Privacy Policy

Controller

Types of Data Processed

• Inventory data (e.g., personal master data, names, addresses)
• Contact data (e.g., email, phone numbers)
• Content data (e.g., text entries, photographs, videos)
• Usage data (e.g., websites visited, interest in content, access times)
• Meta/communication data (e.g., device information, IP addresses)

Categories of Data Subjects

• Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as "users").

Purpose of Processing

• Provision of the online offering, its functions and content
• Responding to contact requests and communicating with users
• Security measures
• Reach measurement / marketing

Definitions

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data.

"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant Legal Bases

In accordance with Art. 13 GDPR, we inform you of the legal bases for our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and EEA, the following applies unless the legal basis is mentioned in the privacy policy:

The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;

The legal basis for processing to fulfil our services and carry out contractual measures as well as to respond to enquiries is Art. 6 para. 1 lit. b GDPR;

The legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR;

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

The legal basis for processing necessary to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.

The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.

The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 GDPR.

The processing of special categories of data (pursuant to Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.

Security Measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data and responses to data threats. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Cooperation with Processors, Joint Controllers and Third Parties

If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transfer data to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if a transfer of data to third parties, such as payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose, transfer or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that corresponds to legal requirements.

Transfers to Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons or companies, this only takes place if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we only process or have data processed in third countries with a recognised level of data protection, which includes US processors certified under the "Privacy Shield" or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page).

Rights of Data Subjects

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 legal requirements.

In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

In accordance with legal requirements, you have the right to request that data concerning you be deleted immediately or, alternatively, to request a restriction of processing of the data in accordance with legal requirements.

You have the right to request that data concerning you that you have provided to us be received in accordance with legal requirements and to request its transfer to other controllers.

You also have the right, in accordance with legal requirements, to lodge a complaint with the competent supervisory authority.

Right of Withdrawal

You have the right to revoke consent given with effect for the future.

Right to Object

You may object to the future processing of data concerning you in accordance with legal requirements at any time. The objection may be made in particular against processing for direct marketing purposes.

Cookies and Right to Object in Direct Marketing

"Cookies" are small files that are stored on users' computers. Different information can be stored within cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are referred to as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Likewise, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if they are only the controller's cookies, they are referred to as "first-party cookies").

We may use temporary and permanent cookies and will clarify this in our privacy policy.

If we ask users for consent to the use of cookies (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a GDPR. Otherwise, users' personal cookies are processed in accordance with the following explanations within the scope of this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR) or, if the use of cookies is necessary to provide our contractual services, pursuant to Art. 6 para. 1 lit. b GDPR, or, if the use of cookies is necessary to perform a task carried out in the public interest or in the exercise of official authority, pursuant to Art. 6 para. 1 lit. e GDPR.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offering may be available.

Deletion of Data

The data processed by us will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated within this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Changes and Updates to the Privacy Policy

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

Business-Related Processing

In addition, we process

• Contract data (e.g., subject matter of contract, term, customer category)
• Payment data (e.g., bank details, payment history)

from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Agency Services

We process our customers' data in the context of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In this context, we process inventory data (e.g., customer master data such as names or addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). In principle, we do not process special categories of personal data unless they are part of a commissioned processing. The data subjects include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of processing is to provide contractual services, billing and our customer service. The legal bases for processing arise from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimisation, security measures). We process data that is necessary for the establishment and fulfilment of contractual services and point out the necessity of their provision. Disclosure to external parties only takes place if it is required in the context of an order. When processing data provided to us in the context of an order, we act in accordance with the instructions of the clients and the legal requirements for order processing pursuant to Art. 28 GDPR and do not process the data for any purposes other than those of the order.

We delete the data after expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 years pursuant to Section 257 para. 1 German Commercial Code, 10 years pursuant to Section 147 para. 1 German Fiscal Code). In the case of data disclosed to us in the context of an order by the client, we delete the data in accordance with the specifications of the order, generally after the end of the order.

Administration, Financial Accounting, Office Organisation, Contact Management

We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the context of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c GDPR, Art. 6 para. 1 lit. f GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in processing lies in administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.

In this context, we disclose or transfer data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.

Furthermore, we store information about suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of later contact. This predominantly company-related data is generally stored permanently.

Business Analysis and Market Research

In order to operate our business economically, to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f GDPR, whereby the data subjects include contractual partners, prospects, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimise our offering and business efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised values.

If these analyses or profiles are personal, they will be deleted or anonymised upon termination by the users, otherwise after two years from the conclusion of the contract. In all other cases, the overall business analyses and general trend determinations are prepared anonymously wherever possible.

Privacy Notice in the Application Process

We process applicant data only for the purpose and within the scope of the application process in accordance with legal requirements. The processing of applicant data is carried out to fulfil our (pre)contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b GDPR and Art. 6 para. 1 lit. f GDPR if data processing becomes necessary for us, e.g. in the context of legal proceedings (in Germany, Section 26 German Federal Data Protection Act also applies).

The application process requires applicants to provide us with the applicant data. The necessary applicant data are marked if we offer an online form, otherwise they result from the job descriptions and generally include personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and certificates. In addition, applicants may voluntarily provide us with additional information.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this privacy policy.

Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated in the context of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g. health data such as severe disability status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants in the context of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data if these are required for the exercise of the profession).

If available, applicants can submit their applications to us via an online form on our website. The data is transmitted to us encrypted according to the state of the art.

Furthermore, applicants can send us their applications via email. However, please note that emails are generally not sent encrypted and applicants must ensure encryption themselves. We can therefore not accept any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or postal delivery instead. Instead of applying via the online form and email, applicants still have the option of sending us their application by post.

The data provided by applicants may be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Deletion takes place, subject to a legitimate revocation by the applicants, after the expiry of a period of six months, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any travel expense reimbursement are archived in accordance with tax law requirements.

Contact

When contacting us (e.g. via contact form, chat, email, telephone or via social media), the user's details are processed to handle the contact request and its processing pursuant to Art. 6 para. 1 lit. b (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f (other enquiries) GDPR. The users' details may be stored in a Customer Relationship Management system ("CRM system") or comparable enquiry organisation.

We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Hosting and Email Dispatch

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.

In this context, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offering on the basis of our legitimate interests in efficient and secure provision of this online offering pursuant to Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).

Collection of Access Data and Log Files

We or our hosting provider collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

Google AdWords and Conversion Measurement

We use the online marketing method Google "AdWords" to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. If a user is shown ads for products, for example, that they have shown interest in on other online offerings, this is referred to as "remarketing". For these purposes, when our and other websites on which the Google advertising network is active are accessed, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is saved on the user's device (comparable technologies may be used instead of cookies). This file records which websites the user has visited, what content they are interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit time and other information about the use of the online offering.

Furthermore, we receive an individual "conversion cookie". The information collected with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that could personally identify users.

Users' data is processed pseudonymously within the Google advertising network. This means that Google does not store and process, for example, the name or email address of users, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. This means that from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google's servers in the USA.

If we ask users for consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a GDPR. Otherwise, users' personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR).

Insofar as data is processed in the USA, the data transfer is based on the EU-US Data Privacy Framework (DPF) and additionally on Standard Contractual Clauses (SCCs) pursuant to Art. 46 para. 2 lit. c GDPR. Google is certified under the DPF: https://www.dataprivacyframework.gov/participant/5780.

For more information on Google's use of data, settings and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of ads by Google (https://adssettings.google.com/authenticated).

Reach Measurement with Matomo

In the context of reach analysis by Matomo, the following data is processed: the browser type and version you use, the operating system you use, your country of origin, date and time of the server request, the number of visits, your time spent on the website and the external links you have clicked. The IP address of users is anonymised before it is stored.

Matomo uses cookies that are stored on the user's computer and enable analysis of the use of our online offering by users. In the process, pseudonymous usage profiles of users can be created from the processed data. The cookies have a storage period of one week. The information generated by the cookie about your use of this website is only stored on our server and is not passed on to third parties.

Users can object to the anonymised data collection by the Matomo programme at any time with effect for the future by using the option below. In this case, a so-called opt-out cookie is placed in their browser, which means that Matomo no longer collects any session data. However, if users delete their cookies, this also means that the opt-out cookie is deleted and must therefore be reactivated by users.

The logs with users' data are deleted after a maximum of 6 months.

If we ask users for consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a GDPR. Otherwise, users' personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR).

Online Presences in Social Media

We maintain online presences within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. For US providers, data transfers are based on the EU-US Data Privacy Framework (DPF) and additionally on Standard Contractual Clauses (SCCs) pursuant to Art. 46 para. 2 lit. c GDPR.

Furthermore, users' data is usually processed for market research and advertising purposes. For example, usage profiles can be created from users' usage behaviour and the resulting interests. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

The processing of users' personal data is based on our legitimate interests in effective information of users and communication with users pursuant to Art. 6 para. 1 lit. f GDPR. If users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis for processing is Art. 6 para. 1 lit. a, Art. 7 GDPR.

For a detailed presentation of the respective processing and opt-out options, we refer to the information provided by the providers linked below.

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

• Facebook/Meta pages, groups (Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data - Privacy Policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, DPF: https://www.dataprivacyframework.gov/participant/4452.
• Google / YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, DPF: https://www.dataprivacyframework.gov/participant/5780.
• Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/Opt-Out: http://instagram.com/about/legal/privacy/.
• X (formerly Twitter) (X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy: https://x.com/privacy, Opt-Out: https://x.com/personalization.
• Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/Opt-Out: https://about.pinterest.com/privacy-policy.
• LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) - Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, DPF: https://www.dataprivacyframework.gov/participant/4287.
• Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) - Privacy Policy/Opt-Out: https://privacy.xing.com/en/privacy-policy.