WPTeam Privacy Policy - How we handle your data

We take the protection of your personal data very seriously. That is why we would like to explain to you openly and clearly what data we collect, what we use it for, and how we protect it reliably. Our goal is to make you feel secure at all times—whether you are visiting our website, using our WordPress services, or contacting us.

wpteam recht

Preamble

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

The terms used are not gender-specific.

As of September 19, 2025

Table of contents

Responsible party

WPTeam
Holger Korff
Alter Wall 32
20457 Hamburg

Authorized representatives: Holger Korff

Email address: kontakt@wpteam.io

Phone: +49 4141 510571

Legal notice: https://www.wpteam.io/impressum/

Overview of processing operations

The following overview summarizes the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

  • Inventory data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Image and/or video recordings.
  • Audio recordings.
  • Log data.

Categories of data subjects

  • Service recipients and clients.
  • Employees.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.
  • People depicted.
  • Third parties.
  • Customers.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Finance and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.
  • Artificial intelligence (AI).

Relevant legal basis

Relevant legal basis according to the GDPR: Below you will find an overview of the legal bases of the GDPR on 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 this in the privacy policy.

  • Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

Relevant legal basis under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (Swiss DSG for short). Unlike the GDPR, for example, the Swiss DSG does not generally require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully, and proportionately (Art. 6 (1) and (2) of the Swiss DSG). In addition, we only collect personal data for a specific purpose that is recognizable to the data subject and only process it in a manner that is compatible with this purpose (Art. 6 (3) of the Swiss DSG).

Note on the applicability of the GDPR and the Swiss FADP: This privacy policy serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “sensitive personal data,” the terms used in the GDPR, ‘processing’ of “personal data,” “legitimate interest,” and “special categories of data,” are used. However, the legal meaning of the terms continues to be determined in accordance with the Swiss FADP within the scope of the Swiss FADP.

Security measures

In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies we use and the processing of a complete IP address is not necessary, the IP address is shortened (also known as “IP masking”). In this case, the last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or significantly impede the identification of a person based on their IP address.

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and 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 indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, bodies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This double safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place. For more information on the DPF and a list of certified companies, please visit the U.S. Department of Commerce website at https://www.
dataprivacyframework.gov.
https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

Disclosure of personal data abroad: In accordance with the Swiss Federal Act on Data Protection (FADP), we only disclose personal data abroad if adequate protection of the persons concerned is guaranteed (Art. 16 FADP). If the Federal Council has not determined that adequate protection is provided (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures.

For data transfers to the US, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by a Swiss adequacy decision on June 7, 2024. In addition, we have concluded standard data protection clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and set out contractual obligations to protect your data.

This double safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard data protection clauses serve as additional security. Should changes arise within the framework of the DPF, the standard data protection clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers are certified under the DPF and whether standard data protection clauses are in place. The list of certified companies and further information on the DPF can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

Appropriate safeguards apply to data transfers to other third countries, including international agreements, specific guarantees, standard data protection clauses approved by the EDÖB, or internal company data protection regulations that have been pre-approved by the EDÖB or a competent data protection authority in another country.

General information on data storage and deletion

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

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

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

If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Storage and deletion of data: The following general periods apply to storage and archiving under German law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) No. 1 in conjunction with (4) HGB).
  • 8 years – Accounting documents, such as invoices and expense receipts (Section 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).
  • 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant to taxation, e.g., hourly wage slips, operating statements, calculation documents, price tags, but also payroll documents, insofar as they are not already accounting documents, and cash register receipts (Section 147 (1) No. 2, 3, 5 in conjunction with (3) AO, Section 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, as well as to process related inquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB)
    .
    Retention and deletion of data: The following general periods apply to retention and archiving in accordance with Austrian law:
    • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices, as well as all necessary work instructions and other organizational documents (Federal Tax Code (BAO §132), Commercial Code (UGB §§190-212)).
    • 6 years – Other business documents: Commercial or business letters received, copies of commercial or business letters sent, and other documents, provided they are relevant for tax purposes. This includes, for example, hourly wage slips, operating statements, calculation documents, price tags, and payroll documents, unless they are already accounting documents and cash register receipts (Federal Tax Code (BAO §132), Commercial Code (UGB §§190-212)).
    • 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).

    Data retention and deletion: 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 vouchers and invoices, as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
    • 10 years – Data necessary for considering potential claims for damages or similar contractual claims and rights, as well as for processing related inquiries, based on previous business experience and customary industry practices, is stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable in certain cases (Art. 127, 130 OR). After five years, claims for rent, lease and capital interest, as well as other periodic payments, for the delivery of food, for meals and for innkeeper’s debts, as well as for craftsmanship, small sales of goods, medical services, professional services provided by lawyers, legal agents, attorneys, and notaries, and from the employment relationship of employees (Art. 128 OR).

    Rights of data subjects

    Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

    • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing.
    • Right to withdraw consent: You have the right to withdraw your consent at any time.
    • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
    • Right to rectification: In accordance with legal requirements, you have the right to request that data concerning you be completed or that incorrect data concerning you be corrected.
    • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
    • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
    • Complaint to a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority,
      in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.
      Rights of data subjects under the Swiss FADP:

      As a data subject, you have the following rights under the provisions of the Swiss DSG:

      • 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 exercise your rights under this law and to ensure transparent data processing.
      • Right to data disclosure or transfer: You have the right to request the disclosure of your personal data that you have provided to us in a commonly used electronic format.
      • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
      • Right to object, erasure, and destruction: You have the right to object to the processing of your data and to request that your personal data be erased or destroyed.

      Business services

      We process data from 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 contractual partners (or pre-contractual), for example to respond to inquiries.

      We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of administrative tasks associated with these obligations and for company organization. We also process the data on the basis of our legitimate interests in both proper and business-oriented management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial 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. Contractual partners will be informed about other forms of processing, such as for marketing purposes, within the framework of this privacy policy.

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

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

      • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
      • Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
      • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
      • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
      • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

      Further information on processing operations, procedures, and services:

      • Online shop, order forms, e-commerce, and service fulfillment: We process our customers’ data to enable them to select, purchase, or order the selected products, goods, and related services, as well as to pay for and receive or have them delivered or performed. If necessary for the execution of an order, we use service providers, in particular postal, freight forwarding, and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing, as well as contact information for the purpose of consultation. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
      • IT services: We process the data of our customers and clients in order to enable them to plan, implement, and support IT solutions and related services. The required information is identified as such in the context of the order, project, or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information to enable any necessary consultations. Insofar as we obtain access to information from end customers, employees, or other persons, we process this information in accordance with legal and contractual requirements.
        The processing procedures include project management and documentation, which cover all phases from the initial requirements analysis to the completion of the project. This includes the creation and management of project schedules, budgets, and resource allocations. Data processing also supports change management, in which changes in the project process are documented and tracked to ensure compliance and transparency. Another process is customer relationship management (CRM), which involves recording and analyzing customer interactions and feedback to improve service quality and efficiently address individual customer needs. In addition, the processing process includes technical support and troubleshooting, which involves recording and processing support requests, troubleshooting, and regular maintenance.

        Furthermore, reporting and performance analysis are carried out, whereby performance indicators are recorded and evaluated in order to assess the effectiveness of the IT solutions provided and to continuously optimize them. All these processes are designed to ensure high customer satisfaction and compliance with all relevant requirements; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

      • Artistic services: The procedures within the scope of artistic services include the acquisition and management of customer and client data, which involves the collection, storage, and use of contact information, contract details, and project-related data. The management and coordination of artistic projects require the creation of project plans, the allocation of resources, the coordination of appointments, and the monitoring of progress. The processing of visitor data is necessary for the implementation of events and exhibitions, such as the collection of contact details for invitations, ticket sales, or newsletter registrations. Financial management in the context of artistic services involves the processing of personal data for invoicing, fee billing, and payment processing. Communication and exchange with customers, partners, and the public takes place via various channels such as email, social media, or messaging services and requires the use of personal data. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
      • Online courses and online training: We process the data of participants in our online courses and online training (collectively referred to as “participants”) in order to provide them with our course and training services. The data processed in this context, the type, scope, purpose, and necessity of its processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services used and, insofar as they are part of our range of services, personal specifications and results of the participants. The forms of processing also include performance assessment and evaluation of our services and those of the course and training instructors. In addition, depending on the equipment and structure of the respective courses or learning content, further processing procedures may be implemented, such as attendance tracking to document participation, progress monitoring to measure and analyze learning progress by collecting exam and test results, and analysis of interactions on learning platforms, such as forum posts and assignment submissions. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
      • Provision of software and platform services: We process the data of our users, registered users, and any test users (hereinafter collectively referred to as “users”) in order to provide them with our contractual services and, on the basis of legitimate interests, to ensure the security of our services and to further develop them. The required information is marked as such in the context of the order, purchase order, or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information for any necessary consultations. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
      • Film and television production: We process the data of our customers and clients to enable them to plan, produce, and distribute film and television content and related services. The necessary information includes the information required for project implementation and billing, as well as contact information for necessary coordination. If we get access to info about end customers, actors, employees, or other people, we process it in line with legal and contractual requirements. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR) .

      Business processes and procedures

      Personal data of service recipients and clients—including customers, clients, or, in special cases, patients, business partners, and other third parties—is 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 design operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies, and the assurance of internal billing and financial processes. In addition, the data supports the protection of the rights of the controller and facilitates administrative tasks and the organization of the company.

      Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. The data will be deleted after the expiry of the statutory retention periods or when the purpose of the processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.

      • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
      • Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; customers; third parties; users (e.g., website visitors, users of online services). Employees (e.g., employees, applicants, temporary staff, and other employees).
      • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and business management procedures; security measures; provision of our online services and user-friendliness; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
      • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
      • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR) ; legitimate interests (Art. 6 (1) (f) GDPR). Legal obligation (Art. 6 (1) (c) GDPR).

      Further information on processing operations, procedures, and services:

      • Contact management and maintenance: Procedures necessary for the organization, maintenance, and backup of contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adjusting contact strategies); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
      • Customer account: Customers can create an account within our online offering (e.g., customer or user account, or “customer account” for short). If registration of a customer account is required, customers will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration and subsequent logins and use of the customer account, we store the IP addresses of customers along with the access times in order to verify registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is stored for purposes other than provision in the customer account or must be retained for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the responsibility of customers to back up their data when terminating their customer account. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
      • General payment transactions: Procedures necessary for the execution of payment transactions, the monitoring of bank accounts, and the control of payment flows (e.g., creation and verification of transfers, processing of direct debits, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management). ; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

      • Accounting, accounts payable, accounts receivable: Procedures necessary for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable (e.g., creation and verification of incoming and outgoing invoices, monitoring and managing open items, executing payment transactions, handling dunning procedures, reconciling accounts in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR) , legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

      • Financial accounting and taxes: Procedures necessary for recording, managing, and controlling financially relevant business transactions, as well as for calculating, reporting, and paying taxes (e.g., account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

      • Marketing, advertising, and sales promotion: Processes required for marketing, advertising, and sales promotion (e.g., market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management, and cost control); Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

      • Public relations: Processes required in the context of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, corporate branding); Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

      Payment procedures

      Within the framework of contractual and other legal relationships, on the basis of legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use banks, credit institutions and other service providers (collectively referred to as “payment service providers”) for this purpose.

      The data processed by the payment service providers includes inventory data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, sum, and recipient-related information. This information is necessary to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means we do not receive any account or credit card-related information, but only information confirming or denying the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. For more information, please refer to the terms and conditions and privacy policy of the payment service providers.

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

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

      Further information on processing operations, procedures, and services:

      • PayPal: Payment services (technical connection of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.

      Provision of online services and web hosting

      We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

      • Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions) ; meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved); log data (e.g., log files relating to logins or the retrieval of data or access times). Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
      • Data subjects: Users (e.g., website visitors, users of online services).
      • Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
      • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
      • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

      Further information on processing operations, procedures, and services:

      • Provision of online services on our own/dedicated server hardware: To provide our online services, we use server hardware operated by us as well as the associated storage space, computing capacity, and software; Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR).
      • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful 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 prevent server overload (especially in the case of malicious attacks, known as DDoS attacks), and to ensure server utilization and stability. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
      • Email dispatch and hosting: The web hosting services we use also include the dispatch, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of emails (e.g., the providers involved) and the contents of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the Internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
      • netcup: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.netcup.de/; Privacy policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php. Data processing agreement: https://helpcenter.netcup.com/de/wiki/general/avv/.

      Use of cookies

      The term “cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online offerings and to analyze visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval 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 offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.

      Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, 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, a distinction is made between the following types of cookies:

      • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).
      • Permanent cookies: Permanent cookies remain stored even after the device is closed. This allows, for example, the login status to be stored and preferred content to be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage duration 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 their consent at any time and also object to the processing in accordance with the legal requirements, including by using the privacy settings of their browser.
        • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
        • Data subjects: Users (e.g., website visitors, users of online services).
        • Purposes of processing: Provision of our online offering and user-friendliness.
        • Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR). Consent (Art. 6 (1) (1) (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 specified 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 similar technologies that are used to store, read, and process information on users’ end devices. As part of this procedure, users’ consent for the use of cookies and the associated processing of information , including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: The duration of storage of the consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, details of the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used. Legal basis: Consent (Art. 6 (1) (a) GDPR).
        • Cookie opt-out: In the footer of our website, you will find a link that allows you to change your cookie settings and revoke your consent.
        • Real Cookie Banner: Consent management: Procedure for obtaining, logging, managing, and revoking consent, in particular for the use of cookies and similar technologies for storing, reading, and processing information on users’ end devices and for processing such information; Service provider: Execution on servers and/or computers under our own data protection responsibility; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://devowl.io/de/wordpress-real-cookie-banner/. Privacy policy: https://devowl.io/de/datenschutzerklaerung/.

        Registration, login, and user account

        Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The data processed includes, in particular, login information (user name, password, and email address).

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

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

        • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.) ; contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Log 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 contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online offering and user-friendliness.
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Deletion after termination.
        • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

        Further information on processing procedures, processes, and services:

        • Registration with pseudonyms: Users may use pseudonyms as user names instead of their real names; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR) .
          User profiles are not public: User profiles are not publicly visible or accessible.
          Two-factor authentication: Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. To this end, you must perform an additional authentication measure (e.g., enter a code sent to a mobile device) in addition to your password. We will inform you about the procedure we use. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
        • Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation, or consent of the users. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
        • No obligation to retain data: It is the responsibility of users to back up their data before the end of the contract upon termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

        Blogs and publication media

        We use blogs or similar means of online communication and publication (hereinafter referred to as “publication medium”). Reader data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication medium in this privacy policy.

        • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
        • Data subjects: Users (e.g., website visitors, users of online services).
        • Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness. Provision of contractual services and fulfillment of contractual obligations.
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
        • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

        Further information on processing operations, procedures, and services:

        Contact and inquiry management

        When contacting us (e.g., by mail, contact form, email, phone, or social media) and within the scope of existing user and business relationships, the information provided by the inquiring persons will be processed to the extent necessary to respond to contact requests and any requested measures.

        • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation) Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
        • Data subjects: Communication partners.
        • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
        • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

        Further information on processing procedures, processes, and services:

        • Contact form: When you contact us via our contact form, by email, or other means of communication, we process the personal data you provide in order to respond to and process your request. This usually includes information such as your name, contact information, and, if applicable, other information that is provided to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
        • National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
        • National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons in the Processing of Personal Data (Data Protection Act – DSG) . The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.
        • Relevant legal basis under the Swiss Data Protection Act: .

        Artificial intelligence (AI)

        We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in the use of AI are listed below. In accordance with the definition of an “AI system” as defined in Article 3 No. 1 of the AI Regulation, we understand AI to mean a machine-based system that is designed for varying degrees of autonomous operation, can be adaptable after its introduction, and produces results such as predictions, content, recommendations, or decisions from the inputs received that can influence physical or virtual environments.

        Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human control, purpose limitation, data minimization, integrity, and confidentiality. We ensure that the processing of personal data is always carried out on a legal basis. This can be either the consent of the data subjects or a legal permission.

        When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that AI providers comply with the applicable regulations. We also observe our obligations when using or operating the AI services we purchase. The processing of personal data by us and the AI providers is based exclusively on consent or legal authorization. In doing so, we attach particular importance to transparency, fairness, and maintaining human control over AI-supported decision-making processes.

        We implement appropriate and robust technical and organizational measures to protect the data processed. These measures ensure the integrity and confidentiality of the data processed and minimize potential risks. We conduct regular reviews of AI providers and their services to ensure ongoing compliance with current legal and ethical standards.

        • Types of data processed: Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation) . Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
        • Data subjects: Users (e.g., website visitors, users of online services). Third parties.
        • Purposes of processing: Artificial intelligence (AI).
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
        • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

        Further information on processing operations, procedures, and services:

        Video conferences, online meetings, webinars, and screen sharing

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

        Data processed by conference platforms: When participants take part in a conference, the conference platforms process the personal data of the participants as described below. The scope of the processing depends, on the one hand, on what data is required for a specific conference (e.g., access data or real names) and what optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the conference platforms may also process participant data 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 of communications, i.e., entries in chats as well as audio and video data, and the use of other available functions (e.g., surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users on the conference platforms, additional data may be processed in accordance with the agreement with the respective conference provider.

        Logging and recordings: If text entries, participation results (e.g., from surveys), and video or audio recordings are logged, participants will be informed of this in advance and, if necessary, asked for their consent.

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

        Information on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to the use of the conference platforms or certain functions (e.g., consent to the recording of conferences), the legal basis for 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 conversation results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

        • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Image and/or video recordings (e.g., photographs or video recordings of a person); Sound recordings. Log data (e.g., log files relating to logins or the retrieval of data or access times).
        • Data subjects: Communication partners; users (e.g., website visitors, users of online services). Persons depicted.
        • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
        • Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR).

        Further information on processing procedures, methods, and services:

        • Mailbox.org: We use the video chat function of Mailbox.org to conduct video conferences with you. Mailbox.org is a German developer that places great emphasis on the privacy of participants and is GDPR-compliant. According to Mailbox.org, connections, video, and audio are protected throughout via Transport Layer Security (TLS) or end-to-end encryption (E2EE). All video conferences run through our own data centers in Germany, spread across two independent locations in Berlin. This ensures that strict data protection and security requirements under German law are met. Service provider: mailbox.org is operated by:
          Heinlein Hosting GmbH
          Schwedter Straße 8/9A
          10119 Berlin; Website: https://mailbox.org/de/ . Privacy policy: https://mailbox.org/de/datenschutz/.

        Newsletter and electronic notifications

        We send newsletters, emails, and other electronic notifications (hereinafter referred to as “newsletters”) exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to provide you with a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter.

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

        The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

        Content:

        Information about us, our services, promotions, and offers.

        • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
        • Data subjects: Communication partners.
        • Purposes of processing: Direct marketing (e.g., by email or post).
        • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
        • Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter at the end of each newsletter, or you can use one of the contact options listed above, preferably email.

        Further information on processing procedures, methods, and services:

        • CleverReach: Email delivery and automation services; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.cleverreach.com/de; Privacy policy: https://www.cleverreach.com/de/datenschutz/. Data processing agreement: Provided by the service provider.

        Advertising communications via email, post, fax, or telephone

        We process personal data for the purposes of advertising communications, which may be carried out via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.

        Recipients have the right to revoke their consent at any time or to object to promotional communications at any time.

        After revocation or objection, we store the data necessary to prove previous authorization for contact or mailing for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objections of users, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).

        • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers) . Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
        • Data subjects: Communication partners.
        • Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
        • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

        Web analysis, monitoring, and optimization

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

        In addition to web analysis, we may 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, may be created for these purposes, and information may be stored in a browser or on a terminal device and then read. 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 by us or by the providers of the services we use, the processing of location data is also possible.

        In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context 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 procedures.

        Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to 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 length of stay, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions) . Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
        • Data subjects: Users (e.g., website visitors, users of online services).
        • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
        • Security measures: IP masking (pseudonymization of the IP address).
        • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

        Further information on processing procedures, methods, and services:

        • Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and identifies returning users with the help of a so-called “digital fingerprint,” which is stored anonymously and changed every 24 hours. With “digital fingerprinting,” user movements within our online offering are recorded using pseudonymized IP addresses in combination with user browser settings in such a way that it is not possible to draw conclusions about the identity of individual users. The user data collected in the context of using Matomo is only processed by us and is not shared with third parties; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://matomo.org/. Security measures: IP masking (pseudonymization of the IP address).

        Presence on social networks (social media)

        We maintain an online presence on social networks and process user data in this context in order to communicate with users who are active there or to provide 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, as it could, for example, make it more difficult to enforce user rights.

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

        For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer you to the privacy policies and information provided by the operators of the respective networks.

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

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

        Further information on processing, procedures, and services:

        • Vimeo: Social network and video platform; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR) ; Website: https://vimeo.com. Privacy policy: https://vimeo.com/privacy.
        • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR); Privacy policy:</ strong> https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF) . Opt-out option: https://myadcenter.google.com/personalizationoff.

        Plug-ins and embedded functions and content

        We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include graphics, videos, or city maps (hereinafter referred to collectively as “content”).

        The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering, but can also be linked to such information from other sources.

        Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to 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 length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved); Contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation).
        • Data subjects: Users (e.g., website visitors, users of online services).
        • Purposes of processing: Provision of our online offering and user-friendliness. Profiles with user-related information (creation of user profiles).
        • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
        • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

        Further information on processing operations, procedures, and services:

        Amendments and updates

        We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. We will inform you as soon as the changes require your involvement (e.g., consent) or other individual notification.

        If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and check the information before contacting them.

        Definition of terms

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

        • Employees: Employees are persons who are in an employment relationship, whether as staff, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer’s obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee performs their work, and the termination, when the employment relationship ends, whether through dismissal, termination agreement, or otherwise. Employee data is all information relating to these individuals and in the context of their employment.
          This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance reviews.
    • 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 individuals and services, institutions, or systems by enabling unique identification and communication.
    • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
    • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
    • Artificial intelligence (AI): The purpose of processing data using artificial intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleaning, and structuring of data, the training and application of AI models, and the continuous review and optimization of results, and is carried out exclusively with the consent of users or on the basis of legal permissions.
    • Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include information about file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission routes. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and review operations.
    • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and how they navigate through an application. Usage data can also include frequency of use, activity timestamps, 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., cookie), or one or more special 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 that consists of using 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 various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.). 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, monitor security, or generate performance reports.
    • Reach measurement:</ strong> Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them to better tailor the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
    • Controller: The “controller” is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
    • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it is collection, evaluation, storage, transmission, or deletion.
    • Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged, or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
    • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction.
      It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
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