Privacy policy

PRIVACY POLICY

State: 9 December 2020

I. Introduction

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The privacy policy applies to all of our processing of personal data, 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 offer”).

The used terms are not gender-specific.

II. Responsible person (“controller“)

LegalTegrity GmbH
Platz der Einheit 2
60327 Frankfurt

Authorised representatives: Pia Michel, Dr. Thomas Altenbach

E-mail: contact@legaltegrity.com
Imprint: https://legaltegrity.com/impressum/

III. Overview of processing

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

1. Types of data processed:

  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information about the applicant’s person or qualification provided voluntarily by the applicant with regard to a specific position or on a voluntary basis).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or person).
  • Contract data (e.g. subject matter of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

 

2. Categories of data subjects:

  • Employees (e.g. employees, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

 

3. Purposes of the processing:

  • Affiliate tracking.
  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Application procedure (establishment and possible later conduct and possible later termination of employment).
  • Office and organisational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Target group formation.
  • Interest-based and behaviour-based marketing.
  • Contact requests and communication.
  • Profiling (creation of user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Surveys and questionnaires (e.g. surveys with input options, multiple choice questions).
  • Provision of contractual services and customer service.
  • Management and response to requests.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

 

IV. Relevant legal bases

In the following, we provide the legal basis of the General Data Protection Regulation (GDPR), on which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence and domicile. Should more specific legal regulations apply in individual cases, we will inform you of these in the Privacy Policy.

  • Consent (Art. 6 para. 1 s. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for carrying out pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 s. 1 lit. c. GDPR) – The processing is necessary to fulfil a legal obligation to which the controller is subject.
  • Protection of public interests (Art. 6 para. 1 s. 1 lit. e. GDPR) – The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • Legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) – If, in the course of the application procedure, special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled capacity or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights arising to him or her from employment law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR, in the case of protection of vital interests of applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. GDPR. In case of communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.
  • Fulfilment of contract and pre-contractual enquiries (EKD) (Section 6 No. 5 DSG-EKD) – Processing is necessary for the performance of a contract to which the data subject is a party or for carrying out pre-contractual measures taken at the request of the data subject.

 

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, conduct or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

V. Security measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate with the risk.

These measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic entry to the data as well as access, input, disclosure, safeguarding of availability and separation of data. Procedures have also been put in place to ensure that data subjects’ rights are respected, that data are deleted and that responses to data breaches are made. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection by designing technology and by using data protection-friendly default settings.

Shorten the IP address: If it is possible or not necessary for us to save your IP address, we will shorten or have your IP address shortened. In the case of shortening the IP address, also known as “IP masking”, the last octet, i.e. the last two numbers of an IP address, are deleted (in this context, the IP address is an identifier individually assigned to an Internet connection by the online access provider). The purpose of shortening the IP address is to prevent or make it much more difficult to identify a person on the basis of their IP address.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.

VI. Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases we observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data which serve to protect your data.

Transfer of information within the organisation: We may transfer or grant access to personal information to other entities within our organisation. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual obligations or if the consent of the data subject or legal permission has been obtained.

Data processing in third countries

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

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

VIII. Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping basket or the place where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
  • Statistical, marketing and personalisation cookies: Furthermore, cookies are generally also used in the context of range measurement and when the interests of a user or his behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e. following the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when you give your consent.

 

Information on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Storage duration: Unless we provide you with explicit information on the storage duration of permanent cookies (e.g. within the framework of a so-called cookie opt-in), please assume that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used at most, which are absolutely necessary for the operation of our online service.

Cookie settings/confirmation option:

Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

IX. Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships and associated measures and within the framework of communication with the contractual partners (or pre-contractual), e.g. to answer enquiries.

We process these data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with these data as well as for business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to participating telecommunication, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.

We inform the contractual partners which data are required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and data protection information of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Customer account: Contractual parties can create an account within our online offer (e.g. customer or user account, in short “customer ac- count”). If the registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of the registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent possible misuse of the customer account.

If customers have cancelled their customer account, the data relating to the customer account will be deleted, subject to retention of the data for legal reasons. It is the responsibility of the customers to secure their data when the customer account is cancelled.

Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers for the processing of payment transactions. The required information is marked as such within the scope of the order or comparable purchase process and includes the information required for delivery, or provision and invoicing, as well as contact information in order to be able to consult with you if necessary.

Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Interested parties, business and contractual partners, customers.

Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organisational procedures, management and response to requests, security measures.

Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legal obligation (Art. 6 para. 1 s. 1 lit. c. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

X. Payment service provider

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).

The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the general terms and conditions and the data protection information of the payment service providers.

For payment transactions, the terms and conditions and the data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and the assertion of rights of revocation, access and other rights of data subjects.

Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Customers, interested parties.

Purposes of processing: Provision of contractual services and customer service, contact requests and communication, affiliate tracking.

Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • PayOne: payment services; service provider: PayOne GmbH, Lyoner Straße 9, 60528 Frankfurt am Main, Germany; website: https://www.payone.com; privacy policy: https://www.payone.com/DE-de/datenschutz.
  • PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à.r.l. et Cie., S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Visa: payment services; service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; website: https://www.visa.de; privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.

 

XI. Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files called up, the date and time of the call-up, the amount of data transferred, notification of successful call-up, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the capacity utilisation of the servers and their stability.

Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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

Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

XII. Registration, login and user account

Users can create a user account. Within the scope of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purpose of using the user account and its purpose.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes. If users have cancelled their user account, their data of the user account will be deleted, subject to a legal obligation to keep records. It is the responsibility of the users to save their data before the end of the contract if they have terminated their user account. We are entitled to irretrievably delete all user data stored during the term of the contract.

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

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), meta/communication data (e.g. device information, IP addresses).

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

Purposes of processing: Provision of contractual services and customer service, security measures, management and response to requests.

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), performance of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

XIII. Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are 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. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this privacy policy.

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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

Purposes of processing: Provision of contractual services and customer service, feedback (e.g. collecting feedback via online form).

Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

XIV. Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact enquiries and any requested measures.

The answering of contact enquiries within the framework of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of our legitimate interest in answering the enquiries.

Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), meta/communication data (e.g. device information, IP addresses).

Data subjects: Communication partners, customers, users (e.g. website visitors, users of online services).

Purposes of processing: Contact requests and communication, management and reply to requests, feedback (e.g. collecting feedback via online form), surveys and questionnaires (e.g. surveys with input possibilities, multiple choice questions).

Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR), protection of public interests (Art. 6 para. 1 s. 1 lit. e. GDPR).

Services used and service providers:

  • HubSpot: customer care and service software (management of customer requests from different channels), ticketing system, feedback, satisfaction and other surveys; service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; website: https://www.hubspot.de; privacy policy: https://legal.hubspot.com/de/privacy-policy.

XV. Communication via messenger

We use messenger for communication purposes and therefore ask you to observe the following information on the functionality of messenger, encryption, use of metadata of communication and your right to object to the communication. You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact details provided to you or the contact details provided within our online offer.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of messenger with encryption enabled to ensure that the message content is encrypted.

However, we would like to point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata) is processed.

Information on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for your consent and you contact us, for example, on your own initiative, we will use messenger in relation to our contractual partners and in the context of contract preparation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our justified interests in fast and efficient communication and 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 data provided to us to messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke a given consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (i.e., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and no legal storage obligations stand in the way of deletion.

Reservation of the reference to other communication channels: Finally, we would like to point out that for reasons of your security, we reserve the right not to answer enquiries via messenger. This is the case if, for example, internal contractual matters require special confidentiality or if a reply via messenger does not meet the formal requirements. In such cases we will refer you to more appropriate communication channels.

Processed data types: Contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. entries in online forms).

Data subjects: Communication partners.

Purposes of processing: Contact requests and communication, direct marketing (e.g. by e-mail or by post).

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • Slack: Slack Messenger without end-to-end encryption; service provider: Slack Technologies, Inc, 500 Howard Street, San Francis- co, CA 94105, USA; website: https://slack.com/intl/de-de/; privacy policy: https://slack.com/intl/de-de/legal.

XVI. Chatbots and chat functions

We offer online chats and chatbot functions as a means of communication (collectively referred to as “chat services”). A chat is an online conversation conducted with a certain amount of timeliness. A chatbot is software that answers users’ questions or informs them about messages. If you use our chat functions, we may process your personal data.

If you use our chat services within an online platform, your identification number is also stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.

We point out to users that the respective platform provider may find out that and when users communicate with our chat services and collect technical information on the user’s device and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e. information on who has communicated with whom, for example) could be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their regulations, to which we refer for further information.

If users agree to activate information with regular messages to a chatbot, they have the possibility to unsubscribe at any time. The chatbot will point out to users how and with what terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, users’ data are deleted from the directory of message recipients.

We use the aforementioned information to operate our chat services, e.g. to address users personally, to answer their queries , to transmit any requested content and also to improve our chat services (e.g. to “teach” chat offers answers to frequently asked questions or to identify unanswered queries).

Legal notice: We use the chat services on a consent basis where we have obtained prior permission from users to process their data as part of our chat services (this applies to cases where users are asked for consent, e.g. so that a chatbot can send them regular messages). If we use chat services to answer users’ questions about our services or our company, this is done for contractual and pre-contractual communication. In addition, we use chat services on the basis of our legitimate interests in optimising the chat services, their economic efficiency and increasing the positive user experience.

Revocation, objection and deletion: You can revoke a given consent or object to the processing of your data within the scope of our chat services at any time.

Processed data types: Contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Data subjects: Communication partners.

Purposes of processing: Contact requests and communication, direct marketing (e.g. by e-mail or by post).

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • HubSpot: chatbot and assistance software and related services; service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; website: https://www.hubspot.de; privacy policy: https://legal.hubspot.com/de/privacy-policy.

XVII. Video conferences, online meetings, webinars and screen sharing

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

In this context, data of the communication participants are processed and stored on the servers of the third party providers, as far as these are components of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions, as well as entries in chats and shared screen content.

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

Information on legal bases: If we ask users for their consent to use the third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis for processing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context we would like to refer you additionally to the information on the use of cookies in this privacy prolicy.

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device in- formation, IP addresses).

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

Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organisational procedures, direct marketing (e.g. by e-mail or post).

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), performance of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

· Microsoft Teams: messenger and conferencing software; service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://products.office.com; privacy policy: https://privacy.microsoft.com/de- de/privacystatement, Security notice: https://www.microsoft.com/de-de/trustcenter.

· Zoom: video conferences, web conferences and webinars; service providers: Zoom Video Communications, Inc, 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; wsite: https://zoom.us; privacy policy: https://zoom.us/docs/de-de/privacy-and- legal.html; Standard Contractual Clauses (Ensuring Level of Data Protection for Processing in Third Countries): https://zoom.us/docs/de-de/privacy-and-legal.html (Referred to as Global DPA).

XVIII. Application procedure

The application procedure requires applicants to provide us with the data required for their assessment and selection. Which information is required can be found in the job description or, in the case of online forms, in the information provided there.

In principle, the required information includes personal details such as name, address, a contact option and proof of the qualifications required for a job. On request, we will also be happy to provide you with the necessary information.

If provided, applicants can send us their applications using an online form. The data will be encrypted and transmitted to us according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not accept any responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may, subject to legal requirements, use applicant management or recruitment software and platforms and services of third parties.

Applicants are welcome to contact us regarding the method of submitting their application or send us their application by post.

Processing of special categories of data: If special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data such as severely disabled capacity or ethnic origin) are requested from applicants in the context of the application procedure so that the controller or the data subject can exercise the rights arising to him or her from labour law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 Par. 2 letter b. GDPR, in the case of protection of vital interests of applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. GDPR. In case of communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.

Deletion of data: In the event of a successful application, the data provided by the applicants may be processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time. Subject to a justified revocation by the applicants, the deletion will take place at the latest after a period of six months, so that we can answer any follow-up questions regarding the application and fulfil our obligations to provide evidence in accordance with the regulations on the equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Admission to an applicant pool: Admission to an applicant 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 current application procedure and that they can withdraw their consent at any time in the future.

Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information on the applicant’s person or qualification provided by applicants with regard to a specific position or voluntarily).

Data subjects: Applicants.

Purposes of processing: Application procedure (establishment and possible subsequent implementation and possible subsequent termination of employment).

Legal bases: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).

Services used and service providers:

  • LinkedIn Recruiter: recruitment platform and services; service provider: https://www.linkedin.com, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy- policy.

XIX. 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 the following purposes: document storage and management, calendar management, e-mailing, spread- sheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chatting and participating in audio and video conferences.

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

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

Information on legal bases: If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes).

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device in- formation, IP addresses).

Data subjects: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.

Purpose of the processing: Office and organisational procedures.

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), performance of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • Telekom Magentacloud: cloud storage services; service provider: Telekom Deutschland GmbH, Landgrabenweg 151, 53227 Bonn, Germany; website: https:/cloud.telekom-dienste.de/; privacy policy: https://www.telekom.de/datenschutz-ganz-einfach.

XX. Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. Insofar as the contents of a newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other details if these are required for the purposes of the newsletter.

Double-opt-in procedure: The registration to our newsletter is always done in a so-called double-opt-in-procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the dispatch service provider are also logged.

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

The registration procedure is recorded on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Information on legal bases: The dispatch of the newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process will be recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law.

Contents: Information about us, our services, actions and offers.

Analysis and success measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or from the server of the newsletter provider if we use a mailing service provider. Within the framework of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined by means of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be allocated to individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the explicit consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible. In this case, the entire newsletter subscription must be cancelled or objected to.

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).

Data subjects: Communication partners.

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

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

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

Services used and service providers:

  • HubSpot: e-mail marketing platform; service provider: HubSpot, Inc. 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Web site: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy.

XXI. Advertising communication via e-mail, post, fax or telephone

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

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

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete it. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.

Data types processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).

Data subjects: Communication partners.

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

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

XXII. Web analysis, monitoring and optimisation

Web analysis (also known as “reach measurement”) is used to evaluate the streams of visitors to our online offer and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite for reuse. We can also understand which areas require optimisation.

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

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, the content viewed, websites visited and elements used on them, and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymisation by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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

Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles)

Security measures: IP masking (pseudonymisation of the IP address).

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • Google Analytics: reach measurement and web analysis; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy.

XXIII. Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the dis- play of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned contents is stored. This information may include, for example, the content viewed, websites visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymisation by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored within the framework of the online marketing procedure, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure, analysed for the purpose of presenting content and supplemented with further data and stored on the server of the online marketing procedure provider.

As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing methods we use and the network links the users’ profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only have access to summarised information about the success of our advertisements. However, in the course of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Google Universal Analytics: We use Google Analytics in the form of Universal Analytics (https://support.google.com/analytics/answer/2790010?hl=de&ref_topic=6010376). “Universal Analytics” refers to a Google Analytics procedure in which the user analysis is based on a pseudonymous user ID, thus creating a pseudonymous profile of the user with information from the use of various devices (so-called “cross-device tracking”).

Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person).

Data subjects: Users (e.g. website visitors, users of online services), interested parties.

Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behaviour-based marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors), cross-device tracking (cross-device processing of user data for marketing purposes)

Security measures: IP masking (pseudonymisation of the IP address).

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Possibility of objection (opt-out): We refer to the privacy policy of the respective providers and the possibilities of objection (so-called “opt-out”) indicated for the providers. If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:

 

Services used and service providers:

  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (for more information on this, please refer to this privacy policy). With the tag manager itself (which implements the tags), no user profiles are created or cookies are stored. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
  • Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; opt-out: opt- out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, advertising display settings: https://adssettings.google.com/authenticated.
  • Google Universal Analytics: service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; security measures: IP Masking (pseudonymisation of the IP address); Privacy Policy: https://policies.google.com/privacy.
  • HubSpot: marketing software for lead generation, marketing automation and analysis; service provider: HubSpot, Inc. 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Web site: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy.
  • LinkedIn: insights tag / conversion measurement; service provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; website: https://www.linkedin.com; security measures: IP Masking (pseudonymisation of the IP address); Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

XXIV. Offer of an affiliate programme

We offer an affiliate programme, i.e., commissions or other benefits (collectively referred to as “commissions”) to users (referred to as “affiliates”) who refer to our offers and services. The reference is made by means of a link assigned to the respective affiliate or other methods (e.g. discount codes) which allow us to recognise that the use of our services was based on the reference (collectively referred to as “affiliate links”).

In order to be able to track whether users have taken advantage of our services due to the affiliate links used by the affiliates, it is necessary for us to know that users have followed an affiliate link. The assignment of the affiliate links to the respective business transactions or to the other use of our services serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the above-mentioned allocation of affiliate links, the affiliate links may be supplemented by certain values which are a component of the link or may be stored elsewhere, e.g. in a cookie. These values may include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times).

Data subjects: Users (e.g. website visitors, users of online services), business and contractual partners.

Purpose of processing: Provision of contractual services and customer service, affiliate tracking.

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), performance of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

XXV. Presence in social networks (social media)

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

Please note that user data may be processed outside the European Union. This may entail risks for the users, as it could, for example, make it more difficult to enforce the rights of the users.

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

For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the privacy policy and information provided by the operators of the respective networks.

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

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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

Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).

Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube: social network; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Opt- out: https://adssettings.google.com/authenticated.
  • Xing: social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

XXVI. Plugins and embedded functions and content

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

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

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

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

Purposes of processing: Provision of our online offer and user-friendliness.

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR).

Services used and service providers:

  • Font Awesome: Display of fonts and symbols; service provider: Fonticons, Inc. .6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; website: https://fontawesome.com/; privacy policy: https://fontawesome.com/privacy.

XXVII. Planning, organisation and support tools

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

In this context, personal data may be processed and stored on the servers of third party providers. This may affect various data which we process in accordance with this data protection declaration. This data may include in particular master data and contact details of users, data on procedures, contracts, other processes and their contents.

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

Information on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Persons concerned: Communication partners, users (e.g. website visitors, users of online services), customers.

Purposes of processing: Office and organisational procedures, contact requests and communication, coverage measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), target group formation, management and answering of enquiries, feedback (e.g. collection of feedback via online form), target group formation (determination of target groups relevant for marketing purposes or other output of content).

Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a. GDPR), fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 s. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 s. 1 lit. f. GDPR), fulfilment of contract and pre-contractual enquiries (EKD) (Section 6 No. 5 DSG-EKD).

Services used and service providers:

  • calendly: online scheduling; service provider: Calendly LLC, 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Website: https://calendly.com/de; Privacy Policy: https://calendly.com/pages/privacy.
  • HubSpot: social media publishing, reporting (e.g. traffic sources, access figures, web analytics), contact management (e.g. contact forms, direct communication and user segmentation), landing pages; service providers: HubSpot, Inc. 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; website: https://www.hubspot.de; privacy policy: https://legal.hubspot.com/de/privacy-policy.

XXVIII. Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.

XXIX. Amendment and update of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.

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

XXX. Rights of data subjects

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

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out pursuant to Art. 6 para. 1 lit. e. or lit. f. GDPR; this also applies to profiling based on these provisions. If personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right of withdrawal in case of consent: You have the right to revoke consents at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data and other information and a copy of the data in accordance with the legal provisions.
  • Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the legal provisions.
  • Right to deletion and restriction of processing: You have the right, in accordance with the legal provisions, to demand that data relating to you be deleted immediately, or alternatively, in accordance with the legal provisions, to demand restriction of the pro- cessing of the data.
  • Right to data transferability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal provisions or to request that it be transferred to another controller.
  • Complaints to the supervisory authority: You also have the right, in accordance with the legal provisions, to lodge a complaint with a supervisory authority, in particular in the member state in which you are habitually resident, your place of work or the place where the alleged infringement occurred, if you consider that the processing of personal data concerning you is in breach of the GDPR.

XXXI. Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Affiliate tracking: As part of “affiliate tracking”, links are logged with the help of which the linking websites refer users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called “affiliate links” and then take advantage of the offers (e.g. purchase goods or services). To this end, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take notice of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values which become part of the link or are stored in some other way, e.g. in a cookie. These values include in particular the initial website (“referrer”), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user as well as tracking specific values such as, for example, advertising material ID, partner ID and categorisations.
  • Controller: “Controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Conversion measurement: “Conversion measurement” (also known as “visitor action evaluation”) is a method of determining the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we are able to track whether the ads we have placed on other websites have been successful.
  • Cross-Device Tracking: “Cross-Device Tracking” is a form of tracking in which the behaviour and interest information of users is recorded in so-called profiles across devices by assigning users an online identifier. In this way, the user information can be analysed for marketing purposes independently of the browsers or devices used (e.g. mobile phones or desktop computers). With most providers, the online identification is not linked to clear data, such as names, postal or e-mail addresses.
  • Interest-based and behavioural marketing: We speak of “interest-based and/or behavioural marketing” when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • IP masking: “IP masking” is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, particularly in online marketing.
  • Location data: “Location data” is created when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WIFI or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Personal data: “Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.
  • Profiling: “Profiling” is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: “Reach measurement” (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: We speak of “remarketing” or “retargeting” when, for example, it is noted for advertising purposes which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Target group formation: We speak of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he/she viewed the products. “Lookalike Audiences” (or similar target groups) are again referred to when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.
  • Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.