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Privacy Policy

Preamble

With the following Privacy Policy, we would like to inform you which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context of 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 services”).

The terms used are not gender-specific.

Last updated: 8 May 2026

Table of Contents

Controller

Black Elephant Advisory GmbH
Okenstrasse 45
77652 Offenburg

Authorised representatives: Carina Heitmann, Hans Härting

Email address: contact@blackelephant.eu

Legal Notice: https://blackelephant.eu/impressum/

Overview of Processing Operations

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

Types of Data Processed

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

Special Categories of Data

  • Health data.

Categories of Data Subjects

  • Communication partners.
  • Users.
  • Persons depicted.

Purposes of Processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organisational procedures.
  • Target group formation.
  • Organisational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.
  • Public relations.

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection 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 (1) sentence 1 (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

National data protection regulations in Austria: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Austria. These include, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special provisions on the right of access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfers, as well as automated individual decision-making.

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

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

Security Measures

In accordance with the legal requirements, and 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, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

These 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, assurance of availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data and responses to threats to the data. In addition, 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 by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect users’ data transmitted via our online services against unauthorised 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 against unauthorised access. TLS, as the more advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and in encrypted form.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational 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 embedded in a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfers within the organisation: We may transfer personal data to other departments or units within our organisation or grant them access to it. Where the data is shared for administrative purposes, this is based on our legitimate business and commercial interests or takes place where it is necessary to fulfil our contract-related obligations or where the data subjects have given their consent or there is a legal permission.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which becomes apparent from the postal address of the respective provider or where the Privacy Policy expressly refers to data transfers to third countries), this always takes place in accordance with the legal requirements.

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

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

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

Disclosure of personal data abroad: In accordance with the Swiss DSG, we only disclose personal data abroad if adequate protection of the data subjects is ensured (Art. 16 Swiss DSG). Where the Federal Council has not determined that adequate protection exists (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative safeguards.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of Switzerland dated 15 September 2024. In addition, we have concluded standard data protection clauses with the respective providers which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and set out contractual obligations to protect your data.

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

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

For data transfers to other third countries, appropriate safeguards apply, including international treaties, specific guarantees, standard data protection clauses approved by the FDPIC, or binding corporate rules recognised in advance by the FDPIC or a competent data protection authority of another country.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or there are no further legal bases for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where statutory 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 the establishment, exercise or defence of legal claims or for the protection of 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 applies specifically to certain processing operations.

Where there are several specifications of the retention period or deletion deadlines for an item of data, the longest period always prevails. Data that is no longer retained for its originally intended purpose but on the basis of legal requirements or for other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the working instructions and other organisational documents required to understand them (§ 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 vouchers, such as invoices and expense receipts (§ 147 para. 1 nos. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
  • 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting vouchers, and cash register receipts (§ 147 para. 1 nos. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 nos. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years – Data required to take into account potential warranty and compensation claims or similar contractual claims and rights and to process related enquiries, based on previous business experience and customary industry practice, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Retention and deletion of data: The following general periods apply under Austrian law to the retention and archiving of personal data, insofar as this is necessary to fulfil legal obligations or to safeguard legitimate interests:

  • 7 years Personal data processed in connection with tax-relevant business documents is retained for a period of seven years in accordance with § 132 BAO and §§ 190–212 UGB. This includes, in particular, books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers, invoices, as well as commercial or business letters received and sent and other documents relevant to the levying of taxes. The period begins at the end of the calendar year for which the last entry was made and is extended, where applicable, for as long as the documents are relevant to pending tax proceedings.
  • 3 years Data required to assert, exercise or defend warranty, compensation or other contractual claims is stored for the duration of the applicable statutory limitation period. This is generally three years in accordance with § 1489 ABGB, unless longer statutory retention obligations exist.

Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices, as well as all necessary working instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (OR)).
  • 10 years – Data necessary to take into account potential claims for damages or similar contractual claims and rights, as well as for processing related enquiries, based on previous business experience and customary industry practice, is stored for the period of the statutory limitation period of ten years, unless a shorter period of five years applies, which is relevant in certain cases (Art. 127, 130 OR). Claims for rent, lease and capital interest as well as other periodic payments, claims arising from the supply of food, for board and lodging and for innkeepers’ debts, as well as claims arising from craftsmanship, retail sale of goods, medical care, professional work by lawyers, legal agents, procurators and notaries, and from the employment relationship of employees become time-barred after five years (Art. 128 OR).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, 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 in the context of which data is stored, the event triggering the period is the time at which the termination or other ending of the legal relationship takes effect.

Rights of Data Subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR, including profiling based on those provisions. Where 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, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain access to this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, in accordance with the legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to a supervisory authority: In accordance with the 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 of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss DSG:

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

  • Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary for you to assert your rights under this Act and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data that you have disclosed to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that personal data concerning you be erased or destroyed.

Provision of the Online Services 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, intensity and frequency of use, types of device 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 relating to logins or the retrieval of data or access times.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services 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 the information in the section “General Information on Data Retention and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web host”); Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).
  • Collection of access data and log files: Access to our online services is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, the date and time of access, the volumes of data transferred, notification of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used, on the one hand, 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 utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidential purposes is excluded from deletion until the respective incident has been finally clarified.
  • Email sending and hosting / transactional emails: The web hosting services we use also include the sending, receipt and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of emails between the sender and their receipt on our server.

    We use rapidmail to send so-called transactional emails. Transactional emails are all emails sent via this website. Examples include enquiries via the contact form, activation notifications when registering a user account, emails for resetting a password, booking confirmations or the sending of invoices. rapidmail is used, among other things, to organise and analyse the sending of emails. The data processed in this context is stored on rapidmail’s servers in Germany. For the purpose of analysis, the emails sent with rapidmail contain a so-called tracking pixel, which connects to rapidmail’s servers when the email is opened. In this way, it can be determined whether an email has been opened. Furthermore, with the help of rapidmail, we can determine whether and which links in the message are clicked. Optionally, links in the email may be set up as tracking links with which your clicks can be counted. This serves to improve traceability in the event of delivery problems, debugging and the continuous improvement of our services; Service provider: Positive Group Deutschland GmbH, Ingeborg-Krummer-Schroth-Straße 18a, 79106 Freiburg im Breisgau, Germany; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.rapidmail.de/dsgvo-konformes-email-marketing. Privacy Policy: https://www.rapidmail.de/datenschutz.
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

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 various purposes, such as the functionality, security and convenience of online services and the analysis of visitor flows. We use cookies in accordance with the statutory provisions. For this purpose, we obtain users’ consent in advance where necessary. Where consent is not required, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about its scope and which cookies are used.

Information on legal bases under data protection law: Whether we process personal data by means of cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, 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 service and closed their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device has been closed. For example, the login status can be saved and preferred content displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period may be up to two years.

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

  • 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 (1) sentence 1 (f) GDPR). Consent (Art. 6 (1) sentence 1 (a) GDPR).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution through which users’ consent to the use of cookies or to the procedures and providers named within the consent management solution is obtained. This procedure serves to obtain, log, manage and withdraw consents, in particular with regard to the use of cookies and comparable technologies used to store, read and process information on users’ devices. As part of this procedure, users’ consents to the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure, are obtained. Users also have the option of managing and withdrawing their consents. The declarations of consent are stored in order to avoid having to ask again and to be able to provide proof of consent in accordance with the legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information is available on the providers of consent management services, the following general information applies: consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, system and device used; Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR).
  • BorlabsCookie: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of information on data protection and cookies, enabling users to withdraw or adjust their consents; Service provider: Executed on servers and/or computers under our own responsibility under data protection law; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, the language as well as the types of consent and the time at which they were given are stored on the server side and in the cookie on the user’s device.

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy notice.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and posts as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, types of device 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 and legitimate interests: Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Retention and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

Contact and Enquiry Management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the information provided by the enquiring persons is processed to the extent necessary to respond to the contact enquiries and any requested measures.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and posts as well as information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; Organisational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Retention and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data transmitted to us in order to respond to and deal with the respective matter. This usually includes details such as name, contact information and, where applicable, further information that is communicated to us and is necessary for appropriate handling. We use this data exclusively for the stated purpose of establishing contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 (b) GDPR), Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

Video Conferences, Online Meetings, Webinars and Screen Sharing

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

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the participants’ personal data listed below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g. provision of access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal details (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet connection, information on the participants’ devices, their operating system, the browser and its technical and language settings, information on the content-related communication processes, i.e. entries in chats as well as audio and video data, and the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users 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) or video or audio recordings are logged, participants will be informed of this transparently in advance and, where necessary, asked for their consent.

Data protection measures for participants: For details of the processing of your data by the conference platforms, please refer to their privacy notices and select the security and data protection settings that are optimal for you in the settings of the conference platforms. Furthermore, for the duration of a video conference, please ensure data and privacy protection in the background of your recording (e.g. by notifying housemates, locking doors and using, where technically possible, the function for blurring the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.

Information on legal bases: Where, 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 the recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of follow-up processing of discussion results, etc.). Otherwise, users’ data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and posts as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, types of device 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 relating to logins or the retrieval of data or access times.).
  • Data subjects: Communication partners; Users (e.g. website visitors, users of online services). Persons depicted.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Communication. Office and organisational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Retention and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

Further information on processing operations, procedures and services:

Newsletters and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipients or on the basis of a legal basis. If the contents of the newsletter are specified when registering for it, these contents are decisive for the users’ consent. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to be able to offer you a personalised service, we may ask for your name so that we can address you personally in the newsletter, or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove that consent was previously given. The processing of this data is restricted to the purpose of a potential defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called “blocklist”).

The registration procedure is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Master 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). Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, types of device and operating systems used, interactions with content and functions).
  • Special categories of personal data: Health data.
  • Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post). Provision of contractual services and fulfilment of contractual obligations.
  • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR). Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).
  • Opt-out: You can cancel 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 at the end of each newsletter, or you can use one of the contact options given above, preferably email, for this purpose.

Further information on processing operations, procedures and services:

  • Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information collected is assigned to the individual newsletter recipients and stored in their profiles until deletion. On this basis, user profiles are created in which usage behaviour and user characteristics are stored. The measurement of open and click rates, the storage of the measurement results in the users’ profiles and their further processing take place on the basis of the users’ consent. Unfortunately, it is not possible to withdraw consent to the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, the stored profile information will be deleted; Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR).
  • Prerequisite for the use of free services: Consent to the sending of mailings may be made a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
  • Rapidmail: Sending of emails to recipient lists (lists of email addresses), management and maintenance of these lists, creation and design of email templates, analysis of dispatch and open rates (how often an email was opened or clicked); Service provider: Positive Group Deutschland GmbH, Ingeborg-Krummer-Schroth-Straße 18a, 79106 Freiburg im Breisgau, Germany; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.rapidmail.de; Privacy Policy: https://www.rapidmail.de/datenschutz. Data processing agreement: https://www.rapidmail.de/hilfe/datenschutzvertrag-nach-eu-dsgvo-abschliessen.

Web Analytics, Monitoring and Optimisation

Web analytics (also referred to as “reach measurement”) serves to evaluate the flows of visitors to our online services and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online services or their functions or content are used most frequently, or invite users to return. It also enables us to understand which areas require optimisation.

In addition to web analytics, we may also use testing procedures, for example to test and optimise different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data combined into a usage process, may be created for these purposes and information may be stored in a browser or on a device and then read out. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data vis-à-vis us or the providers of the services we use, the processing of location data is also possible.

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

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the 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 draw your attention to the information on the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, types of device 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 and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Retention and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR). Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

Further information on processing operations, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyse the use of our online services on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It serves to assign analysis information to a device in order to recognise which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. The time of use and its duration are also stored, as well as the sources of the users who refer to our online services and technical aspects of their devices and browsers.
    In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocation data before being deleted immediately. It is not logged, is not accessible and is not used for any further purposes. When Google Analytics collects measurement data, all IP lookups are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard contractual clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard contractual clauses ( https://business.safety.google/adsprocessorterms); Opt-out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and of the data processed).
  • Google as recipient of consent: The consent given by users in a consent dialogue (also known as “cookie opt-in/consent”, “cookie banner”, etc.) serves several purposes. On the one hand, it serves to fulfil our obligation to obtain consent to the storage of information on, and the reading of information from, users’ devices in accordance with the ePrivacy requirements. On the other hand, it covers the processing of users’ personal data in accordance with the requirements of data protection law. In addition, this consent also applies vis-à-vis Google, as the company is obliged under the requirements of the Digital Markets Act (DMA) to obtain valid consent for personalised services. For this reason, we share the status of the consents given or refused by users with Google. Our consent management software informs Google whether or not consent has been given. The aim is to ensure that users’ decisions are taken into account when using Google measurement services – in particular in the context of reach measurement, conversion tracking and personalised advertising (e.g. Google Analytics, Google Ads and comparable services) – and when integrating further functions and external services. The processing takes place dynamically and depending on the respective user selection, including any withdrawal of consent; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de. Privacy Policy: https://policies.google.com/privacy.

Presences on Social Networks (Social Media)

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

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

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

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

In the case of requests for information and the assertion of data subjects’ rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you may contact us.

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

Further information on processing operations, procedures and services:

  • Instagram: Social network that enables the sharing of photos and videos, commenting on and liking posts, sending messages and subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the social network Facebook – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transfer of data of visitors to our Facebook page (“fan page”). This includes, in particular, information on user behaviour (e.g. content viewed or interacted with, actions taken) as well as device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical analyses via the “Page Insights” service, which provide information on how people interact with our page and its content. The basis for this is an agreement with Facebook (“Information about Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subjects’ rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore address requests for access or erasure directly to Facebook. The rights of users (in particular access, erasure, objection, complaint to a supervisory authority) remain unaffected by this. The joint responsibility is limited exclusively to the collection of the data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited alone is responsible for further processing, including any transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data that is used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and 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, seniority, company size and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy notice: https://www.linkedin.com/legal/privacy-policy.
    We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send requests for access or erasure directly to LinkedIn). The rights of users (in particular the right of access, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of the data and its transfer to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard contractual clauses (https://legal.linkedin.com/dpa), Switzerland – Data Privacy Framework (DPF), Standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Opt-out: https://myadcenter.google.com/personalizationoff.
  • Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.xing.com/. Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plug-ins and Embedded Functions and Content

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

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

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the data processing is that permission. 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 draw your attention to the information on the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, types of device 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 and legitimate interests: Provision of our online services and user-friendliness; Reach measurement (e.g. access statistics, recognition of returning visitors); Tracking (e.g. interest-/behaviour-based profiling, use of cookies); Target group formation. Marketing.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Retention and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR). Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).

Further information on processing operations, procedures and services:

  • Google Fonts (provided on our own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server; no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).
  • YouTube videos: Videos stored on YouTube are embedded within our online services. These YouTube videos are integrated via a special domain using the “youtube-nocookie” component in the so-called “privacy-enhanced mode”. In “privacy-enhanced mode”, until the video is started, only information required by YouTube for the output, control and optimisation of the video display, including your IP address and information about the browser and your device, may be stored on your device in cookies or by means of comparable procedures. As soon as you play the videos, additional information may be processed by YouTube to analyse usage behaviour, for storage in the user profile and for the personalisation of content and advertisements. The storage period for the cookies may be up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) sentence 1 (a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-privacy-enhanced-mode%2Cerweiterten-datenschutzmodus-aktivieren.

Changes and Updates

We ask you to inform yourself regularly about the content of our Privacy Policy. We amend the Privacy Policy as soon as changes in 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.

Where we provide addresses and contact information of companies and organisations in this Privacy Policy, please note that the addresses may change over time, and please check the information before contacting them.

Definitions of Terms

This section provides you with an overview of the terms used in this Privacy Policy. Insofar as the terms are defined by law, their statutory definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Master data: Master data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unambiguous assignment and communication.
  • Content data: Content data comprises 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 limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates
  • Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, 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 in which data is processed, transmitted and managed. Metadata, also known as data about data, comprises information that describes the context, origin and structure of other data. It may include details of file size, creation date, the 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, timestamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, as well as audit logs used to track and review operations.
  • Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data comprises a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and the paths by which they navigate through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and possible 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 kind of automated processing of personal data that consists of using such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently 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 timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to generate performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the flows of visitors to an online service and may include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online services can, for example, recognise 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 their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.
  • Tracking: “Tracking” refers to the ability to trace the behaviour of users across several online services. As a rule, behavioural and interest information relating to the online services used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • 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 on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Target group formation: Target group formation (“custom audiences”) refers to the determination of target groups for advertising purposes, e.g. the display of advertisements. For example, on the basis of a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or for the online shop in which they viewed the products. “Lookalike audiences” (or similar target groups), in turn, refers to the display of content deemed suitable to users whose profiles or interests presumably correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.