Privacy Policy
Information according to EU GDPR & BDSG
It's great that you're here
We, the team at TRINITY electric vehicles GmbH, are delighted by your visit to our website and your interest in our company, services, and products, including data protection in accordance with the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). Protecting your data is very important to us. You can generally use our website without providing any personal data. However, if you wish to use one of our services, processing personal data is necessary. Therefore, we are providing you with a detailed privacy policy and information about the measures we have taken to protect your data when using our website and services.
All our business processes are adapted to the latest technological standards through technical and organizational measures to ensure that your personal data is protected at all times. This includes regular implementation, testing, and adaptation of new technologies in line with technological advancements. Below, we inform you about the purposes for which your data is collected and processed, as well as how you can exercise your rights.
Our privacy policy is based on the terminology used by the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). You can download the full privacy policy as a PDF here.
Download privacy policy as PDF
If you would like to print the privacy policy, you can download it as a PDF using the button labeled "Privacy Policy.pdf" below. Please note that you may need Adobe Acrobat Reader or other software that can safely open PDF documents to view it.
Detailed explanation
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 services").
The terms used are not gender-specific.
As of April 11, 2025
Table of Contents
- preamble
- Responsible
- Overview of processing activities
- Relevant legal bases
- Security measures
- Transfer of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Business processes and procedures
- Use of online platforms for offering and sales purposes
- Suppliers and services used in the course of business activities
- Payment methods
- Credit check
- Provision of the online service and web hosting
- Use of cookies
- Blogs and publication media
- Contact and inquiry management
- Communication via Messenger
- Artificial Intelligence (AI)
- Video conferences, online meetings, webinars and screen sharing
- Cloud services
- Newsletters and electronic notifications
- Advertising communication via email, post, fax or telephone
- Web analytics, monitoring and optimization
- Online marketing
- Offer of an affiliate program
- Customer reviews and rating procedures
- Presences in social networks (social media)
- Management, organization and support tools
- Processing of data in the context of employment relationships
- Application process
- Changes and updates
Responsible
Reinhold Richert,
Im Felde 6,
38536 Meinersen
Authorized representatives: Managing Director
E-mail address:
Legal notice: https://www.trinity-ev.de/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 details.
- Contact details.
- Content data.
- Contract details.
- Usage data.
- Metadata, communication data and process data.
- Social data.
- Applicant data.
- Image and/or video recordings.
- Sound recordings.
- Event data (Facebook).
- Log data.
- Performance and behavioral data.
- Working time data.
- Creditworthiness data.
- Salary data.
Special categories of data
- Health data.
- Religious or philosophical beliefs.
- Trade union membership.
Categories of affected persons
- Recipient of services and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Applicants.
- Business and contractual partners.
- People pictured.
- Third parties.
- Customers.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Range measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Target group definition.
- Affiliate tracking.
- Organizational and administrative procedures.
- Application process.
- Feedback.
- Marketing.
- Profiles containing user-related information.
- Provision of our online services and user-friendliness.
- Assessment of creditworthiness and credit rating.
- Establishment and implementation of employment relationships.
- Information technology infrastructure.
- Financial and payment management.
- Public relations.
- Sales promotion.
- Business processes and business management procedures.
- Artificial Intelligence (AI).
Automated decisions in individual cases
- Credit report.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Furthermore, should more specific legal bases apply 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 his or her personal data for one or more specific purposes.
- Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or 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) - The 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.
- Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g., health data such as severe disability or ethnic origin) are requested from applicants during the application process so that the controller or the data subject can exercise their rights and fulfill their obligations under employment law and social security and social protection law, their processing is carried out in accordance with Art. 9 para. 2 lit. b GDPR, in the case of the protection of the vital interests of the applicants or other persons in accordance with Art. 9 para. 2 lit. c GDPR, or for purposes of preventive or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnosis, the provision of health or social care or treatment, or for the management of health or social care systems and services in accordance with Art. 9 para. 2 lit. h. GDPR. In the case of the disclosure of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.
- Processing of special categories of personal data relating to health, occupation and social security (Art. 9 para. 2 lit. h) GDPR) - The processing is necessary for the purposes of preventive or occupational health care, for the assessment of the work capacity of the employee, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care schemes and services on the basis of Union or Member State law or on the basis of a contract with a health professional.
National data protection regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding 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 data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.
Notice regarding the applicability of the GDPR and Swiss Federal Act on Data Protection (FADP): This privacy notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). Therefore, please note that, due to its broader geographical scope and clarity, the terms used here are those of the GDPR. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "special categories of personal data" used in the Swiss FADP, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are employed. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP when applicable.
Security 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 varying likelihood and severity of the threat to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.
Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we rely on 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), thus 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 with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transfer of personal data
As part of our processing of personal data, it may be necessary to transfer or disclose this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure its protection.
DHL: Shipping service provider: Transmission of postal data.
DPD: Shipping service provider: Transmission of postal data.
Tax advisor: accounting data, customer data.
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 can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the data transfer to third countries), this is always done in accordance with the legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This dual safeguard ensures comprehensive protection of your data: The Data Protection Framework (DPF) forms the primary layer of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.
For each service provider, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about the DPF and a list of certified companies can be found on the U.S. Department of Commerce website 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 legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission's information service: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General information on data storage and deletion
We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if 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 for the protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.
If there are multiple specifications regarding the retention period or deletion deadlines for a given date, the longest period always applies.
If a time limit does not expressly begin on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.
Data that is no longer retained for the originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.
Further information on processing procedures, methods and services:
- Data storage and deletion: The following general retention periods apply under German law for storage and archiving:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organizational documents 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, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 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 standard industry practices, will be 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 a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are 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 of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
- Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access 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 your personal data or the correction of inaccurate personal data concerning you.
- Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
- Right to data portability: You have the right to receive the personal 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.
- Right to lodge a complaint with a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes 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"), within the framework of contractual and similar legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.
We use this data to fulfill our contractual obligations. These include, in particular, the obligation to provide the agreed services, any update obligations, and remedying warranty claims and other service disruptions. Furthermore, we use the data to protect our rights and for the administrative tasks associated with these obligations, as well as for company organization. We also process the data based on our legitimate interests in both proper and efficient business management and security measures to protect our contractual partners and our business operations from misuse, compromise of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, such as for marketing purposes, within the scope of this privacy policy.
We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colors) or symbols (e.g. stars or similar), or personally.
We delete data after the expiry of statutory warranty periods and similar 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 archiving reasons (for example, for tax purposes, usually ten years). Data disclosed to us by the contractual partner within the scope of a contract is deleted according to the specifications and generally after the contract has ended.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Service recipients and clients; interested parties; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures; business processes and management procedures.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Contract performance 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 information on processing procedures, methods and services:
- Online shop, order forms, e-commerce, and delivery: We process our customers' data to enable them to select, purchase, and order their chosen products, goods, and related services, as well as to facilitate payment and delivery or fulfillment. If necessary for order fulfillment, we use service providers, in particular postal, freight forwarding, and shipping companies, to carry out delivery or fulfillment for our customers. We utilize the services of banks and payment service providers for processing payments. The required information is marked as such during the ordering or similar purchase process and includes the information needed for delivery, provision, and invoicing, as well as contact information to allow for any necessary follow-up. Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Automotive industry and vehicle technology: We process the data of our customers and clients to enable them to develop, produce, and provide vehicles and vehicle technologies, as well as related services. The required information includes data necessary for project implementation and invoicing, as well as contact information for necessary coordination. Insofar as we gain access to information from end customers, employees, or other individuals, we process this information 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), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Craft services: We process the data of our customers and clients (hereinafter referred to collectively as "customers") to enable them to select, purchase, or commission the chosen services or works, as well as related activities, and to facilitate payment, delivery, execution, or performance.
The required information is marked as such during the order, purchase, or similar contract conclusion process and includes the information necessary for delivery and invoicing, as well as contact information to allow for any necessary follow-up. Legal basis: Contract performance 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 specific cases, clients, patients, or business partners, as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.
The collected data serves to fulfill contractual obligations and to design efficient operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies, and the assurance of internal accounting and financial processes. Additionally, the data supports the protection of the data controller's rights and facilitates administrative tasks and the organization of the company.
Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. Data will be deleted after the expiry of statutory retention periods or when the purpose of processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Log data (e.g., log files concerning logins or data retrieval or access times).
- Affected persons: Service recipients and clients; prospective clients; communication partners; business and contractual partners; customers; third parties; users (e.g., website visitors, users of online services). Employees (e.g., staff, applicants, temporary workers, and other employees).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and management procedures; security measures; provision of our online services and user-friendliness; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Contract performance 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 information on processing procedures, methods and services:
- Contact management and maintenance: Procedures required for the organization, maintenance, and security of contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adapting contact strategies); Legal bases: Contract performance 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 service (e.g., customer or user account, hereinafter referred to as "customer account"). If registration of a customer account is required, customers will be notified accordingly, as well as informed about the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and use of the customer account, we store the customers' IP addresses along with the access times in order to verify the registration and prevent any misuse of the customer account. If the customer account is terminated, the customer account data will be deleted after the termination date, unless it is retained for purposes other than providing the customer account or must be retained for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the customer's responsibility to back up their data when terminating their customer account. Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- General payment transactions: Procedures necessary for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creating and verifying transfers, processing direct debits, checking bank statements, monitoring incoming and outgoing payments, chargeback management, account reconciliation, cash management); Legal bases: Contract performance 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: Processes necessary for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable (e.g., creating and verifying incoming and outgoing invoices, monitoring and managing open items, processing payments, handling dunning procedures, reconciling accounts receivable and payable, accounts payable and accounts receivable); Legal bases: Contract performance 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: Processes necessary for recording, managing, and controlling financially relevant business transactions, as well as for calculating, reporting, and paying taxes (e.g., posting and booking business transactions, preparing quarterly and annual financial statements, processing payments, handling dunning procedures, reconciling accounts, providing tax advice, preparing and filing tax returns, and managing tax matters); Legal bases: Contract performance 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).
- Purchasing: Processes necessary for the procurement of goods, raw materials, or services (e.g., supplier selection and evaluation, price negotiations, order placement and monitoring, verification and control of deliveries, invoice verification, order management, inventory management, creation and maintenance of purchasing policies); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Sales: Processes necessary for the planning, implementation, and control of measures for marketing and selling products or services (e.g., customer acquisition, offer preparation and follow-up, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, sales channel management). Legal basis: Contract performance 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: Processes necessary for marketing, advertising and sales promotion (e.g., market analysis and target group definition, 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 basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Economic analyses and market research: To fulfill business purposes and to identify market trends and the needs of contractual partners and users, the available data relating to business transactions, contracts, inquiries, etc., are analyzed. The group of data subjects may include contractual partners, prospective customers, customers, visitors, and users of the controller's online services. The analyses are carried out for the purposes of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, profiles of registered users, including their information on services used, are taken into account. The analyses are solely for the controller's use and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized, values. Furthermore, user privacy is respected; the data is pseudonymized for analysis purposes wherever possible and, where feasible, processed anonymously (e.g., as aggregated data). Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Public relations: Procedures required within the framework of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: 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 policies of the respective platforms apply in addition to our privacy policy. This applies in particular to the processing of payments and the methods used on the platforms for audience measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Service recipients and clients. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing. Business processes and operational procedures.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Contract performance 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 information on processing procedures, methods and services:
- eBay: Online marketplace for e-commerce; Service provider: eBay Marketplaces GmbH, Helvetiastrasse 15/17, 3005 Bern, Switzerland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ebay.de/ ; Privacy policy: https://www.ebay.de/help/policies/member-behavior-policies/datenschutzerklrung?id=4260 . Data processing agreement: Provided by the service provider.
- Kleinanzeigen.de: Online marketplace for e-commerce; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Data processing agreement: Provided by the service provider; Service provider: kleinanzeigen.de GmbH,
Dernburgstraße 50,
14057 Berlin,
Germany; Website: https://www.kleinanzeigen.de/ . Privacy policy: https://themen.kleinanzeigen.de/datenschutzerklaerung .
Suppliers and services used in the course of business activities
In the course of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter referred to as "Services") in compliance with legal requirements. Their use is based on our legitimate interest in the proper, lawful, and efficient management of our business operations and internal organization.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as related information such as authorship or date of creation); Contract data (e.g., subject matter of the contract, term, customer category).
- Affected persons: Service recipients and clients; prospective clients; business and contractual partners. Employees (e.g., salaried employees, applicants, temporary workers and other staff).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures. Business processes and management procedures.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- DATEV: Software for accounting, communication with tax advisors and authorities, and document storage; Service provider: DATEV eG, Paumgartnerstr. 6-14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/ ; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/ . Data processing agreement: Provided by the service provider.
- JTL WaWi: Inventory management system, customer data, order information; Service provider: JTL-Software-GmbH
Rheinstr. 7
41836 Hückelhoven
Tel.: +49 2433 8056801
E-mail:This email address is protected against spambots! JavaScript must be enabled to view it. ; Website: https://www.jtl-software.de/. Privacy Policy: https://www.jtl-software.de/datenschutz. - Greyhound ticketing system: Captures customer data in an email management tool for the efficient processing of customer inquiries and orders via email, including corresponding histories and assignments; Service provider: GREYHOUND Software GmbH,
Segelfliegerweg 53,
49324 Melle,
Germany; Website: https://greyhound-software.com/ . Privacy policy: https://greyhound-software.com/datenschutz . - Simple-Fax: Send and receive faxes via an online fax service provider; Service provider: simple Communication GmbH,
Salzdahlumer Str. 196,
38126 Braunschweig, Germany; Website: https://simple-fax.de/ . Privacy policy: https://simple-fax.de/datenschutzerklaerung .
Payment methods
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use additional service providers besides banks and credit institutions for this purpose (collectively "payment service providers").
The data processed by payment service providers includes master data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount, and recipient-related information. This information is necessary to process the transactions. However, the entered data is processed and stored only by the payment service providers. This means we do not receive any account or credit card information, but only confirmation or rejection of the payment. The payment service providers may transmit the data to credit reference agencies for identity and creditworthiness verification. Please refer to the terms and conditions and privacy policies of the payment service providers for further information.
The terms and conditions and privacy policies of the respective payment service providers apply to payment transactions and can be accessed on their respective websites or transaction applications. We also refer you to these for further information and to exercise your rights of withdrawal, access, and other data subject rights.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Service recipients and clients; business and contractual partners; interested parties.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and operational procedures.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Contract performance 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 information on processing procedures, methods and services:
- PayPal: Payment services (technical integration of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de . Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
Credit check
If we provide services in advance or assume comparable economic risks (e.g., when ordering on account), we reserve the right, in order to protect our legitimate interests, to obtain identity and credit information for the purpose of assessing credit risk based on mathematical-statistical procedures from specialized service providers (credit agencies).
We process the information we receive from credit agencies regarding the statistical probability of payment default as part of a sound discretionary decision on the establishment, execution, and termination of the contractual relationship. We reserve the right to refuse payment by invoice or any other advance payment in the event of a negative credit check result.
The decision as to whether we will provide advance payment is made in accordance with legal requirements solely on the basis of an automated decision in each individual case, which our software makes based on information from the credit agency.
If we obtain explicit consent from our contractual partners, the legal basis for the credit check and the transfer of customer data to credit agencies is that consent. If no consent is obtained, the credit check is carried out on the basis of our legitimate interests in ensuring the security of our payment claims.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Creditworthiness data (e.g., credit score received, estimated probability of default, risk classification based thereon, historical payment behavior). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons: Service recipients and clients; interested parties; business and contractual partners.
- Purposes of processing: Assessment of creditworthiness and solvency.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Automated decisions in individual cases: Credit report (decision based on a credit check).
Further information on processing procedures, methods and services:
- Credit check as a prerequisite for providing payment options: The provision of payment options, e.g., payment by invoice or installment payment, may be dependent on the result of the customer's credit check. In this case, we ask customers to consent to the credit check procedure; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- CRIF AG (Switzerland): Credit reporting agency; Service provider: CRIF AG, Hagenholzstrasse 81, 8050 Zurich, Switzerland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.crif.ch/ . Privacy policy: https://www.crif.ch/datenschutz/ .
- CRIF GmbH (Austria): Credit reporting agency; Service provider: CRIF GmbH, Diefenbachgasse 35 A, 1150 Vienna, Austria; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.crif.at/ . Privacy policy: https://www.crif.at/datenschutzerklaerung-website .
- SCHUFA: Credit reporting agency; Service provider: SCHUFA Holding AG, Private Customer Service Center, P.O. Box 10 34 41, 50474 Cologne, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.schufa.de/ . Privacy policy: https://www.schufa.de/datenschutz/ .
- Association of Creditreform Clubs eV: Credit reporting agency; Service provider: Association of Creditreform Clubs eV, Hellersbergstraße 12, D-41460 Neuss, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.creditreform.de/ . Privacy policy: https://www.creditreform.de/datenschutz .
- Aifinyo: Transfer of customer data to payment service providers for financing purposes. Aifinyo conducts a credit check using this customer data; service provider: aifinyo AG,
Friedrichstraße 94,
10117 Berlin; website: https://www.aifinyo.de/ . Privacy policy: https://www.aifinyo.de/datenschutz/ .
Provision of the online service and web hosting
We process user data to provide 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 time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved); log data (e.g., log files concerning logins or data retrieval or access times); content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures. Provision of contractual services and fulfillment of contractual obligations.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web host") or otherwise obtain; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 contain the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: 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 that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.
- Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. Please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). We therefore cannot assume any responsibility for the transmission of emails between the sender and their receipt on our server. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- 1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website : https://www.ionos.de ; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy ; Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/
Use of cookies
The term "cookies" refers to functions that store information on and read it from users' devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. Where necessary, we obtain users' consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about the scope of this consent and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage duration: The following types of cookies are distinguished with regard to storage duration:
- Temporary cookies (also known as 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).
- Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved and preferred content to be displayed directly when the user revisits a website. User data collected via cookies can also be used for audience measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these cookies are persistent and can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to processing in accordance with legal requirements, including via their browser's privacy settings.
- Types of data processed: Metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online service and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing procedures, methods and services:
- Processing of cookie data based on consent: We use a consent management solution to obtain user consent for the use of cookies or for the processes and providers mentioned within the consent management solution. This process serves to obtain, log, manage, and revoke consent, particularly regarding the use of cookies and similar technologies that are used to store, read, and process information on users' devices. Within this process, user consent for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management process, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored to avoid repeated requests and to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to assign the consent to a specific user or their device. Unless specific information is available regarding the providers of consent management services, the following general guidelines apply: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details of the scope of consent (e.g., categories of cookies and/or service providers concerned), and information about the browser, system, and device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Cookie opt-out: In the footer of our website you will find a link through which you can change your cookie settings and revoke any consent you have given.
Blogs and publication media
We use blogs or similar online communication and publication tools (hereinafter referred to as "publication medium"). Reader data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. For further information regarding the processing of visitor data to our publication medium, please refer to the privacy policy.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact and inquiry management
When you contact us (e.g. by mail, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to answer the contact requests and any requested measures.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Communication partners.
- Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing procedures, methods and services:
- Contact form: When you contact us via our contact form, email, or other communication channels, we process the personal data you provide to answer and process your request. This typically includes information such as your name, contact details, and any other information you provide that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; legal basis: 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).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to take note of the following information regarding the functionality of the messengers, encryption, the use of communication metadata and your options to object.
You can also contact us via alternative methods, such as by phone or email. Please use the contact options provided to you or those listed within our online services.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we would like to point out that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages is not visible, not even to the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure the encryption of message content.
However, we would also like to point out to our communication partners that while the messenger providers cannot see the content, they can find out that and when communication partners communicate with us, and that technical information about the communication partners' devices and, depending on their device settings, location information (so-called metadata) are processed.
Legal basis for communication: If we request permission from our communication partners before communicating with them via messenger, the legal basis for processing their data is their consent. Otherwise, if we do not request consent and they contact us on their own initiative, for example, we use messengers in our dealings with our contractual partners and during contract negotiations as a contractual measure. In the case of other interested parties and communication partners, we use messengers based on our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messenger. Furthermore, we would like to point out that we will not transmit the contact details you provide to the messenger service for the first time without your consent.
Revocation, objection, and deletion: You can revoke your consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion policy (i.e., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any inquiries from the communication partners, provided that no reference to a previous conversation is to be expected and that no legal retention obligations prevent deletion.
Subject to the possibility of using other communication channels: To ensure your security, we ask for your understanding that we may not be able to respond to inquiries via messenger for certain reasons. This applies to situations where, for example, contract details must be treated as particularly confidential or where a response via messenger does not meet formal requirements. In these cases, we recommend that you use more suitable communication channels.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as information relating to them, such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Communication partners.
- Purpose of processing: Communication.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: 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 information on processing procedures, methods and services:
- Instagram: Messaging via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com . Privacy policy: https://privacycenter.instagram.com/policy/ .
- Facebook Messenger: Send and receive text messages, make voice and video calls, create group chats, share files and media, transmit location information, synchronize contacts, encrypt messages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com ; Privacy policy: https://www.facebook.com/privacy/policy/ ; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing . Basis for third-country transfers: DPF ), Standard Contractual Clauses ( https://www.facebook.com/legal/EU_data_transfer_addendum ).
Artificial Intelligence (AI)
We use artificial intelligence (AI), which involves processing personal data. The specific purposes and our interest in using AI are described below. In accordance with the definition of an "AI system" as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adapting after its implementation, and capable of generating results such as predictions, content, recommendations, or decisions from the inputs received, which can influence physical or virtual environments.
Our AI systems are deployed in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection regulations. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimization, integrity, and confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can be either the consent of the data subjects or a legal authorization.
When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable regulations. We also adhere to our own obligations when using or operating the AI services we procure. The processing of personal data by us and the AI providers is based solely on consent or legal authorization. We place particular emphasis on transparency, fairness, and maintaining human oversight of AI-supported decision-making processes.
To protect the processed data, we implement appropriate and robust technical and organizational measures. These ensure the integrity and confidentiality of the processed data and minimize potential risks. Through regular audits of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
- Types of data processed: Content data (e.g., textual or image-based messages and posts, as well as related information such as authorship details or creation date). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
- Affected persons: Users (e.g., website visitors, users of online services). Third parties.
- Purposes of processing: Artificial Intelligence (AI).
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information, and make predictions ("AI," i.e., "Artificial Intelligence," to be understood in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openai.com/product ; Privacy policy: https://openai.com/de/policies/eu-privacy-policy ; Opt-out option: https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform .
- DeepL: Translation of texts into various languages and provision of synonyms and context examples. Support with proofreading and improving texts in various languages; Service provider: DeepL SE, Maarweg 165, 50825 Cologne, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.deepl.com ; Privacy policy: https://www.deepl.com/de/privacy . Data processing agreement: Provided by the service provider.
Video conferences, online meetings, webinars and screen sharing
We use third-party platforms and applications (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as "conferences"). We comply with legal requirements when selecting conference platforms and their services.
Data processed by conference platforms: When participating in a conference, the conference platforms process the following personal data of the participants. The scope of processing depends, firstly, on which data is required for a specific conference (e.g., providing access data or full names) and, secondly, on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the conference platforms may also process participant data for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet connection, information on the participants' devices, their operating system, browser and its technical and language settings, information on the content of the communication processes, i.e., entries in chats as well as audio and video data, and the use of other available functions (e.g., surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users on the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recording: If text entries, participation results (e.g., from surveys) and video or audio recordings are logged, participants will be informed transparently in advance and asked for their consent if necessary.
Participant data protection measures: Please refer to the data protection notices of the conference platforms for details on how your data is processed and select the optimal security and data protection settings for yourself within the platform's settings. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of the video conference (e.g., by informing roommates, locking doors, and using the background blur function where technically possible). Links to the conference rooms and access data must not be shared with unauthorized third parties.
Legal basis: If, in addition to the conference platforms, we also process user data and request users' consent to the use of the conference platforms or specific functions (e.g., consent to conference recordings), the legal basis for the processing is this consent. Furthermore, our processing may be necessary for the performance of our contractual obligations (e.g., in participant lists, in the case of processing meeting results, etc.). Otherwise, user data is processed based on our legitimate interests in efficient and secure communication with our communication partners.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, 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 data retrieval or access times).
- Affected persons: 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.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Cisco WebEx: Conference and communication software; Service provider: Webex Communications Deutschland GmbH, Hansaallee 249, c/o Cisco Systems GmbH, 40549 Düsseldorf, Parent company: Cisco Systems, Inc., 170 West Tasman Dr., San Jose, CA 95134, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.webex.com/de ; Privacy policy: https://www.cisco.com/c/de_de/about/legal/privacy-full.html . Basis for third-country transfers: Data Privacy Framework (DPF).
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time document collaboration, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/ ; Privacy statement: https://privacy.microsoft.com/de-de/privacystatement ; Security information: https://www.microsoft.com/de-de/trustcenter . Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA ).
- Skype: Messenger and conferencing software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.skype.com/de/ ; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement ; Security information: https://www.microsoft.com/de-de/trustcenter . Basis for third-country transfers: Data Privacy Framework (DPF).
- TeamViewer: Conference and communication software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.teamviewer.com/de/ . Privacy policy: https://www.teamviewer.com/de/legal/privacy-and-cookies/ .
- Zoom: Video conferencing, online meetings, webinars, screen sharing, optional session recording, chat function, integration with calendars and other apps; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website : https://zoom.us ; Privacy policy: https://explore.zoom.us/de/privacy/ ; Data processing agreement: https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf ), Data Privacy Framework (DPF) Standard Contractual Clauses ( https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf ).
Cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "Software as a Service") for storing and managing content (e.g. document storage and management, exchanging documents, content and information with specific recipients or publishing content and information).
Within this framework, personal data may be processed and stored on the providers' servers, insofar as this data is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data relating to transactions, contracts, other processes, and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.
If we provide forms, documents, and content to other users or publicly accessible websites using cloud services, the providers may store cookies on users' devices for web analytics purposes or to remember user settings (e.g., in the case of media control).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons: Interested parties; communication partners; business and contractual partners.
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Apple iCloud: Cloud storage service; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/ . Privacy policy: https://www.apple.com/legal/privacy/de-ww/ .
- Dropbox: Cloud storage service; Service provider: Dropbox, Inc., 333 Brannan Street, San Francisco, California 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.dropbox.com/de ; Privacy policy: https://www.dropbox.com/privacy ; Data processing agreement: https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf . transfers : Data Privacy Framework (DPF) , Standard Contractual Clauses ( https://assets.dropbox.com/documents/en/legal/dfb-data-processing-agreement.pdf ).
- Google Cloud Storage: Cloud storage, cloud infrastructure services, and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://cloud.google.com/ ; Privacy policy: https://policies.google.com/privacy ; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum ; transfers : Data Privacy Framework (DPF), Standard Contractual Clauses ( https://cloud.google.com/terms/eu-model-contract-clause ). Further information: https://cloud.google.com/privacy .
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services, and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-de ; Privacy statement: https://privacy.microsoft.com/de-de/privacystatement Security information: https://www.microsoft.com/de-de/trustcenter ; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA . Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA ).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or on the basis of a legal obligation. If the newsletter's content is specified during the registration process, this content is decisive for the user's consent. Normally, providing your email address is sufficient to register for our newsletter. However, to offer you a personalized service, we may ask for your name for a personal greeting in the newsletter or for further information if necessary for the newsletter's purpose.
Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove previously given consent. The processing of this data is limited to the purpose of defending against potential claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In cases where we are obligated to permanently respect objections, we reserve the right to store the email address solely for this purpose in a blocklist.
The registration process is logged based on our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure email delivery system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Affected persons: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g., via email or post); audience measurement (e.g., access statistics, recognition of returning visitors). Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to receiving further newsletters. You will find a link to unsubscribe at the end of each newsletter, or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Measuring open and click rates: Our newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server, or its server if we use a mailing service provider, when the newsletter is opened. During this retrieval, technical information, such as details about your browser and system, as well as your IP address and the time of retrieval, are collected. This information is used to technically improve our newsletter based on the technical data or to analyze target groups and their reading behavior based on their retrieval locations (which can be determined using 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 is assigned to individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to their interests. The measurement of open and click rates, the storage of the measurement results in user profiles, and their further processing are based on the users' consent. A separate revocation of performance tracking is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Prerequisite for using free services: Consent to receive mailings may be a prerequisite for using free services (e.g., access to certain content or participation in specific promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
- Brevo: Email delivery and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: 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.
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to promotional communications at any time.
After revocation or objection, we store the data necessary to prove previous authorization for contacting you or sending you information for up to three years after the end of the year in which the revocation or objection occurred, based on our legitimate interests. The processing of this data is limited to the purpose of defending against potential claims. Based on our legitimate interest in permanently respecting users' revocations or objections, we also store the data necessary to prevent renewed contact (e.g., depending on the communication channel, email address, telephone number, name).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
- Affected persons: Communication partners.
- Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analytics, monitoring and optimization
Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online services and can include pseudonymous data on visitor behavior, interests, or demographic information such as age or gender. Reach analysis allows us, for example, to identify when our online services, their features, or content are most frequently used and encourage repeat visits. It also enables us to understand which areas require optimization.
In addition to web analytics, we can also use testing procedures to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles—that is, data aggregated from a usage session—may be created for these purposes, and information may be stored in a browser or on a device and then read. The data collected includes, in particular, websites visited and elements used therein, as well as technical information such as the browser used, the computer system used, and usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.
Furthermore, users' IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored for web analytics, A/B testing, and optimization; instead, pseudonyms are used. 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 the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is that consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient, economical, and user-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 time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); user profiles (creation of user profiles); remarketing; conversion measurement (measuring the effectiveness of marketing measures). Marketing.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Information on consent recipients and cookieless analytics: Information on consent recipients: The consent given by users within the framework of a consent dialog (also known as "cookie opt-in/consent," "cookie banner," etc.) serves several purposes. Firstly, it allows us to fulfill our obligation to obtain consent for the storage and retrieval of information on and from users' devices (in accordance with ePrivacy guidelines). Secondly, it covers the processing of users' personal data in accordance with data protection regulations. Furthermore, this consent also applies to Google, as the company is obligated under the Digital Markets Act to obtain consent for personalized services. Therefore, we share the status of user consents with Google. Our consent management software informs Google whether consents have been given or not. The aim is to ensure that the consents given or not given by users are taken into account when using Google Analytics and when integrating functions and external services. This allows user consent and its revocation within the framework of Google Analytics and other Google services to be dynamically adjusted on our website, depending on the user's selection.
Cookieless analysis: We use the extended implementation of Google Analytics' consent mode. This means that if users do not consent to the storage and reading of information on their devices—especially regarding cookies—no cookies or similar information will be stored on their devices. Likewise, no user profiles will be created.
In this case, Google's code generates a random identification number on the user's device and transmits it to Google (a so-called "ping"). This identification number is not stored in the browser, in apps, or on any other user device. This identification number is unique for each website visit, so user behavior or interests are not tracked across devices or websites. Only a minimum of information about user activity is sent. This includes information about consent status and information for conversion measurement, i.e., whether a user was directed to our website via a Google ad.
Additionally, the following information may be transmitted, if available: a) Functional information such as headers (technical details transmitted by the browser), b) Timestamp (date and time of access), c) User agent (information about the browser and device used, only on the web), d) Referrer URL (the URL of the page from which the user came), e) Aggregated/pseudonymous information: This includes an indication of whether the current or a previous page in the user's navigation history contains ad click information in the URL (e.g., GCLID/DCLID, special tracking codes from Google), a random number generated with each page load, and information about the consent management platform used by the website owner (e.g., developer ID); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de . Privacy Policy: https://policies.google.com/privacy . - No collection of detailed location and device data (Google Analytics function): No detailed location and device data is collected (more information: https://support.google.com/analytics/answer/12017362 ).
- Google Tag Manager: We use Google Tag Manager, a software from Google that allows us to centrally manage website tags via a user interface. Tags are small code elements on our website used to record and analyze visitor activity. This technology helps us improve our website and the content it offers. Google Tag Manager itself does not create user profiles, store cookies containing user profiles, or perform independent analyses. Its function is limited to simplifying and streamlining the integration and management of the tools and services we use on our website. However, when using Google Tag Manager, users' IP addresses are transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set. This data processing only occurs, however, when services are integrated via the Tag Manager. For more detailed information about these services and their data processing, please refer to the subsequent sections of this privacy policy. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Data processing agreement:
https://business.safety.google/adsprocessorterms . Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms ) .
Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar methods are used to store user information relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical data such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this data may also be processed.
In addition, users' IP addresses are stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing methods know the actual user identity, but only the information stored in their profiles.
The information contained in the profiles is typically stored in cookies or using similar methods. These cookies can later be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing provider.
In exceptional cases, it is possible to associate personal data with profiles, primarily when users are, for example, members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by giving their consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, through conversion tracking, we can analyze which of our online marketing methods have led to a conversion, i.e., a contract signed with us. Conversion tracking is used solely for the purpose of analyzing the success of our marketing activities.
Unless otherwise stated, please assume that the cookies used will be stored for a period of two years.
Information on the legal basis: If we request users' consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient, economical, and user-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.
Information on cancellation and objection:
We refer you to the privacy policies of the respective providers and the opt-out options provided by those providers. If no explicit opt-out option is specified, you can disable cookies in your browser settings. However, this may limit the functionality of our website. We therefore also recommend the following opt-out options, which are offered for specific areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Across all regions: https://optout.aboutads.info.
- Types of data processed: Usage data (e.g., page views and time spent on the site, 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, timestamps, identification numbers, persons involved). Event data (Facebook) ("Event data" is information sent to the provider Meta, for example, via Meta pixels (whether through apps or other channels), relating to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. Event data is processed to create target groups for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as comments, login information, or contact information such as names, email addresses, or phone numbers. Event data is deleted by Meta after a maximum of two years, and the resulting target groups disappear when our Meta user accounts are deleted.).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation; marketing; profiles with user-related information (creation of user profiles); conversion measurement (measuring the effectiveness of marketing measures); remarketing. Provision of our online services and user-friendliness.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Facebook Ads: Placement of advertisements within the Facebook platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com ; Privacy policy: https://www.facebook.com/privacy/policy/ ; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out option: We refer to the data protection and advertising settings in the user's profile on the Facebook platforms, as well as to Facebook's consent procedures and contact options for exercising rights of access and other data subject rights, as described in Facebook's privacy policy; Further information: User event data, i.e. Behavioral and interest data is processed for targeted advertising and audience segmentation purposes based on the joint controllership agreement ("Controller Addendum," https://www.facebook.com/legal/controller_addendum ). Joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and Conversion Tracking: Online marketing methods for placing content and ads within the service provider's advertising network (e.g., in search results, videos, on websites, etc.) so that they are displayed to users who have a likely interest in the ads. We also measure ad conversions, i.e., whether users have taken the opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Website: https://marketingplatform.google.com ; Privacy policy: https://policies.google.com/privacy ; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: Types of processing and data processed: https://business.safety.google/adsservices/ . Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms .
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that adds users of an online service to a pseudonymous remarketing list. This allows users to be shown ads on other online platforms based on their visit to the online service. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Website: https://marketingplatform.google.com . Privacy policy: https://policies.google.com/privacy . Basis for third-country transfers: Data Privacy Framework (DPF). Further information: Types of processing and data processed: https://business.safety.google/adsservices/ . Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms .
- Enhanced Conversion Tracking for Google Ads: When users click on our Google ads and subsequently use the advertised service (a "conversion"), the data entered by the user, such as email address, name, home address, or telephone number, may be transmitted to Google. The hash values are then compared with existing Google accounts of the users in order to better evaluate and improve user interaction with the ads (e.g., clicks or views) and thus their performance; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Website : https://support.google.com/google-ads/answer/9888656
- Instagram Ads: Placement of advertisements within the Instagram platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.instagram.com ; Privacy policy: https://privacycenter.instagram.com/policy/ ; Basis for third-country transfers: Data Privacy Framework (DPF); Right to object (opt-out): We refer to the data protection and advertising settings in the user's profile on the Instagram platform, as well as within the framework of Instagram's consent procedure and Instagram's contact options for exercising rights of access and other data subject rights in Instagram's privacy policy; Further information: User event data, i.e. Behavioral and interest data is processed for targeted advertising and audience segmentation purposes based on the joint controllership agreement ("Controller Addendum," https://www.facebook.com/legal/controller_addendum ). Joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn Insight Tag: Code that loads when a user visits our online service and tracks the user's behavior and conversions, storing this information in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.linkedin.com ; Privacy policy: https://www.linkedin.com/legal/privacy-policy , Cookie policy: https://www.linkedin.com/legal/cookie_policy ; Data processing agreement: https://www.linkedin.com/legal/l/dpa ; Legal basis for third-country transfers: 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 .
Offer of an affiliate program
We offer an affiliate program, meaning commissions or other benefits (collectively referred to as "commissions") for users (referred to as "affiliates") who refer to our offers and services. Referrals are made via a link assigned to the respective affiliate or other methods (e.g., discount codes) that allow us to recognize that the use of our services was based on the referral (collectively referred to as "affiliate links").
To track whether users have accessed our services through affiliate links provided by our affiliates, we need to know that users have followed an affiliate link. The association of affiliate links with specific transactions or other uses of our services is solely for the purpose of commission calculation and will be deleted as soon as it is no longer needed for this purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are either part of the link itself or can be stored elsewhere, e.g., in a cookie. These values may include, in particular, the referring website, the time, an online identifier of the operator of the website where the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.
Legal basis for data processing: The processing of our partners' data is carried out for the provision of our (pre-)contractual services. User data is processed based on their consent.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and time spent on the site, 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 data retrieval or access times).
- Affected persons: Users (e.g., website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Affiliate tracking.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Customer reviews and rating procedures
We participate in review and rating processes to evaluate, optimize, and promote our services. When users rate us through the participating rating platforms or processes, or otherwise provide feedback, the providers' terms and conditions and privacy policies also apply. As a rule, registration with the respective providers is also required to submit a rating.
To ensure that reviewers have actually used our services, we transmit the necessary data regarding the customer and the service used (including name, email address, and order number or item number) to the respective review platform with the customer's consent. This data is used solely to verify the user's authenticity.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Affected persons: Service recipients and clients. Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Rating Widget: We integrate so-called "rating widgets" into our online services. A widget is a functional and content element integrated into our online services that displays dynamic information. It can be displayed, for example, as a seal or similar element, sometimes also called a "badge." While the widget's content is displayed within our online services, it is retrieved from the servers of the respective widget provider at that moment. This is the only way to ensure that the content shown is always up-to-date, especially the current rating. For this to work, a data connection must be established between the webpage accessed within our online services and the widget provider's server. The widget provider receives certain technical data (access data, including the IP address) necessary to deliver the widget's content to the user's browser. Furthermore, the widget provider receives information that users have visited our online services. This information can be stored in a cookie and used by the widget provider to identify which online services participating in the evaluation process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Google Customer Reviews: Service for collecting and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/ ; Privacy policy: https://policies.google.com/privacy ; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: When collecting customer reviews, an identification number and the time of the business transaction being reviewed are processed. For review requests sent directly to customers, the customer's email address, their country of residence, and the review details themselves are processed. Further information on the types of processing and the data processed: https://business.safety.google/adsservices/ . Data processing terms for Google advertising products: Information on the services, data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms .
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about ourselves.
Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on usage patterns and the resulting user interests. These profiles may then be used to display advertisements both within and outside the networks that are presumably tailored to the users' interests. Therefore, cookies are typically stored on users' computers to record their usage patterns and interests. Additionally, user profiles can also store data independent of the devices used by the users (especially if they are members of the respective platforms and logged in).
For a detailed description of the respective processing methods and the options for objecting (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the latter have access to user data and can take appropriate action and provide information directly. Should you nevertheless require assistance, 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 image messages and posts, as well as information relating to them, such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Communication; feedback (e.g., collecting feedback via online form). Public relations.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com ; Privacy policy: https://privacycenter.instagram.com/policy/ . Basis for third-country transfers: Data Privacy Framework (DPF).
- Facebook Pages: Profiles within the Facebook social network - We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "Fan Page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/ ), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/ ). As described in the Facebook Data Policy under "How do we use this information?" Facebook explains that it also collects and uses information to provide analytics services, known as "Page Insights," to page administrators, enabling them to gain insights into how people interact with their pages and the content associated with them. We have entered into a specific agreement with Facebook ("Information about Page Insights," https://www.facebook.com/legal/terms/page_controller_addendum ), which specifically outlines the security measures Facebook must observe and in which Facebook has agreed to comply with data subject rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). The rights of users (in particular, the rights to access, deletion, objection, and lodging a complaint with the relevant supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" ( https://www.facebook.com/legal/terms/information_about_page_insights_data ). Joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular regarding the transfer of data to its parent company, Meta Platforms, Inc., in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com ; Privacy policy: https://www.facebook.com/privacy/policy/ . Basis for third-country transfers: 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 collecting (but not further processing) visitor data used to generate "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as their actions. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, along with information from user profiles, such as job title, country, industry, hierarchical level, company size, and employment status. Information regarding LinkedIn's processing of user data can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have entered into a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum ) which, in particular, regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for access or erasure directly to LinkedIn). The rights of users (in particular the right to access, erasure, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to its parent company, LinkedIn Corporation, in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website : https://www.linkedin.com Privacy Policy: https://www.linkedin.com/legal/privacy-policy ; Legal basis for third-country transfers: 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 . - YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy policy: https://policies.google.com/privacy ; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/personalizationoff .
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/ . Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung .
Management, organization and support tools
We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning, and delivering our services. We comply with legal requirements when selecting third-party providers and their services.
Within this framework, personal data may be processed and stored on the servers of third-party providers. This may involve various types of data, which we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data relating to transactions, contracts, other processes, and their content.
If users are referred to third-party providers or their software or platforms in the course of communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security, service optimization, or marketing purposes. We therefore ask you to review the privacy policies of the respective third-party providers.
- Types of data processed: Content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved).
- Affected persons: 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.
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Processing of data in the context of employment relationships
In the context of employment relationships, personal data is processed with the aim of effectively managing the establishment, execution, and termination of such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.
Data processing encompasses various aspects, ranging from contract initiation to contract termination. This includes the organization and management of daily working hours, the management of access rights and permissions, and the handling of personnel development measures and employee reviews. The processing also serves the purpose of payroll and salary payments, which are critical aspects of contract execution.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring workplace safety or collecting performance data for the evaluation and optimization of operational processes. Furthermore, data processing includes the disclosure of employee data within the framework of external communication and publication processes, where this is necessary for operational or legal purposes.
The processing of this data is always carried out in compliance with applicable legal frameworks, with the constant aim of creating and maintaining a fair and efficient working environment. This also includes respecting the data protection rights of the employees concerned, and anonymizing or deleting data after the processing purpose has been fulfilled or in accordance with statutory retention periods.
- Types of data processed: Employee data (information on employees and other persons in an employment relationship); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Master data (e.g., full name, home address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Social data (data subject to social confidentiality and processed, for example, by social security institutions, social welfare agencies, or pension authorities); Log data (e.g., log files concerning logins or data retrieval or access times); Performance and behavioral data (e.g., performance and behavioral aspects such as performance reviews, feedback from supervisors, training participation, compliance with company policies, self-assessments, and behavioral assessments). Working time data (e.g., start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g., base salary, bonus payments, premiums, tax bracket information, surcharges for night work/overtime, tax deductions, social security contributions, net payment amount); image and/or video recordings (e.g., photographs or video recordings of a person); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
- Special categories of personal data: Health data; Religious or philosophical beliefs; Trade union membership.
- Affected persons: Employees (e.g., salaried employees, applicants, temporary workers and other staff).
- Purposes of processing: Establishing and carrying out employment relationships (processing employee data in the context of establishing and carrying out employment relationships); business processes and operational procedures; security measures; provision of contractual services and fulfillment of contractual obligations; public relations. Office and organizational procedures.
- Legal basis: Contract performance 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). Processing of special categories of personal data relating to healthcare, professional and social security (Art. 9 para. 2 lit. h) GDPR).
Further information on processing procedures, methods and services:
- Time tracking: Procedures for recording employee working hours include both manual and automated methods, such as the use of time clocks, time tracking software, or mobile apps. Activities include entering arrival and departure times, break times, overtime, and absences. Verification and validation of the recorded working hours include reconciliation with duty rosters or shift schedules, verification of absences, and approval of overtime by supervisors. Reports and analyses are generated based on the recorded working hours to provide time sheets, overtime reports, and absence statistics for management and the HR department. Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Access management: Procedures required for defining, managing, and controlling access rights and user roles within a system or organization (e.g., creating access profiles, role- and access-based control, reviewing and approving access requests, regularly checking access rights, tracking and auditing user activities, creating security policies and procedures); Legal bases: Contract performance 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).
- Special categories of personal data: Special categories of personal data are processed within the context of the employment relationship or to fulfill legal obligations. The processed special categories of personal data include data concerning the health, trade union membership, or religious affiliation of employees. This data may be disclosed to health insurance companies, processed for assessing employees' fitness for work, for occupational health management, or for providing information to the tax authorities. Legal bases: Contract performance 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).
- Sources of processed data: Personal data obtained during the application process and/or the employment relationship of employees is processed. In addition, personal data from other sources is collected where legally required. These may include tax authorities for tax-relevant information, the respective health insurance provider for information on incapacity for work, third parties such as employment agencies, or publicly accessible sources such as professional social networks in the context of application procedures. Legal bases: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Video surveillance: Employee monitoring serves the purpose of company security, protecting property, and ensuring employee safety. Various procedures and data processing steps are implemented for this purpose.
First, surveillance cameras are installed and positioned following a site analysis to identify security-relevant areas. The cameras are then installed in suitable locations, and signs or warning notices can be posted to indicate the presence of surveillance.
Regular checks are conducted to ensure the cameras are functioning correctly and that no malfunctions occur that could compromise security.
The actual monitoring takes place through video recordings to capture and document potential security incidents. These recordings are subsequently evaluated and analyzed to identify suspicious activity and respond appropriately.
All recorded video data is archived in accordance with legal regulations and data protection guidelines. It should be noted that the data is deleted after a maximum of 96 hours, unless there is a specific suspicion requiring longer retention to clarify the facts or ensure the company's security.
In addition, measures for data deletion are implemented as soon as the retention periods have expired or the data is no longer needed in order to comply with data protection guidelines and protect the privacy of employees; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - Purposes of data processing: Employees' personal data is primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, processing this data is necessary to comply with legal obligations under tax and social security law. In addition to these primary purposes, employee data is also used to fulfill regulatory and supervisory requirements, to optimize electronic data processing processes, and to compile internal or inter-company data, potentially including statistical data. Employee data may also be processed for the assertion of legal claims and for defense in legal disputes. Legal bases: Contract performance 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).
- Transfer of employee data: Employee data is processed internally only by those departments that require it to fulfill operational, contractual, and legal obligations.
Data is only transferred to external recipients if required by law or if the employees concerned have given their consent. Possible scenarios for this include requests for information from authorities or in the case of employee savings plans. Furthermore, the data controller may transfer personal data to other recipients to the extent necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) banks b) health insurance funds, pension insurance institutions, retirement savings providers, and other social security institutions c) authorities, courts (e.g., tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and disclosure obligations) d) tax and legal advisors e) third-party debtors in the case of wage and salary garnishments f) other bodies to which legally binding declarations must be submitted.
Furthermore, data may be shared with third parties if this is necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender field of emails or letterheads, as well as the creation of profiles on external platforms; 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). - Business travel and travel expense accounting: Procedures necessary for the planning, execution, and accounting of business trips (e.g., booking travel, organizing accommodation and transportation, managing travel expense advances, submitting and reviewing travel expense reports, monitoring and recording incurred costs, complying with travel policies, and handling travel expense management); Legal bases: Contract performance 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).
- Payroll accounting and wage processing: Procedures necessary for calculating, paying, and documenting wages, salaries, and other remuneration of employees (e.g., recording working hours, calculating deductions and bonuses, paying taxes and social security contributions, preparing payroll statements, maintaining payroll accounts, and reporting to tax authorities and social security institutions); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
- Deletion of employee data: Employee data is deleted under German law when it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the employer's legitimate interests. The following retention and archiving obligations are observed:
- General personnel documents – General personnel documents (such as employment contract, employment certificate, supplementary agreements) are kept for up to three years after the termination of the employment relationship (§ 195 German Civil Code).
Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 German Fiscal Code, § 257 German Commercial Code).
Information on wages and working hours – Information on wages and working hours for (accident) insured persons with proof of wages is kept for five years (§ 165 I 1, IV 2 German Social Code, Book VII). - Payroll lists including lists for special payments - Payroll lists including lists for special payments, provided that a booking document exists, are kept for ten years (§ 147 AO, § 257 HGB).
- Payroll lists for interim, final and special payments - Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
- Employee insurance documents - Employee insurance documents, provided that booking receipts are available, are kept for ten years (§ 147 AO, § 257 HGB).
- Contribution statements to social security institutions – Contribution statements to social security institutions are kept for ten years (§ 165 SGB VII).
Payroll accounts – Payroll accounts are kept for six years (§ 41 I 9 EStG). - Applicant data - will be stored for a maximum of six months from receipt of the rejection.
- Working time records (for more than 8 hours on working days) - are kept for two years (§ 16 II Working Time Act (ArbZG)).
- Application documents (following online job advertisement) - are kept for three to a maximum of six months after receipt of the rejection (§ 26)
- Federal Data Protection Act (BDSG) nF, § 15 IV General Equal Treatment Act (AGG)).
- Certificates of incapacity for work (AU) - are kept for up to five years (§ 6 I Aufwendungsausgleichsgesetz (AAG)).
- Documents relating to company pension schemes - These must be kept for 30 years (§ 18a Law on the Improvement of Company Pension Schemes (BetrAVG)).
- Employee illness data - These are kept for twelve months after the start of the illness if the absences in one year do not exceed six weeks.
- Documents relating to maternity protection - These are kept for two years (§ 27 para. 5 MuSchG).
- General personnel documents – General personnel documents (such as employment contract, employment certificate, supplementary agreements) are kept for up to three years after the termination of the employment relationship (§ 195 German Civil Code).
- Personnel file management: Procedures necessary for the organization, updating, and administration of employee data and documents (e.g., recording employee master data, storing employment contracts, certificates, and attestations, updating data when changes occur, compiling documents for employee reviews, archiving personnel files, and complying with data protection regulations); Legal bases: Contract performance 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), Processing of special categories of personal data relating to health, occupational health, and social security (Art. 9 para. 2 lit. h) GDPR).
- Personnel development, performance appraisal, and employee appraisals: Procedures required for the promotion and development of employees, as well as for assessing their performance and conducting employee appraisals (e.g., needs analysis for further training, planning and implementation of training measures, preparation of performance appraisals, conducting target agreement and feedback meetings, career planning and talent management, succession planning); Legal bases: Contractual performance 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), Processing of special categories of personal data relating to health, occupational health and safety (Art. 9 para. 2 lit. h) GDPR).
- Obligation to provide data: The data controller informs employees that providing their data is necessary. This is generally the case if the data is required for establishing and carrying out the employment relationship or if its collection is legally mandated. Providing data may also be necessary if employees assert claims or are entitled to claims. The implementation of these measures or the fulfillment of services depends on the provision of this data (for example, providing data for the purpose of receiving wages). Legal bases: Contract performance 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).
- Publication and Disclosure of Employee Data: Employee data will only be published or disclosed to third parties if this is necessary for the performance of their duties in accordance with their employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website, or in public registers, as agreed upon or in accordance with their job description, or if their duties include representative functions. This may also be the case if the performance of duties involves public presentation or communication, such as taking photographs for public relations purposes. Otherwise, employee data will only be published with their consent or based on the employer's legitimate interests, for example, in the case of stage or group photographs taken at a public event. Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Application process
The application process requires applicants to provide us with the data necessary for their assessment and selection. The required information is specified in the job description or, in the case of online forms, in the information provided there.
Generally, the required information includes personal details such as name, address, contact information, and proof of qualifications necessary for the position. We will gladly provide further details upon request.
Where available, applicants are welcome to submit their applications via our online form, which is encrypted using state-of-the-art technology. Alternatively, it is also possible to send applications to us by email. However, we would like to point out that emails are generally not encrypted when sent over the internet. Although emails are usually encrypted during transmission, this encryption does not occur on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the security of the application during its transmission between the sender and our server.
For the purposes of candidate sourcing, application submission and candidate selection, we may, in compliance with legal requirements, use applicant management or recruitment software and platforms and services from third-party providers.
Applicants are welcome to contact us regarding the method of submitting their application or to send us their application by post.
Processing of special categories of data: Insofar as special categories of personal data (Art. 9 para. 1 GDPR, e.g., health data such as severe disability or ethnic origin) are requested from or provided by applicants during the application process, their processing is carried out so that the controller or the data subject can exercise their rights and fulfill their obligations arising from employment law and social security and social protection law, in the case of protecting the vital interests of the applicants or other persons, or for purposes of preventive or occupational medicine, for assessing the employee's fitness for work, for medical diagnosis, for the provision of health or social care or treatment, or for the management of health or social care systems and services.
Data Deletion: If an application is successful, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a legitimate objection from the applicant, deletion will take place no later than six months after the application date. This allows us to answer any follow-up questions regarding the application and to comply with our obligations under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursements will be archived in accordance with tax regulations.
Inclusion in a talent pool: Inclusion in a talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process, and that they can withdraw their consent at any time for the future.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as information relating to them, such as authorship or date of creation); applicant data (e.g., personal details, postal and contact addresses, application documents and the information contained therein, such as cover letters, CVs, certificates, and other information provided by applicants regarding a specific position or voluntarily provided by applicants concerning their person or qualifications).
- Affected persons: Applicants.
- Purposes of processing: Application process (establishment and any subsequent implementation as well as possible subsequent termination of the employment relationship).
- Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal basis: Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
- Stepstone: Services related to employee recruitment (search for employees, communication, application process, contract negotiations); Service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.stepstone.de . Privacy policy: https://www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/ .
- Classifieds.de: Placing job advertisements on classifieds.de; Service provider: kleinanzeigen.de GmbH,
Dernburgstraße 50,
14057 Berlin; Website: https://themen.kleinanzeigen.de . Privacy policy: https://themen.kleinanzeigen.de/datenschutzerklaerung .
Changes and updates
We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.
If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

