facebook.com/legal/terms/dataprocessing) the ‘Data Security Terms’ (https://www.facebook.com/legal/terms/data_security_terms) 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). Users' rights (in particular the right 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(1)(f) GDPR); Website: https://www.instagram.com. Privacy policy: https://privacycenter.instagram.com/policy/.
OpenStreetMap: We integrate maps from the ‘OpenStreetMap’ service, which are provided by the OpenStreetMap Foundation (OSMF) under the Open Data Commons Open Database Licence (ODbL). User data is used by OpenStreetMap exclusively for the purpose of displaying map functions and temporarily storing the selected settings. This data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually given in the settings of their end devices or browsers); Service provider: OpenStreetMap Foundation (OSMF); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.openstreetmap.de. Privacy policy: https://osmfoundation.org/wiki/Privacy_Policy.
reCAPTCHA: We integrate the ‘reCAPTCHA’ function in order to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically operating machines (so-called ‘bots’). The data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, cookies under certain circumstances, and results of manual recognition processes (e.g. answering questions or selecting objects in images). Data processing is based on our legitimate interest in protecting our online offering from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Changes and updates
We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. We will inform you as soon as the changes require your participation (e.g. consent) or other individual notification.
If we provide addresses and contact information for companies and organisations in this privacy policy, please note that the addresses may change over time and we ask you to check the information before contacting them.
Definition of terms
This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.
Employees: Employees are persons who are in an employment relationship, whether as staff, salaried employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs his or her work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the execution, in which the employee performs their work, and the termination, when the employment relationship ends, whether through dismissal, termination agreement or otherwise. Employee data is all information relating to these individuals 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.
Master data: Master data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities or systems by enabling unique identification and communication.
Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include 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 data: Contact data is essential information that enables communication with individuals 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.
Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about how 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 may include details such as file size, creation date, document author and change history. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages and chat histories, including the individuals involved, timestamps and transmission routes. Procedural data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
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 features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data may 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 identifying trends, preferences, and potential problem areas within digital offerings.
Personal data: ‘Personal data’ is any information relating to an identified or identifiable natural person (hereinafter ‘data subject’); A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special characteristics that express 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.) or to predict them (e.g. interest in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as 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, monitor security or create performance reports.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic 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 offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them to better tailor the content of their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more accurate analyses of the use of an online offering.
Location data: Location data is generated when a mobile device (or another device with the technical capabilities to determine its location) connects to a radio cell, Wi-Fi or similar technical means and functions for determining its location. Location data is used to indicate the geographically determinable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
Tracking: ‘Tracking’ refers to the tracking of user behaviour across multiple online services. As a rule, information about behaviour and interests is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling) with regard to the online services used. This information can then be used, for example, to display advertisements to users that are likely to match their interests.
Controller: The ‘controller’ is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: ‘Processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it is collection, evaluation, storage, transmission or deletion.
Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the terms and 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 the start and end dates of the contract, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is 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 dates, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorisations and fees.
Target group formation: Target group formation (known as ‘custom audiences’) refers to the determination of target groups for advertising purposes, e.g. the display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. The term ‘lookalike audiences’ (or similar target groups) is used when content that is considered suitable is displayed to users whose profiles or interests are presumed to correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.