PRIVACY POLICY
Preamble
With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as „data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as „online offer”).
The terms used are not gender-specific.
Status: 1. April 2025
Content overview
- Preamble
- Responsible party
- Overview of processing
- Substantial legal foundations
- Safety measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of the person affected
- Business services
- Provision of the online offer and web hosting
- Use of cookies
- Contact and request management
- Communication via e‑mail, post, fax or telephone
- Web analysis, monitoring and optimization
- Presences in social networks (social media)
- Plug-ins and embedded functions as well as content
- Definitions of terms
Responsible party
Manuel Fleßenkämper
Grundstr. 3
35708 Haiger
Email address: hallo@flessenkaemper.eu
Phone: +49 2773 8729763
Imprint: https://flessenkaemper.eu/impressum/
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of processed data
- Inventory data.
- Payment data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Log data.
Categories of affected persons
- Service recipient and client.
- Interested parties.
- Communication partner.
- Users.
- Business and contractual partners.
- Education and course participants.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Range measurement.
- Office and organizational procedures.
- Organizational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offer and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Sales promotion.
- Business processes and business procedures.
Substantial legal foundations
Relevant legal bases according to the GDPR: In the following 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 regulations of the GDPR, national data protection requirements may apply in your or our country of residence or headquarters. Should more specific legal bases also be decisive in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given his consent to the processing of personal data concerning him or her for a specific purpose or more specific purposes.
- Performance of the contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.
- Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR) - The processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR) - the processing is necessary to safeguard the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject which require the protection of personal data do not prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and the transmission as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states can be applied.
Note on validity GDPR and Swiss DSG: This data protection information serves both to provide information according to the Swiss DSG and according to the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to the broader spatial application and comprehensibility. In particular, instead of the terms „processing” of „personal data”, „overriding interest” and „personal data that are particularly worthy of protection” used in the GDPR, the terms „processing” of „personal data” as well as „legitimate interest” and „special categories of data” are used in the GDPR. However, the legal meaning of the terms will continue to be determined by the Swiss DSG within the framework of the validity of the Swiss DSG.
Safety measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, the scope, the circumstances and the purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to them, input, disclosure, ensuring availability and separation. Furthermore, we have set up procedures that guarantee the exercise of data subject rights, the deletion of data and reactions to the data protection. Furthermore, we take into account the protection of personal data already in the development resp. Selection of hardware, software and procedures in accordance with the principle of data protection, through technical design and through data protection-friendly presets.
Transmission of personal data
As part of our processing of personal data, it happens that they are transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data can be e.g. B. service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or contracts. Agreements that serve to protect your data with the recipients of 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 we do this in the context of the use of third-party services or the disclosure or disclosure, the data process. If data is transmitted to other persons, bodies or companies (which is recognizable by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer to third countries), this is always done in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission of 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers that meet the requirements of the EU Commission and define contractual obligations to protect your data.
This double protection ensures comprehensive protection of your data: the DPF forms the primary protection layer, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses intervene as a reliable relapse option. This is how we ensure that your data is always adequately protected even in the event of any political or legal changes.
With the individual service providers, we inform you whether they are certified according to 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/.
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consents or legally required transmissions. Information on transfers to third countries and applicable adequacy decisions can be found in the information offered by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en? prefLang=en.
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 other legal basis for the processing. This applies to cases in which the original purpose of processing is no longer required or the data is no longer required. Exceptions to this regulation exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be stored for commercial or tax reasons or whose storage is necessary for legal prosecution or for the protection of the rights of other natural or legal persons must be archived accordingly.
Our privacy policy contains additional information on the storage and deletion of data that applies specifically to certain processing processes.
In the case of several information on the retention period or deletion periods of a date, the longest period is always decisive.
If a period does not expressly begin on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships, in the context of which data is stored, the event triggering the period is the time of the termination or other termination of the legal relationship.
Data that is no longer stored for the originally intended purpose, but on the basis of legal requirements or other reasons, we process exclusively for the reasons that justify their retention.
Further information on processing processes, procedures and services:
- Retention and deletion of data: The following general periods apply to the storage and archiving according to German law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with Para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with 4 HGB).
- 8 years – booking documents, e.g. B. Invoices and cost documents (§ 147 para. 1 no. 4 and 4a in conjunction with 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with 4 HGB).
- 6 years – Other business documents: received commercial or business letters, reproductions of the sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g. B. hourly wage slips, company accounting sheets, calculation documents, price markings, but also payroll documents, insofar as they are not already posting documents and cash registers (§ 147 para. 1 no. 2, 3, 5 in conjunction with 3 AO, § 257 1 No. 2 and 3 in conjunction with 4 HGB).
- 3 years – Data that is necessary to consider potential warranty and damage claims or similar contractual claims and rights and to process related requests, based on previous business experience and usual industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Rights of the person affected
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
- Right of withdrawal for consent: You have the right to revoke your consent at any time.
- Right to information: You have the right to request confirmation of whether the data concerned is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request its transmission to another controller.
- Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data violates the requirements of the GDPR.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as „contract partners”), within the framework of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.
We use this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other performance disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the organization of the company. In addition, we process the data on the basis of our legitimate interests both in proper and business management as well as security measures to protect our contractual partners and our business operations against misuse, endangerment of their data, secrets, information and rights (e.g. for the participation 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 the 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 for the fulfillment of legal obligations. The contractual partners are informed about other forms of processing, such as for marketing purposes, within the framework of this data protection declaration.
Which data is required for the aforementioned purposes, we communicate to the contractual partners before or in the context of data collection, e.g. in online forms, by special marking (e.g. colors) or Symbols (e.g. B. asterisks o. etc.), or personally with.
We delete the data after expiry of the statutory warranty and comparable obligations, i.e. in principle after four years, unless the data is stored in a customer account, e.g. B. as long as they have to be kept for legal reasons of archiving (for example for tax purposes, usually ten years). Data that has been disclosed to us within the framework of an order by the contractual partner, we delete in accordance with the specifications and in principle 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 details (e.g. postal and e‑mail addresses or telephone numbers). Contract data (e.g. subject of the contract, term, customer category).
- Affected persons: Service recipients and clients; interested parties; business and contractual partners. Education and course participants.
- Purposes of processing: provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business procedures.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”.
- Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as „trainees and trainees”) in order to be able to provide them with our training services. The data processed in this way, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance evaluation and the evaluation of our performance and that of the teachers. As part of our activities, we can also process special categories of data, in particular information on the health of the trainees and further training as well as data from which ethnic origin, political opinions, religious or ideological beliefs emerge. For this purpose, if necessary, we obtain the express consent of the trainers and further training and otherwise process the special categories of data otherwise only if it is necessary for the provision of the training services, for the purposes of health care, social protection or the protection of vitally necessary interests of the trainees and trainees; legal basis: performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online offer and web hosting
We process the data of the users in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the browser or the user’s end device.
- Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times.).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)) ; Safety measures. Provision of contractual services and fulfillment of contractual obligations.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Collection of access data and log files: Access to our online offer is logged in the form of so-called „server log files”. The server log files can include the address and name of the accessed websites and files, date and time of the retrieval, transmitted data volumes, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and usually IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. B. to avoid overloading of the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the workload of the servers and their stability; legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further retention of which is necessary for evidentiary purposes, is exempt from deletion until the final clarification of the respective incident.
- 1&1 IONOS: Services in the field of provision of 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. Order processing agreement:https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.
Use of cookies
The term „cookies” is understood to mean functions that store information on users’ end devices and read it from them. Cookies can also be used in relation to different concerns, for example for the purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. To this end, we obtain the consent of the users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offer. The consent can be revoked at any time. We clearly inform about their scope and which cookies are used.
Information on data protection legal bases: Whether we process personal data using cookies depends on consent. If there is consent, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and his end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used for range measurement. If we do not provide users with explicit information about the type and storage period of cookies (e.g. in the context of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.
- We use the Consent Tool „Real Cookie Banner” to manage the cookies used and similar technologies (tracking pixels, web beacons, etc.) and consents in this regard. Details on how „Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/.
The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f DS-GVO. Our legitimate interest is the management of the used cookies and similar technologies and the consents in this regard.
The provision of personal data is neither contractually prescribed nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
General information on revocation and objection (opt-out): Users can revoke the consents given by them at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Types of data processed: Meta, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
- Processing of cookie data based on consent: We use a consent management solution in which the consent of the users is obtained to the use of cookies or to the procedures and providers mentioned in the context of the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used for the storage, reading and processing of information on the users’ end devices. As part of this procedure, the consents of users for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored in order to avoid a new query and to be able to provide proof of consent in accordance with the legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or his device. If no specific information on the providers of consent management services is available, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created, which together with the time of consent, the information on the scope of consent (e.g. B. categories of cookies and/or service providers) as well as information about the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) GDPR).
Contact and request management
When contacting us (e.g. by post, contact form, e‑mail, telephone or via social media) as well as within the framework of existing user and business relationships, the information of the requesting persons will be processed, insofar as this is necessary to respond to the contact requests and any requested measures.
- Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.) ; Contact details (e.g. postal and e‑mail addresses or telephone numbers); content data (e.g. B. textual or pictoral messages and contributions as well as information concerning them, such as e.g. information on authorship or time of creation); usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
- Affected persons: Communication partners.
- Purposes of processing: communication; organizational and administrative procedures; feedback (e.g. collection of feedback via online form). Provision of our online offer and user-friendliness.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR). Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Contact form: When contacting us via our contact form, by e‑mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, other information that is communicated to us and is necessary for proper processing. We use this data exclusively for the stated purpose of contact and communication; legal bases: contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Communication via e‑mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which is transmitted via various channels, e.g. e‑mail, telephone, post or fax, in accordance with the legal requirements.
The recipients have the right to revoke consent at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove the previous authorization for contact or sending up to three years after the end of the year of the revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest, the revocation resp. If we permanently observe the objection of the users, we also store the data required to avoid contact again (e.g. depending on the communication channel, the e‑mail address, telephone number, name).
- Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.) ; Contact details (e.g. postal and e‑mail addresses or telephone numbers). Content data (e.g. B. textual or pictoral messages and contributions as well as information concerning them, such as e.g. information on authorship or time of creation).
- Affected persons: Communication partners.
- Purposes of processing: Direct marketing (e.g. by e‑mail or by post); Marketing. Sales promotion.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Web analysis, monitoring and optimization
The web analysis (also referred to as „reach measurement”) is used to evaluate the visitor flows of our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of range analysis, we can, for example, identify at what time our online offer or its functions or content are most often used, or invite them to reuse. It is also possible for us to understand which areas require optimization.
In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and then read out. The information collected includes in particular websites visited and elements used there as well as technical information, such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data vis-à-vis us or vis-à-vis the providers of the services used by us, the processing of location data is also possible.
In addition, the IP addresses of the users are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect the users. In general, the context of web analysis, A/B testing and optimization, the clear data of the users (e.g. e‑mail addresses or names), but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Notes on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, the user data will be 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 refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: range measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (cereation of user profiles). Provision of our online offer and user-friendliness.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e‑mail addresses. It serves to assign analysis information to an end device in order to recognize which content users have called up within one or several usage processes, which search terms they have used, have called them up again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log and store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). In the case of EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. If Google Analytics collects measurement data, all IP queries are carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adstermprocessors/; Third country transfer basis: Data Privacy Framework (DPF), Standard contract clauses (https://business.safety.google/processoradsterms), Data Privacy Framework (DPF) Standard contract clauses ( https://business.safety.google/adsprocessorterms); Objection possibility (opt-Out): Opt- hl=en, Settings for the display of advertising displays: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and the processed data).
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This can result in risks for users, because, for example, the enforcement of user rights could be made more difficult.
Furthermore, the data of the users within social networks are usually processed for market research and advertising purposes. For example, user profiles can be created based on the user behavior and the resulting interests of the user. The latter may in turn be used, for example, to place advertisements inside and outside the networks, which presumably correspond to the interests of the users. Therefore, cookies are usually stored on the computers of the users, in which the usage behavior and the interests of the users are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).
For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Even in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. If you still need help, you can contact us.
- Types of data processed: contact data (e.g. postal and e‑mail addresses or telephone numbers); content data (e.g. B. textual or pictoral messages and contributions as well as information concerning them, such as e.g. information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; Feedback (e.g. collection of feedback via online form). Public relations.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Instagram: Social network, allows sharing photos and videos, commenting and favoritise posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis third country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF).
- LinkedIn: Social Network – Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to create the „page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as professional function, country, industry, hierarchical level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have concluded a special agreement with LinkedIn Ireland („Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to comply with the rights of the data subjects (i.e. Users can e.g. information or deletion requests directly to LinkedIn). 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 LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis of third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa), Data Privacy Framework (DPF) Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Plug-ins and embedded functions as well as content
We integrate functional and content elements into our online offer, which are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as „content”).
The integration always presupposes that the third-party providers of this content process the IP address of the users, since they could not send the content to their browser without an IP address. The IP address is therefore necessary for the presentation of these contents or functions. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons”) for statistical or marketing purposes. The „pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and the operating system, websites to be referred to, the time of the visit and further information on the use of our online offer, but also be combined with such information from other sources.
Information on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis for the data processing is the permission. Otherwise, the user data will be used 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 refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness.
- Retention and deletion: Deletion according to the information in the section „General information on data storage and deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Google Fonts (sourced from Google Server): Purchase of fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address 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 are necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the provider of the fonts in the USA – When visiting our online offer, the browsers of the users send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CCS. These HTTP queries include (1) the IP address used by each user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent that describes the browser and operating system versions of the website visitors, and the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants 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 adjust the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These summarized usage statistics are published on the Google Fonts Analytics page. Finally, the reference 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 advertisements; Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy Basis; Third country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF). Further information:https://developers.google.com/fonts/faq/privacy? hl=de.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to serve understanding.
- Inventory data: Inventory 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 people and services, facilities or systems by enabling clear assignment and communication.
- Content data: Content data includes information generated in the course of the creation, processing and publication of content of all kinds. This category of data may include text, images, videos, audio files, and other multimedia content that are published on various platforms and media. Content data is not only limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication data
- Contact details: Contact details are essential information that allows communication with people or organizations. They include, among other things Phone numbers, postal addresses and e‑mail addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- Meta, communication and process data: Meta, communication and process data are categories that contain information about the way 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. They can include information about file size, creation date, document author, and change histories. Communication data records the exchange of information between users through various channels, such as e‑mail traffic, call logs, messages on social networks and chat histories, including the people involved, time stamps and transmission channels. Process data describes the processes and operations within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, what features they prefer, how long they stay on certain pages, and which paths they use to navigate an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information, and location data. They are especially valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and possible problem areas within digital offers
- Personal data: „Personal data” means any information relating to an identified or identifiable natural person (hereinafter „data subject”); an identifiable natural person is considered to be identified if, 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 specific characteristics that express the physical, physiological, genetic, psychological, 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 consisting in the use of such personal data to protect certain personal aspects relating to a natural person (depending on the type of profiling, different information concerning the demographics, behaviour and interests, such as e.g. the interaction with websites and their content, etc.) to analyze, evaluate or to predict them (e.g. the interests in certain content or products, the click behavior on a website or the 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 includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, to monitor security, or to create performance reports.
- Range measurement: The range measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can analyse the behavior or interests of the visitors in certain information, e.g. B. content of websites. With the help of range analysis, operators of online offers can e.g. B. recognize at what time users visit their websites and what content they are interested in. This allows you e.g. B. better adapt the content of the websites to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offer.
- Controller: „Controller” means the natural or legal person, public authority, agency or other body that, alone or jointly with others, decides on the purposes and means of processing personal data.
- Processing: „Processing” means any operation or set of operations carried out with or without automated means relating to personal data. The term goes far and covers practically any handling of data, be it the collection, evaluation, storage, transmission or deletion.
- Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and performance of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
- Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for e‑commerce, online banking, and any other form of financial transaction. They include details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and invoice information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
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