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Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. This 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.

Status: April 4, 2025

Legal text by Dr. Schwenke - please click for more information.

Table of Contents

Controller

kontekst software UG (haftungsbeschränkt) Maria-Theresia-Allee 19 52064 Aachen

Email address: info@kontekst.app

Imprint: https://kontekst.app/impressum/

Overview of Processing Activities

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

Types of Data Processed

  • Inventory data.
  • Employee data.
  • Payment data.
  • Location 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.
  • Depicted persons.
  • 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.
  • Login procedures.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.

Relevant Legal Bases

Relevant legal bases 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 regulations of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 data protection regulations apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG). The BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on applicability of GDPR and Swiss DPA: These privacy notices serve to provide information pursuant to both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data”, the terms used in the GDPR “processing” of “personal data” as well as “legitimate interest” and “special categories of data” are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

Security Measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, disclosure, ensuring availability and segregation of data. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data and response 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 through data protection-friendly default settings.

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

Transfer of Personal Data

In the context of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and economic interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or there are no longer any legal bases for processing. This applies to cases where the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist when legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law 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 privacy notices contain additional information on the retention and deletion of data that specifically applies to certain processing operations.

If there are multiple specifications for the retention period or deletion deadlines of data, the longest period is always decisive.

If a period does not expressly start on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the period is the time when the termination or other termination of the legal relationship takes effect.

Data that is no longer retained for the originally intended purpose, but due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Further notes on processing operations, procedures and services:

  • Retention and deletion of data: The following general deadlines apply to retention and archiving under German law:
    • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet and the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
    • 8 years - Accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
    • 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are of significance for taxation, e.g. hourly wage slips, operating cost accounting sheets, calculation documents, price labels, but also payroll accounting documents insofar as they are not already accounting documents and cash register receipts (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
    • 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 (§§ 195, 199 BGB).

Rights of Data Subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on 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 processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively to demand restriction of the processing of the data in accordance with legal requirements.
  • 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 its transmission to another controller.
  • Complaint to 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 where you usually reside, the supervisory authority of your workplace or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Business Services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”), in the context of contractual and comparable legal relationships as well as associated measures and in relation to communication with contractual partners (or pre-contractually), e.g. 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 safeguard our rights and for the purpose of administrative tasks associated with these obligations and corporate organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as 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 disclose 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 further forms of processing, for example for marketing purposes, within the scope of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, through special markings (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

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 legal reasons of archiving (for tax purposes usually ten years). We delete data disclosed to us by the contractual partner in the context of an order in accordance with the requirements and generally 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 contract, term, customer category).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • IT services: We process the data of our customers and clients to enable them to plan, implement and support IT solutions and related services. The required information is marked as such in the context of the order, project or comparable conclusion of contract and includes the information required for service provision and billing as well as contact information in order to be able to hold any consultations. Insofar as we gain access to information of end customers, employees or other persons, we process it in accordance with legal and contractual requirements. The processing operations include, among others, 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 flow are documented and tracked to ensure compliance and transparency.

    Another process is customer relationship management (CRM), which includes the recording and analysis of 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 includes the recording and processing of support requests, bug fixes and regular maintenance.

    Furthermore, reporting and performance analysis are carried out, whereby performance indicators are recorded and evaluated to assess the effectiveness of the provided IT solutions and to continuously optimize them. All these processes are designed to ensure high customer satisfaction and compliance with all relevant requirements; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

  • Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) to enable them to select, acquire or commission the selected services or works and related activities as well as their payment and provision or execution or provision.

    The required information is marked as such in the context of the order, purchase or comparable conclusion of contract and includes the information required for service provision and billing as well as contact information in order to be able to hold any consultations. Insofar as we gain access to information of end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

  • Provision of software and platform services: We process the data of our users, registered and possible test users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our offering and to be able to develop it further. The required information is marked as such in the context of the order, purchase or comparable conclusion of contract and includes the information required for service provision and billing as well as contact information in order to be able to hold any consultations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business Processes and Procedures

Personal data of service recipients and clients - including customers, clients or in special cases mandates, patients or business partners as well as 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 serves to fulfill contractual obligations and to organize business processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies as well as ensuring internal accounting and financial processes. In addition, the data supports the safeguarding of the controller’s rights and promotes administrative tasks and the organization of the company.

Personal data may be disclosed to third parties if this is necessary to fulfill the purposes mentioned or legal obligations. After the expiry of legal retention periods or when the purpose of processing ceases to apply, the data will be deleted. This also includes data that must be stored longer due to tax law and legal verification obligations.

  • 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. textual or pictorial messages and contributions as well as the information concerning them, such as information on authorship or time of creation); Contract data (e.g. subject matter of 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 information, identification numbers, persons involved); Log data (e.g. log files concerning logins or the retrieval of data or access times.). Employee data (information on employees and other persons in an employment relationship).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partners; Business and contractual partners; Customers; Third parties; Users (e.g. website visitors, users of online services). Employees (e.g. employees, applicants, temporary workers and other staff members).
  • 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 offering and user-friendliness; Communication; Marketing; Sales promotion; Public relations; Financial and payment management. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further notes on processing operations, procedures and services:

  • Customer management and customer relationship management (CRM): Procedures required in the context of customer management and customer relationship management (CRM) (e.g. customer acquisition in compliance with data protection requirements, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support customer relationships, management of CRM systems, secure account management, customer segmentation and target group formation); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Contact management and contact maintenance: Procedures required in the context of organizing, maintaining and securing contact information (e.g. setting up and maintaining a central contact database, regular updates of contact information, monitoring of data integrity, implementation of data protection measures, ensuring access controls, performing backups and restoration of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Customer account: Customers can create an account within our online offering (e.g. customer or user account, briefly “customer account”). If registration of a customer account is required, customers will be informed of this as well as the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the 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 be able to prove the registration and prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be deleted after the termination time, unless they are retained for other purposes 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 secure their data upon termination of the customer account; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Watchlist/Wishlist: Customers can create a product/wishlist. In this case, the products are stored as part of fulfilling our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we explicitly inform customers of different storage periods; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • General payment transactions: Procedures required when conducting payment transactions, monitoring bank accounts and controlling payment flows (e.g. creation and verification of transfers, processing of direct debit transactions, control of bank statements, monitoring of incoming and outgoing payments, chargeback management, account reconciliation, cash management); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the recording, processing and control of business transactions in the area of accounts payable and accounts receivable accounting (e.g. creation and verification of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation in the context of receivables and liabilities, accounts payable accounting and accounts receivable accounting); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Procedures required for the recording, management and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. posting and booking 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 bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Sales: Procedures required for the planning, execution and control of measures for marketing and selling products or services (e.g. customer acquisition, offer creation and follow-up, order processing, customer consulting and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and execution 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 bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Public relations: Procedures required in the context of public relations and 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 corporate websites, corporate branding support); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of Online Platforms for Offering and Sales Purposes

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

  • 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 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 information, identification numbers, persons involved).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

Providers and Services Used in Business Operations

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

  • 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. textual or pictorial messages and contributions as well as the information concerning them, such as information on authorship or time of creation); Contract data (e.g. subject matter of 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 information, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Communication partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures; Business processes and business management procedures; Direct marketing (e.g. by email or postal). Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

Provision of Online Offering and Web Hosting

We process users’ 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 device.

  • Types of data processed: 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 information, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes 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 (especially 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 bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident is finally clarified.
  • OVHcloud: Services in the field of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: OVH GmbH, St. Johanner Str. 41-43, 66111 Saarbrücken, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ovhcloud.com/de/; Privacy policy: https://www.ovh.de/schutz-personenbezogener-daten/. Data processing agreement: https://www.ovh.de/schutz-personenbezogener-daten/.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read it from them. Cookies can also be used for different purposes, such as for the functionality, security and convenience of online offerings as well as for the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain users’ consent in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential to provide expressly requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We clearly inform about its scope and which cookies are used.

Notes on legal bases for data protection: Whether we process personal data using cookies depends on consent. If consent is 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 duration: With regard to the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed 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 and preferred content can be displayed directly when the user visits a website again. Likewise, user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. as part of obtaining consent), users should assume that they are permanent and the storage duration can be up to two years.

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

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

Special Notes on Applications (Apps)

We process the data of users of our application insofar as this is necessary to provide users with the application and its functionalities, monitor its security and develop it further. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administration or use of the application. For the rest, we refer to the privacy notices in this privacy policy with regard to the processing of users’ data.

Legal bases: The processing of data necessary for the provision of the application’s functionalities serves to fulfill contractual obligations. This also applies if the provision of the functions requires authorization from users (e.g. release of device functions). If the processing of data is not necessary for the provision of the application’s functionalities, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimizing the application or security purposes), it takes place on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the processing of the data covered by the consent takes place on the basis of the consent.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); 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 information, identification numbers, persons involved); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of contract, term, customer category); Image and/or video recordings (e.g. photographs or video recordings of a person); Audio recordings. Location data (information on the geographical position of a device or person).
  • 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. Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • Commercial use: We process the data of users of our application, registered and possible test users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our application and to be able to develop it further. The required information is marked as such in the context of use, order, purchase or comparable conclusion of contract and may include the information required for service provision and possible billing as well as contact information in order to be able to hold any consultations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Storage of a universally unique identifier (UUID): The application stores a so-called universally unique identifier (UUID) for the purposes of analyzing the use and functionality of the application as well as storing users’ settings. This identifier is generated when this application is installed (but is not linked to the device, i.e. not a device identifier in this sense), remains stored between the start of the application and its updates and is deleted when users remove the application from their device.
  • Storage of a pseudonymous identifier: So that we can provide the application and ensure its functionality, we use a pseudonymous identifier. The identification is a mathematical value (i.e. no plain data such as names are used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated when this application is installed, remains stored between the start of the application and its updates and is deleted when users remove the application from the device.
  • Device permissions for access to functions and data: The use of our application or its functionalities may require user permissions for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these permissions must be granted by users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on users’ device and software. If users need clarification, they can contact us. We point out that the refusal or revocation of the respective permissions may affect the functionality of our application.
  • Access to the camera and stored recordings: As part of using our application, image and/or video recordings (which also include audio recordings) of users (and other persons captured in the recordings) are processed by accessing the camera functions or stored recordings. Access to the camera functions or stored recordings requires user authorization that can be revoked at any time. The processing of image and/or video recordings only serves to provide the respective functionality of our application, according to its description to users, or its typical and expected functionality.
  • Use of microphone functions: As part of using our application, the microphone functions and audio recordings captured with its help are processed. The use of microphone functions requires user authorization that can be revoked at any time. The use of microphone functions and audio data only serves to provide the respective functionality of our application, according to its description to users, or its typical and expected functionality.
  • Processing of location data: As part of using our application, the location data collected by the device used or otherwise entered by users is processed. The use of location data requires user authorization that can be revoked at any time. The use of location data only serves to provide the respective functionality of our application, according to its description to users, or its typical and expected functionality.
  • No location history and no movement profiles: The location data is only used at specific points and is not processed to create a location history or movement profile of the devices used or their users.

Obtaining Applications via App Stores

Our application is obtained via special online platforms operated by other service providers (so-called “app stores”). In this context, the privacy notices of the respective app stores apply in addition to our privacy notices. This applies in particular with regard to the procedures used on the platforms for reach measurement and interest-based marketing as well as any costs.

  • 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 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 information, identification numbers, persons involved).
  • Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing. Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

Registration, Login and User Account

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

As part of the use of our registration and login functions as well as the use of 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 users in protection against misuse and other unauthorized use. This data is generally 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 transactions 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. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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 concerning 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.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”. Deletion after termination.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • Registration with real names: Due to the nature of our community, we ask users to use our offering only using real names. This means the use of pseudonyms is not permitted; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • User profiles are not public: User profiles are publicly not visible and not accessible.
  • Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to legal permission, obligation or consent of users; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • No obligation to retain data: It is the responsibility of users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all data stored by the user during the contract period; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Single Sign-On Login

“Single sign-on” or “single sign-on login or authentication” refers to procedures that allow users to log in to our online offering using a user account with a single sign-on provider (e.g. a social network). The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already logged in to the single sign-on provider and confirm the single sign-on login via button.

The authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in under this user ID with the respective single sign-on provider and an ID that is not usable for us for other purposes (so-called “user handle”). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of the authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, different data may be involved, usually the email address and user name. The password entered as part of the single sign-on procedure with the single sign-on provider is neither visible to us nor is it stored by us.

Users are asked to note that their information stored with us can be automatically synchronized with their user account with the single sign-on provider, but this is not always possible or actually takes place. For example, if users’ email addresses change, they must manually change them in their user account with us.

We can use the single sign-on login, if agreed with users, as part of or before contract fulfillment, insofar as users have been asked to do so, process as part of consent and otherwise use it on the basis of the legitimate interests on our part and the interests of users in an effective and secure login system.

Should users decide not to use the link of their user account with the single sign-on provider for the single sign-on procedure anymore, they must remove this connection within their user account with the single sign-on provider. If users want to delete their data with us, they must terminate their registration with us.

  • 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); 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 information, identification numbers, persons involved).
  • 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; Login procedures. Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”. Deletion after termination.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Contact and Inquiry Management

When contacting us (e.g. by mail, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to respond to the contact inquiries 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. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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 information, 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; Direct marketing (e.g. by email or postal). Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further notes on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to respond to and process the respective request. This usually includes information such as name, contact information and, if applicable, further information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Brevo: Email sending and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider.

Communication via Messenger

We use messengers for the purpose of communication and therefore ask you to observe the following information on the functionality of messengers, on encryption, on the use of communication metadata and on your options to object.

You can also contact us via alternative channels, e.g. by telephone or email. Please use the contact options communicated to you or the contact options specified within our online offering.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted 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 messengers with encryption activated so that the encryption of message content is ensured.

However, we additionally point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us as well as technical information about the device used by communication partners and depending on the settings of their device also location information (so-called metadata) are 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, for example, on their own initiative, we use messengers in relation to our contractual partners and as part 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 for communication via messenger. Furthermore, we point out that we do not transmit the contact data communicated to us to the messengers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw consent given 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 communication partners, if no reference to a previous conversation is to be expected and the deletion is not opposed by legal retention obligations.

Reservation of reference to other communication channels: For your security, we ask for your understanding that for certain reasons we may not be able to answer inquiries via messenger. This concerns situations where, for example, contractual details must be treated particularly confidentially or a response via messenger does not meet formal requirements. In these cases, we recommend that you use more appropriate communication channels.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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 information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, make access or deletion requests directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular as regards the transmission of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://legal.linkedin.com/dpa), Data Privacy Framework (DPF)Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • LinkedIn messages: Message sending via the social network LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy. Basis for third country transfers: Data Privacy Framework (DPF), Data Privacy Framework (DPF).

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 “conference”). When selecting conference platforms and their services, we observe legal requirements.

Data processed by conference platforms: As part of participation in a conference, the conference platforms process the personal data of participants listed below. The scope of processing depends on which data is required as part of a specific conference (e.g. specification of access data or real names) and which optional information is provided by participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes data on the person (first name, surname), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of Internet access, information on participants’ end devices, their operating system, the browser and its technical and language settings, information on the content of 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). Content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, further 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, this will be communicated transparently to participants in advance and they will be asked for consent if necessary.

Data protection measures of participants: Please note the details of the processing of your data by the conference platforms in their privacy notices and select the optimal security and privacy settings for you within the framework of the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and using, where technically possible, the function to obscure the background). Links to 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 the use of the conference platforms or certain functions (e.g. consent to recording 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.). Furthermore, users’ 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. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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); Audio recordings; Log data (e.g. log files concerning logins or the retrieval of data or access times.). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners; Users (e.g. website visitors, users of online services). Depicted persons.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Direct marketing (e.g. by email or postal). Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • Brevo: Email sending and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider.

Cloud Services

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

In this context, personal data may be processed and stored on the providers’ servers insofar as they are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may in particular include master data and contact data of users, data on processes, contracts, other processes and their content. The providers of cloud services also process usage data and metadata, which they use for security purposes and service optimization.

If we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may 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. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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: Prospective customers; Communication partners. Business and contractual partners.
  • Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specifically mentioned when registering for the newsletter, they are decisive for the consent of users. For registration to our newsletter, it is normally sufficient to provide your email address. However, in order to be able to offer you a personalized service, we may ask you to provide your name for personal address in the newsletter or further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data will be limited to the purpose of a potential defense of claims. An individual deletion request 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 solely for this purpose in a blocklist.

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is based on our legitimate interests in an efficient and secure sending system.

Content:

Information about us, our services, actions 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 information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or postal).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Opt-out option: You can cancel the receipt of our newsletter at any time, i.e. withdraw 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 otherwise use one of the contact options stated above, preferably email, for this purpose.

Promotional Communication via Email, Mail, Fax or Telephone

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

Recipients have the right to withdraw consent at any time or to object to promotional communication at any time.

After withdrawal or objection, we store the data required to prove previous authorization to contact or send for up to three years after the end of the year of withdrawal or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense of claims. On the basis of the legitimate interest of permanently observing users’ withdrawal or objection, 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. textual or pictorial messages and contributions as well as the information concerning them, such as information on authorship or time of creation).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or postal); Marketing. Sales promotion.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Web Analysis, Monitoring and Optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate visitor flows 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 recognize, for example, at what time our online offering or its functions or content are most frequently used, or invite reuse. Likewise, we can understand which areas need 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, may be created for these purposes and information may be stored in a browser or in a 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 consented to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

Furthermore, 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 plain data of users (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of users, only the information stored in their profiles for the purposes of the respective procedures.

Notes 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, users’ 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 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 information, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creating user profiles).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”. Storage of cookies of up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users’ devices for a period of two years.).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • umami: Web analysis, reach measurement and analysis of user behavior; carried out pseudonymously and without the creation of user profiles; all user data is stored anonymously, i.e. without personal data and without the use of cookies or comparable persistent online identifiers; Service provider: Execution on servers and/or computers under own data protection responsibility; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://umami.is. Privacy policy: https://umami.is/privacy.

Presence on Social Networks (Social Media)

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

We point out that user data may be processed outside the area of the European Union. This may result in risks for users because, for example, the enforcement of user rights could be made more difficult.

Furthermore, users’ data within social networks is usually 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 usage profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of users. For this purpose, cookies are usually stored on users’ computers, in which the usage behavior and interests of users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by users (in particular if they are members of the respective platforms and logged in there).

For a detailed description of the respective forms of processing and opt-out options, we refer to the privacy statements and information provided by the operators of the respective networks.

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

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, make access or deletion requests directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular as regards the transmission of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://legal.linkedin.com/dpa), Data Privacy Framework (DPF)Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Management, Organization and Auxiliary Tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organization, administration, planning and provision of our services. When selecting third-party providers and their services, we observe legal requirements.

In this context, personal data may be processed and stored on third-party providers’ servers. This may involve various data that we process in accordance with this privacy policy. This data may in particular include master data and contact data of users, data on processes, contracts, other processes and their content.

If users are referred to third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the privacy notices of the respective third-party providers.

  • Types of data processed: Content data (e.g. textual or pictorial messages and contributions as well as the information concerning them, such as information on 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 information, identification numbers, persons involved).
  • Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures; Direct marketing (e.g. by email or postal). Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

  • Brevo: Email sending and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider.

Changes and Updates

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

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 please check the information before contacting us.

Definitions of Terms

This section provides you with an overview of the terminology used in this privacy policy. Insofar as the terminology is legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as employees, staff or in similar positions. An employment relationship is a legal relationship between an employer and an employee, which 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 includes various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee performs their work activity, and the termination, when the employment relationship ends, whether by termination, termination agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, vacation entitlements, health data and performance assessments.
  • Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, among others, 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 persons and services, facilities or systems by enabling clear assignment 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 may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not only limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among others, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. They may include information on file size, creation date, author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, time stamps and transmission channels. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used to track and verify 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 via which paths they navigate through an application. Usage data may also include frequency of use, time stamps of activities, IP addresses, device information and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. Furthermore, usage data plays a crucial role in recognizing 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data 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 different information concerning 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 contains information such as time stamps, 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, for security monitoring or to create performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate visitor flows to an online offering and may include the behavior or interests of visitors in certain information, such as content of websites. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Location data: Location data is created when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serves to indicate at which geographically determinable position on earth the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers practically any handling of data, whether it be the collection, the evaluation, the storage, the transmission or the deletion.
  • Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This data category is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties as well as the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. They serve as a legal basis for the relationship between the parties and are 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 of crucial importance for electronic 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 invoice information. Payment data may also include information on payment status, chargebacks, authorizations and fees.