Privacy Policy

The register of processing activities includes a collection of general information that is relevant to all processing procedures described below, as well as specific details on individual processing processes in which personal data (hereinafter also referred to as “data”) are processed. This structure is intended to both maintain clarity and provide precise information. The general information explains basic principles and guidelines that apply to all processing activities, such as compliance with data protection principles, the legal basis of data processing, and the handling of the rights of the data subjects. The specific part of the register lists detailed information on the individual processing processes, including the purpose of the data processing, the categories of data affected, the recipients of the data and, if applicable, the transfer of data to third countries. This register serves as a central document to ensure the transparency and traceability of data processing and is an essential element for fulfilling the documentation obligations under the General Data Protection Regulation (GDPR).

Preamble

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

The terms used are not gender-specific.

As of May 8, 2024

 

Table of contents

responsible person

Verena Schiessl
Verena Schiessl Consulting
Kloster-Prüll-Weg 7
93107 Thalmassing

E-mail address: schiessl.verena@gmail.com Phone: +491732660408 Imprint: vs-insights.com/impressum

Overview of processing

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

types of data processed

  • inventory data.
  • employee data.
  • payment details.
  • contact details.
  • content data.
  • contract data.
  • usage data.
  • Meta-, communication- and procedural data.
  • social data.
  • Image and/or video recordings.
  • sound recordings.
  • log data.
  • performance and behavioral data.
  • working time data.
  • creditworthiness data.
  • salary data.

Special categories of data

  • health data.
  • Religious or ideological beliefs.
  • union membership.

categories of data subjects

  • service recipient and client.
  • employees.
  • interested parties.
  • communication partner.
  • users.
  • business and contractual partners.
  • Persons depicted.
  • third parties.

purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • security measures.
  • direct marketing.
  • reach measurement.
  • tracking.
  • office and organizational procedures.
  • conversion measurement.
  • target group formation.
  • organizational and administrative procedures.
  • feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Assessment of creditworthiness and credit rating.
  • Establishment and implementation of employment relationships.
  • Information technology infrastructure.
  • financial and payment management.
  • public relations.
  • sales promotion.
  • business processes and business management procedures.

Relevant legal bases

Relevant legal bases under 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 domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contract performance and pre-contractual inquiries (Article 6 (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 taken at the request of the data subject.
  • Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) – the processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail.
  • Processing of special categories of personal data relating to healthcare, occupation and social security (Article 9 (2) (h) GDPR) – The processing is necessary for the purposes of preventive healthcare or occupational medicine, for the assessment of the employee’s capacity to work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social systems and services on the basis of Union or Member State law or on the basis of a contract with a healthcare professional.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on 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 deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. In addition, state data protection laws of the individual federal states may apply.

Relevant legal bases under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Data Protection Act (in short “Swiss DSG”). Unlike the GDPR, for example, the Swiss DSG does not generally stipulate that a legal basis for the processing of personal data must be stated and that the processing of personal data is carried out in good faith, is lawful and proportionate (Art. 6 para. 1 and 2 of the Swiss DSG). In addition, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in a way that is compatible with this purpose (Art. 6 para. 3 of the Swiss DSG).

Note on the validity of the GDPR and the Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss DSG and 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 requiring particular protection” used in the Swiss DSG, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DSG within the scope of the validity of the Swiss DSG.

security 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, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, 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, input, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

transmission of personal data

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

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transmission (Art. 49 Para. 1 GDPR). In addition, we will inform you of the basis for third-country transfers for the individual providers from the third country, with the adequacy decisions taking priority as the basis. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework.

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

According to Article 16 of the Swiss Data Protection Act, exceptions to the disclosure of data abroad may be permitted if certain conditions are met, including consent of the data subject, contract execution, public interest, protection of life or physical integrity, data made public or data from a legally provided register. These disclosures are always made in accordance with the legal requirements.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent is revoked or there are no further legal bases for the processing. This applies to cases in which the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require the data to be stored or archived for a longer period.

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

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

If there are several specifications regarding the retention period or deletion period for a date, the longest period always applies.

If a period does not expressly begin on a specific date and is 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 the context of which data is stored, the event triggering the period is the time at which the termination or other termination of the legal relationship takes effect.

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

Further information on processing procedures, methods and services:

  • 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 as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (Section 147 Paragraph 3 in conjunction with Paragraph 1 Nos. 1, 4 and 4a AO, Section 14b Paragraph 1 UStG, Section 257 Paragraph 1 Nos. 1 and 4, Paragraph 4 HGB).
    • 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g. hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register slips (Section 147 Paragraph 3 in conjunction with Paragraph 1 Nos. 2, 3, 5 AO, Section 257 Paragraph 1 Nos. 2 and 3, Paragraph 4 HGB).
    • 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights as well as to process related inquiries based on previous business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
  • Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:
    • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (OR)).
    • 10 years – Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as to process related requests, based on previous business experience and standard industry practices, are stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is applicable in specific cases (Art. 127, 130 OR). After five years, claims for rent, lease and capital interest as well as other periodic payments, from the delivery of food, for catering and for innkeeper’s debts, as well as from craft work, retail sales of goods, medical care, professional work by lawyers, legal agents, procurators and notaries and from the employment relationship of employees expire (Art. 128 OR).

rights of the data subjects

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

  • Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
  • Right to withdraw consent: You have the right to withdraw 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 request information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: In accordance with the statutory provisions 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 habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of the data subjects under the Swiss DSG:

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

  • Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing.
  • Right to data disclosure or transfer: You have the right to request that we provide you with your personal data in a common electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, deletion and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be deleted or destroyed.

Business Services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”), within the framework of contractual and comparable legal relationships and associated 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 service disruptions. In addition, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and company organization. In addition, we process the data on the basis of our legitimate interests in both proper and economical business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. 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 fulfill legal obligations. The contractual partners are informed about other forms of processing, such as for marketing purposes, in this data protection declaration.

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

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

  • Types of data processed: Inventory data (e.g. full name, home 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 of the contract, term, customer category).
  • Affected persons: service recipients and clients; interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and commercial procedures.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

  • Consulting: We process the data of our clients, interested parties and other clients or contractual partners (collectively referred to as “clients”) in order to be able to provide our services to them. The procedures that are part of and for the purposes of consulting include: contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, collecting and managing client-specific information and data, scheduling and organizing appointments, providing consulting resources and materials, billing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.If it is necessary for our contract fulfilment, to protect vital interests or legally, or if the client has given their consent, we will disclose or transmit client data to third parties or agents, such as authorities, subcontractors or in the area of ​​IT, office or similar services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
  • Data analysis: We process the data of our customers and clients in order to provide them with data analysis, evaluation and advice as well as related services. The required information includes the information required for analysis, evaluation and billing as well as contact information for necessary coordination. If we receive access to information from end customers, employees or other persons, we process it in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
  • Management consulting: We process the data of our customers, clients, interested parties and other clients or contractual partners (collectively referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.If it is necessary for our contract performance or legally required, or if the customer has given their consent, we will disclose or transmit customer data to third parties or agents, such as authorities, courts or in the field of IT, office or similar services, in compliance with professional regulations; legal basis: contract performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

business processes and procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the 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 fulfill contractual obligations and to make operational processes efficient. This includes processing business transactions, managing customer relationships, optimizing sales strategies and ensuring internal accounting and financial processes. In addition, the data supports the protection of the rights of the person responsible and promotes administrative tasks and the organization of the company.

Personal data may be passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations. After the statutory retention periods have expired or if the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer due to tax and legal proof obligations.

  • Types of data processed: Inventory data (e.g. full name, home 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. textual or visual messages and contributions as well as the 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); protocol data (e.g. log files relating to logins or the retrieval of data or access times); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behaviour). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services). Employees (e.g. employees, applicants, temporary workers and other staff).
  • 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; assessment of creditworthiness and credit rating; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR).

Further information on processing procedures, methods and services:

  • Contact management and contact maintenance: Procedures required to organize, maintain and secure contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly checking communication history and adapting contact strategies); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR), Legitimate Interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
  • General payment transactions: procedures that are necessary for carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, processing direct debit transactions, checking account statements, monitoring incoming and outgoing payments, direct debit management, account reconciliation, cash management); Legal bases: contract performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
  • Accounting, accounts payable accounting, accounts receivable accounting: Procedures that are required for the recording, processing and control of business transactions in the area of ​​accounts payable and accounts receivable accounting (e.g. creation and checking of incoming and outgoing invoices, monitoring and management of open items, implementation of payment transactions, processing of dunning procedures, account reconciliation in the context of receivables and liabilities, accounts payable accounting and accounts receivable accounting); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
  • Financial accounting and taxes: procedures required for the recording, administration and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and filing of tax returns, processing of tax matters); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: procedures that are necessary 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 programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
  • Public relations: procedures that are required within the framework of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, preparation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, maintenance of corporate branding); Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Use of online platforms for offer and sales purposes

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

  • Types of data processed: Inventory data (e.g. full name, home 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); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved).
  • Affected persons: Service recipients and clients. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing; business processes and commercial procedures. Communication.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

  • GULP: Services related to the search for project services, experts and freelancers, communication, offer processing and contract negotiations; Service provider: Gulp Information Services GmbH, Landsberger Straße 187, 80687 Munich, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://www.gulp.de ; Data protection declaration: https://www.gulp.de/agb/datenschutz-und-anonymitaet . Basis for third country transfers: Switzerland – adequacy decision (Germany).

Providers and services used in the course of business activities

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

  • Types of data processed: Inventory data (e.g. full name, home 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. textual or visual messages and contributions as well as the 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).
  • Affected persons: service recipients and clients; interested parties; business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures. Business processes and commercial procedures.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • sevDesk: Online software for invoicing, accounting, banking and tax filing with receipt storage; Service provider: sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://sevdesk.de/ ; Data protection declaration: https://sevdesk.de/datenschutz/ ; Data processing agreement: https://sevdesk.de/datenschutz/ . Basis for third country transfers: Switzerland – adequacy decision (Germany).

provision of the online offer 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 device.

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved). Protocol data (e.g. log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures. Provision of contractual services and fulfillment of contractual obligations.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods 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 from a corresponding server provider (also called “web host”) or obtain from other sources; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter 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”. The server log files can 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 access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
  • 1&1 IONOS: Services in the field of the 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 Clause 1 lit. f) GDPR); Website: https://www.ionos.de ; Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy ; Contract processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/ . Basis for third country transfers: Switzerland – adequacy decision (Germany).

use of cookies

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

Notes on consent:  We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless it is not required by law. Permission is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent will be clearly communicated to them and will contain information on the respective cookie usage.

Notes on data protection legal bases:  The data protection basis on which we process users’ personal data using cookies depends on whether we ask them for consent. If users accept, the legal basis for the use of their data is their declared consent. Otherwise, the data used using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to meet our contractual obligations. We will explain the purposes for which we use cookies in the course of this data protection declaration or as part of our consent and processing processes.

Storage period:  With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the 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 using cookies can also be used to measure reach. If we do not provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

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

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a consent management solution that obtains users’ consent to the use of cookies or to the procedures and providers named in 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 to store, read and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. The consent declarations are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The data is stored on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information is available about the providers of consent management services, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the end device used; Legal basis: consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR).

contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent that this is necessary to answer the contact inquiries and any requested measures.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation).
  • Data subjects: communication partners.
  • Purposes of processing: communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

communication via messenger

We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.

You can also contact us in alternative ways, e.g. by telephone or email. Please use the contact options provided to you or the contact options provided 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 a current version of the messenger with encryption activated to ensure that the message content is encrypted.

However, we would also like to point out to our communication partners that although the providers of the messengers cannot see 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) are also processed.

Notes 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. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger 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 meeting the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.

Revocation, objection and deletion: You can 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 information from the communication partners, if no reference to a previous conversation is to be expected and there are no statutory retention periods that prevent deletion.

Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that for certain reasons we may not be able to answer inquiries via messenger. This applies to situations in which, for example, contract details must be treated with particular confidentiality or a response via messenger does not meet the formal requirements. In these cases, we recommend that you use more suitable communication channels.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Affected persons: communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: communication; direct marketing (e.g. by email or post); reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavior-based profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
  • Legal basis: Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

  • Microsoft Teams: Microsoft Teams – Messenger; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365 ; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement , Security information: https://www.microsoft.com/de-de/trustcenter . Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
  • Signal: Signal Messenger with end-to-end encryption; Service provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite 120-223 Mountain View, CA 94041, USA; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://signal.org/de/ . Privacy policy: https://signal.org/legal/ .
  • WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Website: https://www.whatsapp.com/ ; Privacy Policy: https://www.whatsapp.com/legal . Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
  • LinkedIn: Social Network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not further processing) of visitor data created for the purposes of creating the “Page Insights” (statistics) of our LinkedIn profiles. 
    This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user’s profile, such as job function, country, industry, hierarchy 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 (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum ), in which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of those affected (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, in particular 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 Clause 1 Letter f) GDPR); Website: https://www.linkedin.com ; Privacy Policy: https://www.linkedin.com/legal/privacy-policy ; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out . 
  • LinkedIn advertisements: placement of advertisements within the LinkedIn platform and evaluation of the ad results; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; legal basis: consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); website: https://business.linkedin.com/de-de/marketing-solutions/ads ; data protection declaration: https://www.linkedin.com/legal/privacy-policy ; basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – adequacy decision (Ireland); possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out . Further information: https://legal.linkedin.com/dpa .
  • LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user’s behavior and conversions and saves them in a profile (possible purposes: measuring campaign performance, optimizing ad delivery, building user-defined and similar target groups); service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; legal basis: consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); website: https://www.linkedin.com ; privacy policy: https://www.linkedin.com/legal/privacy-policy , cookie policy: https://www.linkedin.com/legal/cookie_policy ; order processing agreement: https://www.linkedin.com/legal/l/dpa ; basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – adequacy decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .
  • LinkedIn plugins and content: LinkedIn plugins and content – This can include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://www.linkedin.com ; Privacy policy: https://www.linkedin.com/legal/privacy-policy ; Contract processing agreement: https://legal.linkedin.com/dpa ; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .

video conferences, online meetings, webinars and screen sharing

We use platforms and applications from other providers (hereinafter referred to as “conference platforms”) for the purposes of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conferences”). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: When participating in a conference, the conference platforms process the personal data of the participants listed below. The extent of the processing depends on which data is required as part of a specific conference (e.g. providing access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data can also be processed by the conference platforms for security purposes or service optimization. The data processed includes personal data (first name, last name), contact information (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-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of the communications is encrypted to the extent technically provided by the conference provider. If the participants are registered as users on the conference platforms, then additional data can 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, this will be communicated transparently to the participants in advance and they will be asked for their consent, if necessary.

Participants’ data protection measures: Please refer to the conference platforms’ data protection notices for details of how your data is processed by them and select the security and data protection settings that are best for you in the settings of the conference platforms. Please also ensure that data and personal data are protected in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and using the function to blur the background, if technically possible). Links to the conference rooms and access data must not be passed on to unauthorized third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing discussion results, etc.). In addition, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Protocol data (e.g. log files relating to logins or the retrieval of data or access times).
  • Affected persons: communication partners; users (e.g. website visitors, users of online services). Persons depicted.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

cloud services

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

In this context, personal data may be processed and stored on the providers’ servers if they are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. 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 the cloud services also process usage data and metadata, which they use for security purposes and to optimize the service.

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

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the 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, device types and operating systems used, interactions with content and functions).
  • Affected persons: interested parties; communication partners; business and contractual partners.
  • Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

web analysis, monitoring and optimization

Web analysis (also known as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. Using reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or encourage reuse. It is also possible for us to understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a 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 consented to us or the providers of the services we use collecting their location data, the processing of location data is also possible.

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

Notes on legal bases: If we ask users for their consent to use 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 data protection declaration.

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavior-related profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing. Provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

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 may result in risks for users because it could, for example, make it more difficult to enforce user rights.

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

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

In the case of requests for information and the assertion of data subject rights, we would 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 email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • 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.
  • Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • LinkedIn: Social Network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not further processing) of visitor data created for the purposes of creating the “Page Insights” (statistics) of our LinkedIn profiles. 
    This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user’s profile, such as job function, country, industry, hierarchy 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 (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum ), in which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of those affected (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, in particular 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 Clause 1 Letter f) GDPR); Website: https://www.linkedin.com ; Privacy Policy: https://www.linkedin.com/legal/privacy-policy ; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out . 

change and update

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

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

definitions of terms

This section provides you with an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • Employees: Employees are people who are in an employment relationship, whether as employees, staff or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It involves the employer’s obligation to pay the employee remuneration while the employee performs his or her work. The employment relationship includes various stages, including the initiation, in which the employment contract is concluded, the implementation, in which the employee carries out his or her work activity, and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these people and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
  • Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data can include, among other things, 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, institutions or systems by enabling clear assignment and communication.
  • Content data: Content data includes information generated during the creation, editing and publishing of all types of content. 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 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 dates
  • Contact details: Contact details are essential information that enable communication with people or organizations. They include, among others, telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a process that can be used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to see whether the ads we have placed on other websites were successful.
  • Performance and behavioral data: Performance and behavioral data refers to information related to how people perform tasks or behave in a specific context, such as an educational, work, or social setting. This data may include metrics such as productivity, efficiency, quality of work, attendance, and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes, and responses to various situations. These types of data are often used for performance evaluations, training and development efforts, and decision-making within organizations.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information about file size, creation date, author of a document and change histories. Communication data records the exchange of information between users across different channels, such as email traffic, call logs, social media messages and chat histories, including the people involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review 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, which features they prefer, how long they spend on certain pages and which paths they take through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing 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” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more 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 consisting in the use of this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Log Data: Log data is information about events or activities logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the usage or operation of a system. Log data is often used to analyze system problems, monitor security, or create performance reports.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information relating to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is 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 covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Contract data: Contract data is specific information related to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed upon, pricing 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 needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorizations and fees.
  • Target group formation: Target group formation (English “custom audiences”) is when target groups are determined for advertising purposes, e.g. displaying 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 in which he viewed the products. “Lookalike audiences” (or similar target groups) are, in turn, when content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.

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