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Preamble

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

The terms used are not gender specific.

As of: 6 May 2023

Responsible

neoponder GmbH
Ugur Tustas
Managing Director

Hornackswisch 11
22523 Hamburg

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E-mail address:

ugur.tustas@neoponder.de

Imprint:

www.neoponder.de/impressum

Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the persons affected.

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Types of data processed

  • Inventory data.

  • Payment data.

  • Location data.

  • Contact data.

  • Content data.

  • Contract data.

  • Usage data.

  • Meta, communication and procedural data.

 

Special categories of data

  • Health data.

  • Data on sex life or sexual orientation.

  • Religious or ideological beliefs.

  • Data revealing racial and ethnic origin.

 

Categories of persons affected

  • Customers.

  • Employees.

  • Interested parties.

  • Communication partners.

  • Users.

  • Business and contractual partners.

  • Pupils/students/participants.

  • Persons depicted.

 

Purposes of processing

  • Provision of contractual services and customer service.

  • Contact requests and communication.

  • Security measures.

  • Direct marketing.

  • Reach measurement.

  • Tracking.

  • Office and organizational procedures.

  • Conversion measurement.

  • Target group formation.

  • Management and response to inquiries.

  • Feedback.

  • Marketing.

  • Profiles with user-related information.

  • Provision of our online offering and user-friendliness.

  • Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.

  • Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.

  • Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.

  • Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) - Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, if certifications or binding internal data protection regulations exist (Art. 44 to 49 GDPR, information page of the EU Commission : https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Deletion of data

The data we process is deleted in accordance with legal requirements as soon as the consents to processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Our privacy policy may also contain further information on the storage and deletion of data, which applies primarily to the respective processing operations.

Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online offers and to create analyses of visitor flows.
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Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offer). Strictly necessary cookies generally include cookies with functions that serve to display and run the online service, load balancing, security, storing user preferences and choices, or similar purposes related to providing the main and secondary functions of the online service requested by users. The revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online service and improving its usability) or, if this is done as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
 
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
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 within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data in order to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and commercial business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by special marking (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 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons. The statutory retention period is ten years for documents relevant to tax law, as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of the commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was drawn up, the commercial or business letter was received or sent or the accounting document was created, the recording was made or the other documents were created.
If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.
 
  • Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact details (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category).
  • Special categories of personal data: health data (Art. 9 Para. 1 GDPR); data on sex life or sexual orientation (Art. 9 Para. 1 GDPR); religious or ideological beliefs (Art. 9 Para. 1 GDPR); data revealing racial and ethnic origin (Art. 9 Para. 1 GDPR).
  • Affected persons: interested parties; business and contractual partners; pupils/students/participants.
  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organizational procedures; administration and response to inquiries.
  • Legal bases: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b) GDPR); legal obligation (Art. 6 Para. 1 Clause 1 lit. c) GDPR); legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).

 

Further information on processing processes, procedures and services:

  • Education and training services: We process the data of participants in our education and training courses (uniformly referred to as "trainees") in order to be able to provide them with our training services. The data processed here, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of the teachers. As part of our activities, we can also process special categories of data, in particular information on the health of trainees and those receiving training as well as data that reveal ethnic origin, political opinions, religious or ideological beliefs. To do this, we will obtain an explicit consent from the trainees and those receiving training where necessary and otherwise only process the special categories of data if it is necessary to provide the training services, for the purposes of health care, social protection or the protection of the vital interests of the trainees and those receiving training; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

  • Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (collectively referred to as "clients") in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. As part of our work, we can also process special categories of data, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. To do so, we will obtain an explicit consent from the client where necessary and otherwise process the special categories of data if this serves the health of the client, the data is public or other legal permissions exist. If it is necessary for our contract fulfilment, to protect vital interests or legally, or if the client has given their consent, we will disclose or transmit client data to third parties or agents, such as authorities, accounting offices and in the area of ​​IT, office or similar services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

  • Consulting: We process the data of our clients, clients, interested parties and other clients or contractual partners (collectively referred to as "clients") in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. If it is necessary for our contract fulfilment, to protect vital interests or legally, or if the client has given their consent, we will disclose or transmit client data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or similar services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

  • 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 be able to provide them with our course and training services. The data processed here, the type, scope, purpose and necessity of their processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services used and, if part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance assessment and evaluation of our services and those of the course and training leaders; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

  • Project and development services: We process the data of our customers and clients (hereinafter referred to as "customers") in order to enable them to select, purchase or commission the selected services or works and associated activities as well as to pay for them and make them available or to carry them out or provide 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 the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process it in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

  • Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. 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 the provision of services and billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

Provision of the online offer and web hosting

We process user data in order to be able 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. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).

  • Data subjects : users (e.g. website visitors, users of online services).

  • Purposes of processing : Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.

  • Legal basis : Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Collection of access data and log files : Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis : Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); Deletion of data : Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.

Special notes on applications (apps)

We process the data of the users of our application to the extent that this is necessary in order to provide the application and its functionalities to the users, to monitor its security and to develop it further. We can also contact users in compliance with the legal requirements if communication is necessary for the purposes of administration or use of the application. Furthermore, with regard to the processing of user data, we refer to the data protection information in this data protection declaration.

Legal basis : The processing of data required to provide the functionality of the application serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. approval of device functions). If the processing of data is not required to provide the functionality of the application, but serves the security of the application or our business interests (e.g. collection of data for the purposes of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

  • Types of data processed: inventory data (e.g. names, addresses); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).

  • Purposes of processing : Provision of contractual services and customer service.

  • Legal basis : Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Performance of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent that it is necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

  • Types of data processed : inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).

  • Data subjects : users (e.g. website visitors, users of online services).

  • Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness.

  • Legal basis : Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Contact and inquiry management

When you contact us (e.g. by post, contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.

  • Types of data processed : contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).

  • Data subjects : communication partners.

  • Purposes of processing : contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness.

  • Legal basis : legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR); performance of the contract and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form : If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis : Contractual fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Communication via messenger
We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objecting.
You can also contact us in alternative ways, e.g. by telephone or email. Please use the contact options provided to you or the contact options provided within our online offering.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we would like to point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption activated to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messenger cannot see the content, they can find out that and when communication partners are communicating with us, and technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Furthermore, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and there are no statutory retention periods that prevent deletion.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer inquiries via messenger. This is the case, for example, if internal contractual details require special confidentiality or if an answer via messenger does not meet the formal requirements. In such cases, we refer you to more appropriate communication channels.
  • Types of data processed: contact data (e.g. email, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); content data (e.g. entries in online forms).
  • Affected persons: communication partners.
  • Purposes of processing: contact inquiries and communication; direct marketing (e.g. by email or post).
  • Legal basis: consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).

Further information on processing procedures, methods 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 purposes of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "conference"). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: When participating in a conference, the conference platforms process the personal data of the participants listed below. The extent of the processing depends on which data is required as part of a specific conference (e.g. providing access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the participants' data can also be processed by the conference platforms for security purposes or service optimization. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content of the communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users on the conference platforms, then further data can be processed in accordance with the agreement with the respective conference provider.

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

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

Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, etc.). Furthermore, 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. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

  • Affected persons: communication partners; users (e.g. website visitors, users of online services); people depicted.

  • Purposes of processing: provision of contractual services and customer service; contact inquiries and communication; office and organizational procedures.

  • Legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

Cloud services

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

In this context, personal data can be processed and stored on the providers' servers if they are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. This data can include, in particular, master data and contact details of users, data on processes, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata, which they use for security purposes and to optimize the service.

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

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

  • Affected persons: customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners.

  • Purposes of processing: office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).

  • Legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. In addition, our newsletters contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure : Registration for our newsletter is always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

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

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was 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 delivery system.

Contents :

Information about us, our services, promotions and offers.

  • Types of data processed : inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).

  • Affected persons: communication partners.

  • Purposes of processing : direct marketing (e.g. by e-mail or post).

  • Legal basis : Consent (Article 6 (1) sentence 1 lit. a) GDPR).

  • Opt-out option : You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke consent given or to object to advertising communication at any time.

After revocation or objection, we store the data required to prove previous authorization for contacting or sending 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 respecting the user's revocation or objection, we also store the data required to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).

  • Types of data processed : inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).

  • Data subjects : communication partners.

  • Purposes of processing : direct marketing (e.g. by e-mail or post).

  • Legal basis : Consent (Article 6 (1) sentence 1 lit. a) GDPR); Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Web analysis, monitoring and optimization

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

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

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a device and read from it. The information collected includes in particular websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to us or the providers of the services we use collecting their location data, location data can also be processed.

The IP addresses of users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but 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 purposes of the respective processes.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

  • Affected persons: Users (e.g. website visitors, users of online services).

  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavior-related profiling, use of cookies); provision of our online offer and user-friendliness; conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing.

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

Presences in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce users' rights.

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

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

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

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).

  • Affected persons: Users (e.g. website visitors, users of online services).

  • Purposes of processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.

  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

Plugins 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 can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, the time of the visit and other information about the use of our online offer, as well as be linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); location data (information on the geographical position of a device or a person).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: provision of our online offer and user-friendliness; profiles with user-related information (creation of user profiles); marketing.

  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

Changes and updates to the privacy policy

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

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

Rights of the data subjects

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

  • Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising .

  • Right to withdraw consent : You have the right to withdraw your consent at any time.

  • Right to information : You have the right to request confirmation as to whether or not data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.

  • Right to rectification : You have the right, in accordance with the legal requirements, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.

  • Right to erasure and restriction of processing : You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.

  • Right to data portability : You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format or to request that it be transmitted to another controller in accordance with the legal requirements.

  • Complaint to a supervisory authority : Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you violates the provisions of the GDPR.

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