Privacy Policy
Preamble
With the following privacy policy, we wish to inform you about the types of personal data (hereinafter also referred to simply as ‘data’) that we process, the purposes for which we do so, and the extent of such processing. This privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and, in particular, on our websites, in mobile applications and within external online platforms, such as our social media profiles (hereinafter collectively referred to as the “online offering”).
The terms used are not gender-specific.
Date: 22 August 2026
Table of Contents
Maxim Heidebrecht
Paderbornerstr 153
32760 Detmold, Germany
Email: maxbreht@gmail.com
Legal notice: https://maxbreht.com/legal-notice
Overview of data processing
The following overview summarises the types of data processed and the purposes of such processing, and identifies the data subjects.
Types of data processed
Relevant legal bases under the GDPR: Below is 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 country or ours, depending on where you or we are resident or have our registered office. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
Safety measures
In accordance with statutory requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of threats to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input of, disclosure of, and availability of the data, and ensuring its segregation. Furthermore, we have established procedures to ensure that data subjects’ rights are upheld, that data is deleted and that appropriate action is taken in the event of a data breach. Furthermore, we take the protection of personal data into account right from the development and selection of hardware, software and procedures, in accordance with the principle of data protection by design and through privacy-friendly default settings.
IP address truncation: Where IP addresses are processed by us or by the service providers and technologies we use, and where the processing of a full IP address is not necessary, the IP address is truncated (also known as ‘IP masking’). In this process, the last two digits, or the last part of the IP address following a full stop, are removed or replaced with placeholders. The purpose of truncating the IP address is to prevent, or make it significantly more difficult, to identify a person on the basis of their IP address.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect users’ data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is indicated by the presence of ‘HTTPS’ in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.
Transfer of personal data
In the course of our processing of personal data, such data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or individuals. Recipients of this data may include, for example, service providers commissioned to carry out IT tasks or providers of services and content integrated into a website. In such cases, we comply with the statutory requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.
International data transfers
Data processing in third countries: Where we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in connection with the use of third-party services or the disclosure or transfer of data to other persons, organisations or companies (which can be identified by the postal address of the relevant provider or where the privacy policy expressly refers to data transfers to third countries), this is always carried out in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the European Commission dated 10 July 2023. In addition, we have entered into standard contractual clauses with the relevant providers which comply with the European Commission’s requirements and set out contractual obligations to protect your data.
This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, whilst the Standard Contractual Clauses serve as an additional safeguard. Should any changes arise within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, 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 on the DPF and a list of certified companies can be found on the US Department of Commerce’s website at https://www.dataprivacyframework.gov/ (in English).
Appropriate safeguards apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found on the European Commission’s website:
https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
With the following privacy policy, we wish to inform you about the types of personal data (hereinafter also referred to simply as ‘data’) that we process, the purposes for which we do so, and the extent of such processing. This privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and, in particular, on our websites, in mobile applications and within external online platforms, such as our social media profiles (hereinafter collectively referred to as the “online offering”).
The terms used are not gender-specific.
Date: 22 August 2026
Table of Contents
- Preamble
- Data controller
- Overview of data processing activities
- Relevant legal bases
- Security measures
- Disclosure of personal data
- International data transfers
- General information on data storage and erasure
- Rights of data subjects
- Business services
- Provision of the online service and web hosting
- Use of cookies
- Contact and enquiry management
- Web analytics, monitoring and optimisation
- Social media presence
- Plug-ins, embedded functions and content
- Amendments and updates
- Definitions
Maxim Heidebrecht
Paderbornerstr 153
32760 Detmold, Germany
Email: maxbreht@gmail.com
Legal notice: https://maxbreht.com/legal-notice
Overview of data processing
The following overview summarises the types of data processed and the purposes of such processing, and identifies the data subjects.
Types of data processed
- Master data.
- Employee data.
- Payment data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Log data.
- Beneficiaries and clients.
- Employees.
- Prospective clients.
- Communication partners.
- Users.
- Business and contractual partners.
- Third parties.
- Whistleblowers.
- Provision of contractual services and fulfilment of contractual obligations.
- Communication.
- Security measures.
- Audience measurement.
- Tracking.
- Office and organisational procedures.
- Target group identification.
- Organisational and administrative procedures.
- Feedback.
- Marketing.
- Profiles containing user-related information.
- Provision of our online services and user-friendliness.
- IT infrastructure.
- Whistleblower protection.
- Public relations.
- Business processes and operational procedures.
Relevant legal bases under the GDPR: Below is 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 country or ours, depending on where you or we are resident or have our registered office. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6(1), first sentence, point (a) of the GDPR) – The data subject has given their consent to the processing of personal data relating to them for a specific purpose or for several specific purposes.
- Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) of the GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the data subject’s request.
- Legal obligation (Article 6(1), first sentence, point (c) of the GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data do not override those interests.
Safety measures
In accordance with statutory requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of threats to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input of, disclosure of, and availability of the data, and ensuring its segregation. Furthermore, we have established procedures to ensure that data subjects’ rights are upheld, that data is deleted and that appropriate action is taken in the event of a data breach. Furthermore, we take the protection of personal data into account right from the development and selection of hardware, software and procedures, in accordance with the principle of data protection by design and through privacy-friendly default settings.
IP address truncation: Where IP addresses are processed by us or by the service providers and technologies we use, and where the processing of a full IP address is not necessary, the IP address is truncated (also known as ‘IP masking’). In this process, the last two digits, or the last part of the IP address following a full stop, are removed or replaced with placeholders. The purpose of truncating the IP address is to prevent, or make it significantly more difficult, to identify a person on the basis of their IP address.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect users’ data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is indicated by the presence of ‘HTTPS’ in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.
Transfer of personal data
In the course of our processing of personal data, such data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or individuals. Recipients of this data may include, for example, service providers commissioned to carry out IT tasks or providers of services and content integrated into a website. In such cases, we comply with the statutory requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.
International data transfers
Data processing in third countries: Where we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in connection with the use of third-party services or the disclosure or transfer of data to other persons, organisations or companies (which can be identified by the postal address of the relevant provider or where the privacy policy expressly refers to data transfers to third countries), this is always carried out in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the European Commission dated 10 July 2023. In addition, we have entered into standard contractual clauses with the relevant providers which comply with the European Commission’s requirements and set out contractual obligations to protect your data.
This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, whilst the Standard Contractual Clauses serve as an additional safeguard. Should any changes arise within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, 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 on the DPF and a list of certified companies can be found on the US Department of Commerce’s website at https://www.dataprivacyframework.gov/ (in English).
Appropriate safeguards apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found on the European Commission’s website:
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 statutory provisions as soon as the underlying consents are withdrawn or there are no longer any legal grounds for processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply where statutory obligations or specific interests require the data to be retained or archived for a longer period.
In particular, data that must be retained for commercial or tax law reasons, or where storage is necessary for the purposes of legal proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.
Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
Where there are multiple specifications regarding the retention period or deletion deadlines for a particular piece of data, the longest period shall always apply. We process data that is no longer retained for its originally intended purpose, but rather due to legal requirements or other reasons, exclusively for the purposes that justify its retention.
Data retention and deletion: The following general time limits apply to data retention and archiving under German law:
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
We process the personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively referred to as ‘contractual partners’), for the purpose of establishing, implementing and managing contractual relationships and similar legal relationships. This also includes pre-contractual measures carried out upon request, as well as communication relating to the respective contractual relationship.
The processing serves, in particular, to fulfil our principal and ancillary contractual obligations. These include the provision of the agreed services, any obligations to provide updates and information, the handling of warranty claims and other service disruptions, the processing of revocations, terminations of continuing contractual relationships, rescissions, refunds, and the processing of other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.
In particular, we process master data such as name, address and, where applicable, company name; contact details such as email address and telephone number; contract and service data such as the subject matter of the contract, contract term, order or transaction number; usage and service data; payment and billing data; as well as the content and history of communications. Where necessary, we also process data disclosed or transmitted to us in the course of carrying out an order.
Furthermore, we process the data to safeguard our rights and to fulfil legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations and, where applicable, obligations to provide evidence and account for our actions. Furthermore, processing takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners from misuse and threats to data, confidential information and other legal interests. This may also involve the use of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other agents, insofar as this is necessary for the performance of the contract or to fulfil legal obligations.
Personal data will only be disclosed to third parties to the extent that this is necessary for the performance of a contract, for the implementation of pre-contractual measures, to safeguard legitimate interests or to fulfil legal obligations. We provide separate information regarding any further processing, in particular for marketing purposes, within this privacy policy.
We inform our contractual partners of the data required in each individual case at the time of data collection, for example by means of appropriate labelling on online forms or through personal contact.
Data is deleted as soon as it is no longer required for the aforementioned purposes and there are no statutory retention obligations preventing this. Statutory retention periods, in particular under commercial and tax law, may require data to be stored for a longer period. We delete data transmitted in connection with a specific order once the order has been completed and any retention periods have expired, provided there are no further statutory or contractual obligations to retain the data.
The legal basis for the processing is Article 6(1)(b) of the GDPR for the implementation of pre-contractual measures and the fulfilment of the relevant contractual relationship, as well as Article 6(1)(c) of the GDPR for the fulfilment of legal obligations. Where the processing is based on legitimate interests, it is carried out on the basis of Article 6(1)(f) of the GDPR. Where processing is based on Article 6(1)(f) of the GDPR, it is carried out to safeguard our legitimate interests in the proper and efficient organisation of our business, the internal administration and documentation of business transactions, the enforcement and defence of legal claims, the safeguarding of IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests consist, in particular, of ensuring secure and legally compliant business operations and safeguarding our ability to act as a business.
We delete personal data that we process in accordance with statutory provisions as soon as the underlying consents are withdrawn or there are no longer any legal grounds for processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply where statutory obligations or specific interests require the data to be retained or archived for a longer period.
In particular, data that must be retained for commercial or tax law reasons, or where storage is necessary for the purposes of legal proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.
Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
Where there are multiple specifications regarding the retention period or deletion deadlines for a particular piece of data, the longest period shall always apply. We process data that is no longer retained for its originally intended purpose, but rather due to legal requirements or other reasons, exclusively for the purposes that justify its retention.
Data retention and deletion: The following general time limits apply to data retention and archiving under German law:
- 10 years – retention period for books and records, annual accounts, inventories, management reports, opening balance sheets, as well as the working instructions and other organisational documents necessary for their understanding (§ 147 Abs. 1 Nr. 1 i.V.m. Abs. 3 AO, § 257 Abs. 1 Nr. 1 i.V.m. Abs. 4 HGB).
- 8 years – accounting documents, such as invoices and expense receipts (§ 147 Abs. 1 Nr. 4 und 4a i.V.m. Abs. 3 Satz 1 AO, § 14b Abs. 1 UStG sowie § 257 Abs. 1 Nr. 4 i.V.m. Abs. 4 HGB).
- 6 years – Other business records: incoming commercial or business correspondence, copies of outgoing commercial or business correspondence, other documents in so far as they are relevant for tax purposes, e.g. hourly pay slips, operational accounting sheets, costing documents, price labels, as well as payroll records, in so far as they are not already accounting vouchers, and till receipts (§ 147 Abs. 1 Nr. 2, 3, 5 i.V.m. Abs. 3 AO, § 257 Abs. 1 Nr. 2 u. 3 i.V.m. Abs. 4 HGB).
- 3 years – Data required to take into account potential warranty and compensation claims or similar contractual claims and rights, and to process related enquiries, based on previous business experience and standard industry practices, will be retained for the duration of the standard 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 are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. Where personal data relating to you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of your personal data for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
- Right of access: You have the right to request confirmation as to whether data relating to you is being processed, and to obtain access to this data, as well as further information and a copy of the data, in accordance with the statutory provisions.
- Right to rectification: In accordance with the statutory provisions, you have the right to request that data relating to you be completed or that any inaccurate data relating to you be rectified.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to request that data relating to you be erased without delay or, alternatively, in accordance with the statutory provisions, to request a restriction on the processing of the data.
- Right to data portability: You have the right to receive the data concerning you that you have provided to us, in accordance with the statutory requirements, in a structured, commonly used and machine-readable format, or to request that it be transferred to another data controller.
- Complaints to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged infringement occurred, if you consider that the processing of your personal data infringes the provisions of the GDPR.
We process the personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively referred to as ‘contractual partners’), for the purpose of establishing, implementing and managing contractual relationships and similar legal relationships. This also includes pre-contractual measures carried out upon request, as well as communication relating to the respective contractual relationship.
The processing serves, in particular, to fulfil our principal and ancillary contractual obligations. These include the provision of the agreed services, any obligations to provide updates and information, the handling of warranty claims and other service disruptions, the processing of revocations, terminations of continuing contractual relationships, rescissions, refunds, and the processing of other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.
In particular, we process master data such as name, address and, where applicable, company name; contact details such as email address and telephone number; contract and service data such as the subject matter of the contract, contract term, order or transaction number; usage and service data; payment and billing data; as well as the content and history of communications. Where necessary, we also process data disclosed or transmitted to us in the course of carrying out an order.
Furthermore, we process the data to safeguard our rights and to fulfil legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations and, where applicable, obligations to provide evidence and account for our actions. Furthermore, processing takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners from misuse and threats to data, confidential information and other legal interests. This may also involve the use of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other agents, insofar as this is necessary for the performance of the contract or to fulfil legal obligations.
Personal data will only be disclosed to third parties to the extent that this is necessary for the performance of a contract, for the implementation of pre-contractual measures, to safeguard legitimate interests or to fulfil legal obligations. We provide separate information regarding any further processing, in particular for marketing purposes, within this privacy policy.
We inform our contractual partners of the data required in each individual case at the time of data collection, for example by means of appropriate labelling on online forms or through personal contact.
Data is deleted as soon as it is no longer required for the aforementioned purposes and there are no statutory retention obligations preventing this. Statutory retention periods, in particular under commercial and tax law, may require data to be stored for a longer period. We delete data transmitted in connection with a specific order once the order has been completed and any retention periods have expired, provided there are no further statutory or contractual obligations to retain the data.
The legal basis for the processing is Article 6(1)(b) of the GDPR for the implementation of pre-contractual measures and the fulfilment of the relevant contractual relationship, as well as Article 6(1)(c) of the GDPR for the fulfilment of legal obligations. Where the processing is based on legitimate interests, it is carried out on the basis of Article 6(1)(f) of the GDPR. Where processing is based on Article 6(1)(f) of the GDPR, it is carried out to safeguard our legitimate interests in the proper and efficient organisation of our business, the internal administration and documentation of business transactions, the enforcement and defence of legal claims, the safeguarding of IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests consist, in particular, of ensuring secure and legally compliant business operations and safeguarding our ability to act as a business.
- Types of data processed: Master data (e.g. full name, residential address, contact details, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact details (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; prospective clients; business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures; business processes and business management procedures.
- Retention and erasure: Erasure in accordance with the information provided in the section ‘General information on data storage and erasure’.
- Legal basis: Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) of the GDPR); legal obligation (Article 6(1), first sentence, point (c) of the GDPR); legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
Further information on processing procedures, methods and services:
We process users’ data in order to provide them with our online services. To this end, 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.
The term „cookies" refers to functions that store and retrieve information on users’ devices. Cookies may also be used for various purposes, such as ensuring the functionality, security and user-friendliness of online services, as well as for analysing visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain users’ consent in advance where necessary. Where consent is not required, we rely on our legitimate interests. This applies where the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online service. Consent may be withdrawn at any time. We provide clear information on the scope of this and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. Where consent has been given, this serves as the legal basis. Where consent has not been given, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Retention period: With regard to the retention period, a distinction is made between the following types of cookies:
When you contact us (e.g. by post, via the contact form, by email, by telephone or via social media), as well as in the context of existing user and business relationships, the details provided by the enquirers are processed to the extent necessary to respond to the enquiries and to carry out any requested actions.
- Event management: We process the data of participants in the events, functions and similar activities that we offer or organise (hereinafter collectively referred to as “participants” and “events”) in order to enable them to take part in the events and make use of the services or promotions associated with their participation.
- Where, in this context, we process health-related data, religious, political or other special categories of data, this is done on the basis of public knowledge (e.g. in the case of thematically focused events, or where it serves the purposes of healthcare, safety, or is carried out with the consent of the data subjects).
- The required details are identified as such in the context of the conclusion of a contract, order or similar agreement and include the information necessary for the provision of services and invoicing, as well as contact details to enable any necessary consultations. Where we obtain access to information relating to end customers, employees or other individuals, we process such information in accordance with statutory and contractual requirements; legal bases: performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) of the GDPR).
We process users’ data in order to provide them with our online services. To this end, 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, types of devices and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, individuals involved). Log data (e.g. log files relating to logins, data retrieval or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
- Retention and erasure: Erasure in accordance with the information provided in the section ‘General information on data storage and erasure’.
- Legal basis: Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
- Provision of our online services on rented server space: To provide our online services, we use server space, computing capacity and software which we rent or otherwise obtain from a relevant server provider (also known as a ‘web host’); legal basis: legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
- Collection of access data and log files: Access to our online service is recorded in the form of so-called ‘server log files’. Server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, confirmation of successful access, browser type and version, the user’s operating system, the referrer URL (the page visited previously) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to prevent server overload (particularly in the event of malicious attacks, known as DDoS attacks), and, on the other hand, to ensure server capacity utilisation and stability; legal basis: legitimate interests (Article 6(1), first sentence, point (f) of the GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and is then deleted or anonymised. Data that must be retained for evidential purposes is exempt from deletion until the relevant incident has been fully resolved.
- Content Delivery Network: We use a ‘Content Delivery Network’ (CDN). A CDN is a service that enables the content of a website – in particular large media files such as graphics or programme scripts – to be delivered more quickly and securely via servers distributed across different regions and connected via the internet; Legal basis: Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
The term „cookies" refers to functions that store and retrieve information on users’ devices. Cookies may also be used for various purposes, such as ensuring the functionality, security and user-friendliness of online services, as well as for analysing visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain users’ consent in advance where necessary. Where consent is not required, we rely on our legitimate interests. This applies where the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online service. Consent may be withdrawn at any time. We provide clear information on the scope of this and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. Where consent has been given, this serves as the legal basis. Where consent has not been given, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Retention period: With regard to the retention period, a distinction is made between the following types of cookies:
- Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest once a user has left an online service and closed their device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device has been closed. This allows, for example, the login status to be saved and preferred content to be displayed immediately when the user visits a website again. Similarly, user data collected via cookies may be used for audience measurement. Unless we provide users with explicit information regarding the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period may be up to two years.
- Types of data processed: Meta data, communication data and procedural data (e.g. IP addresses, timestamps, identification numbers, individuals involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR). Consent (Article 6(1), first sentence, point (a) of the GDPR).
- Processing of cookie data on the basis of consent: We use a consent management solution through which users’ consent is obtained for the use of cookies or for the procedures and providers specified within the consent management solution. This procedure serves to obtain, log, manage and revoke consents, in particular with regard to the use of cookies and similar technologies employed to store, read and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management procedure. Users also have the option to manage and withdraw their consent. Consent declarations are stored to avoid having to request consent again and to be able to provide evidence of consent in accordance with legal requirements. Storage takes place on the server and/or in a cookie (a so-called ‘opt-in’ cookie) or by means of similar technologies, in order to be able to associate the consent with a specific user or their device. In the absence of specific information 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 together with the time of consent, details of the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the device used; legal basis: consent (Article 6(1), first sentence, point (a) of the GDPR).
When you contact us (e.g. by post, via the contact form, by email, by telephone or via social media), as well as in the context of existing user and business relationships, the details provided by the enquirers are processed to the extent necessary to respond to the enquiries and to carry out any requested actions.
- Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image-based messages and posts, as well as related information such as details of authorship or the time of creation). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, individuals involved).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form). Provision of our online services and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
- Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR). Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) of the GDPR).
- Contact form: When you contact us via our contact form, by email or through other communication channels, we process the personal data provided to us in order to respond to and deal with your enquiry. This generally includes details such as your name, contact details and, where applicable, any further information provided to us that is necessary for the appropriate handling of your enquiry. We use this data exclusively for the stated purpose of establishing contact and communication; legal bases: performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) of the GDPR), legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
Web analytics, monitoring and optimisation
Web analytics (also known as ‘reach measurement’) is used to analyse visitor traffic to our online platform and may include pseudonymous data on visitors’ behaviour, interests or demographic information, such as age or gender. With the help of reach analysis, we can, for example, identify at what times our online platform, its functions or its content are used most frequently, or encourage visitors to return. It also enables us to identify which areas require optimisation.
In addition to web analytics, we may also use testing procedures to, for example, test and optimise different versions of our online service or its components.
Unless otherwise stated below, profiles – that is, data aggregated to a specific usage session – may be created for these purposes, and information may be stored in a browser or on a device and subsequently retrieved. The data collected includes, in particular, websites visited and the elements used there, as well as technical information such as the browser used, the computer system used and details of usage times. Where 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.
In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. Generally speaking, no plaintext user data (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of users, but only the information stored in their profiles for the purposes of the respective processes.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. our interest in providing efficient, cost-effective 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.
Security measures: IP masking (pseudonymisation of the IP address);
Privacy Policy:https://business.safety.google/privacy/;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/;
Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms);
Option to opt out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of adverts: https://myadcenter.google.com/personalizationoff.
Further information: https://business.safety.google/adsservices/ (Types of processing and the data processed).
Social media presence
We maintain an online presence on social media platforms and, in this context, process user data in order to communicate with users active on these platforms or to provide information about us.
We would like to point out that user data may be processed outside the European Union in the course of this. This may entail risks for users, as it could, for example, make it more difficult to enforce their rights.
Furthermore, users’ data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users’ behaviour and the resulting interests. These profiles may in turn be used, for instance, to display advertisements within and outside the networks that are presumed to correspond to users’ interests. Consequently, cookies are usually stored on users’ computers, in which their usage behaviour and interests are recorded. In addition, data may also be stored in these user profiles regardless of the devices used by the users (particularly if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the options for objecting (opt-out), please refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the exercise of data subjects’ rights, we would also like to point out that these can be exercised most effectively with the service providers themselves. Only the service providers have access to the user data and are able to take appropriate action and provide information directly. Should you nevertheless require assistance, please do not hesitate to contact us.
Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
We incorporate functional and content elements into our online service which are sourced from the servers of their respective providers (hereinafter referred to as ‘third-party providers’). These may include, for example, graphics, videos or city maps (hereinafter collectively referred to as ‘content’).
This integration always requires the third-party providers of this content to process users’ IP addresses, as they would be unable to send the content to users’ browsers without an IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavour to use only such content whose respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. These ‘pixel tags’ enable information, such as visitor traffic on the pages of this website, to be analysed. This pseudonymous information may also be stored in cookies on the user’s device and may include, amongst other things, technical details about the browser and operating system, referring websites, the time of the visit and further details regarding the use of our online service; it may also be linked to such information from other sources.
Notes on legal bases: Where 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 on the basis of our legitimate interests (i.e. our interest in providing efficient, cost-effective 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.
Web analytics (also known as ‘reach measurement’) is used to analyse visitor traffic to our online platform and may include pseudonymous data on visitors’ behaviour, interests or demographic information, such as age or gender. With the help of reach analysis, we can, for example, identify at what times our online platform, its functions or its content are used most frequently, or encourage visitors to return. It also enables us to identify which areas require optimisation.
In addition to web analytics, we may also use testing procedures to, for example, test and optimise different versions of our online service or its components.
Unless otherwise stated below, profiles – that is, data aggregated to a specific usage session – may be created for these purposes, and information may be stored in a browser or on a device and subsequently retrieved. The data collected includes, in particular, websites visited and the elements used there, as well as technical information such as the browser used, the computer system used and details of usage times. Where 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.
In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. Generally speaking, no plaintext user data (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of users, but only the information stored in their profiles for the purposes of the respective processes.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. our interest in providing efficient, cost-effective 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, types of devices and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, individuals involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Audience measurement (e.g. access statistics, identification of returning visitors); profiles containing user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Article 6(1), first sentence, point (a) of the GDPR). Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
- Google Analytics: We use Google Analytics to measure and analyse the use of our online service on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It serves to associate analytical information with a device in order to identify which content users have accessed during one or more sessions, which search terms they have used, whether they have revisited that content, or how they have interacted with our online service. The time of use and its duration are also stored, as well as the sources from which users have been directed to our online service and technical details of their devices and browsers.
- In the process, pseudonymous user profiles are created using information derived from the use of various devices, which may involve the use of cookies. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides approximate geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based equivalents). For EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before being deleted immediately. It is not logged, is not accessible and is not used for any other purposes. When Google Analytics collects measurement data, all IP queries are carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6(1)(a) GDPR); website:
Security measures: IP masking (pseudonymisation of the IP address);
Privacy Policy:https://business.safety.google/privacy/;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/;
Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms);
Option to opt out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of adverts: https://myadcenter.google.com/personalizationoff.
Further information: https://business.safety.google/adsservices/ (Types of processing and the data processed).
Social media presence
We maintain an online presence on social media platforms and, in this context, process user data in order to communicate with users active on these platforms or to provide information about us.
We would like to point out that user data may be processed outside the European Union in the course of this. This may entail risks for users, as it could, for example, make it more difficult to enforce their rights.
Furthermore, users’ data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users’ behaviour and the resulting interests. These profiles may in turn be used, for instance, to display advertisements within and outside the networks that are presumed to correspond to users’ interests. Consequently, cookies are usually stored on users’ computers, in which their usage behaviour and interests are recorded. In addition, data may also be stored in these user profiles regardless of the devices used by the users (particularly if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the options for objecting (opt-out), please refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the exercise of data subjects’ rights, we would also like to point out that these can be exercised most effectively with the service providers themselves. Only the service providers have access to the user data and are able to take appropriate action and provide information directly. Should you nevertheless require assistance, please do not hesitate to contact us.
- Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image-based messages and posts, as well as related information such as details of authorship or the time of creation). Usage data (e.g. page views and time spent on the site, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via an online form). Public relations.
- Retention and erasure: Erasure in accordance with the information provided in the section ‘General information on data storage and erasure’.
- Legal basis: Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
- Instagram: a social network that allows users to share photos and videos, comment on and like posts, send messages, and follow profiles and pages; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: legitimate interests (Article 6(1), first sentence, point (f) of the GDPR); Website:https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for transfers to third countries: Data Privacy Framework (DPF).
- Facebook Pages: Profiles within the Facebook social network – The data controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data relating to visitors to our Facebook page (‘fan page’). This includes, in particular, information on user behaviour (e.g. content viewed or interacted with, actions taken) as well as device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us, via the ‘Page Insights’ service, with statistical analyses that give us an insight into how people interact with our page and its content. This is based on an agreement with Facebook (‘Information about Page Insights’): https://www.facebook.com/legal/terms/page_controller_addendum),which, amongst other things, sets out security measures and the exercise of data subjects’ rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users may therefore submit requests for access or erasure directly to Facebook. Users’ rights (in particular the right of access, erasure, objection and the right to lodge a complaint with a supervisory authority) remain unaffected by this. Joint controllership is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for any further processing, including any possible transfer to Meta Platforms Inc. in the USA; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: legitimate interests (Article 6(1), first sentence, point (f) of the GDPR); website:https://www.facebook.com;
Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- YouTube: social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Article 6(1), first sentence, point (f) of the GDPR); privacy policy: https://business.safety.google/privacy/; Basis for transfers to third countries: Data Privacy Framework (DPF). Right to object (opt-out): https://myadcenter.google.com/.
We incorporate functional and content elements into our online service which are sourced from the servers of their respective providers (hereinafter referred to as ‘third-party providers’). These may include, for example, graphics, videos or city maps (hereinafter collectively referred to as ‘content’).
This integration always requires the third-party providers of this content to process users’ IP addresses, as they would be unable to send the content to users’ browsers without an IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavour to use only such content whose respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. These ‘pixel tags’ enable information, such as visitor traffic on the pages of this website, to be analysed. This pseudonymous information may also be stored in cookies on the user’s device and may include, amongst other things, technical details about the browser and operating system, referring websites, the time of the visit and further details regarding the use of our online service; it may also be linked to such information from other sources.
Notes on legal bases: Where 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 on the basis of our legitimate interests (i.e. our interest in providing efficient, cost-effective 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, types of devices and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, individuals involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; audience measurement (e.g. access statistics, identification of returning visitors); tracking (e.g. interest-based/behavioural profiling, use of cookies); target group segmentation. Marketing.
- Retention and deletion: Deletion in accordance with the information provided in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Legal basis: Consent (Article 6(1), first sentence, point (a) of the GDPR). Legitimate interests (Article 6(1), first sentence, point (f) of the GDPR).
Further information on processing procedures, methods and services:
We ask that you check the content of our privacy policy regularly. We will amend the privacy policy as soon as changes to the data processing activities we carry out make this necessary. We will inform you as soon as the changes require action on your part (e.g. consent) or any other individual notification.
Where we provide addresses and contact details for companies and organisations in this privacy policy, please note that these details may change over time; we therefore ask you to check the information before making contact.
Definitions of Terms
This section provides an overview of the terms used in this privacy policy. Where these terms are defined by law, their statutory definitions shall apply. The explanations below, however, are primarily intended to aid understanding.
- Google Fonts (retrieved from the Google server): Retrieval of fonts (and icons) for the purpose of ensuring the technically secure, maintenance-free and efficient use of fonts and icons, taking into account their up-to-date status and loading times, their consistent display, and compliance with any licence restrictions. The font provider is provided with the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server belonging to the font provider in the USA – when visiting our website, users’ browsers send HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and, subsequently, the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server; and (3) the HTTP headers, including the user-agent, which describes the browser and operating system versions of website visitors, as well as the referrer URL (i.e. the web page on which the Google Font is to be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analysed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user-agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user-agent must match the font generated for the respective browser type. The user-agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the ‘Analytics’ page of Google Fonts. Finally, the referring URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to Google’s own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted adverts; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Article 6(1)(f) of the GDPR); Website: https://fonts.google.com/; Privacy policy: https://business.safety.google/privacy/; Basis for transfers to third countries: Data Privacy Framework (DPF). Further information: https://fonts.google.com/faq?hl=de#privacy.
- YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Article 6(1), first sentence, point (a) of the GDPR); website: https://www.youtube.com; privacy policy: https://business.safety.google/privacy/; Basis for transfers to third countries: Data Privacy Framework (DPF). Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of adverts: https://myadcenter.google.com/personalizationoff.
We ask that you check the content of our privacy policy regularly. We will amend the privacy policy as soon as changes to the data processing activities we carry out make this necessary. We will inform you as soon as the changes require action on your part (e.g. consent) or any other individual notification.
Where we provide addresses and contact details for companies and organisations in this privacy policy, please note that these details may change over time; we therefore ask you to check the information before making contact.
Definitions of Terms
This section provides an overview of the terms used in this privacy policy. Where these terms are defined by law, their statutory definitions shall apply. The explanations below, however, are primarily intended to aid understanding.
- Employees: The term ‘employees’ refers to individuals who are in a relationship of employment, whether as staff members, employees or in similar roles. A relationship of employment is a legal relationship between an employer and an employee, established by an employment contract or agreement. It entails the employer’s obligation to pay the employee remuneration in return for the employee’s work. The employment relationship comprises various phases, including the commencement phase, during which the employment contract is concluded; the performance phase, during which the employee carries out their work; and the termination phase, when the employment relationship ends, whether through dismissal, a mutual termination agreement or otherwise. Employee data refers to all information relating to these individuals and arising in the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
- Master data: Master data comprises essential information required for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, amongst other things, personal and demographic details such as names, contact details (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, organisations or systems by enabling unique identification and communication.
- Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
- Contact details: Contact details are essential pieces of information that enable communication with individuals or organisations. They include, amongst other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the manner in which data is processed, transmitted and managed. Meta-data, also known as data about data, comprises information that describes the context, origin and structure of other data. It may include details on file size, creation date, the author of a document and revision histories. Communication data records the exchange of information between users via various channels, such as email correspondence, call logs, social media messages and chat histories, including the individuals involved, timestamps and transmission routes. Process data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data encompasses a wide range of information that reveals how users utilise applications, which features they prefer, how long they spend on specific pages, and the paths they take when navigating through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital services
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”); a natural person is regarded as identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles containing user-related information: The processing of ‘profiles containing user-related information’, or ‘profiles’ for short, encompasses any form of automated processing of personal data that involves using such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the nature of the profiling, this may include various types of information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.), or to predict them (e.g. interests in specific content or products, clicking behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
- Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages and other details regarding the use or operation of a system. Log data is often used to analyse system issues, for security monitoring or to generate performance reports.
- Audience measurement: Audience measurement (also known as web analytics) is used to analyse visitor traffic to an online service and may include the behaviour or interests of visitors in relation to specific information, such as website content. With the help of web analytics, operators of online services can, for example, identify at what times users visit their websites and what content they are interested in. This enables them, for instance, to better tailor the content of their websites to the needs of their visitors. For the purposes of web analytics, pseudonymous cookies and web beacons are frequently used to recognise returning visitors and thus obtain more accurate analyses of the use of an online service.
- Tracking: The term ‘tracking’ refers to the ability to monitor users’ behaviour across multiple online services. As a rule, information relating to behaviour and interests in connection with the online services used is stored in cookies or on the servers of the providers of tracking technologies (known as ‘profiling’). This information can then be used, for example, to display adverts to users that are likely to match their interests.
- Data controller: The term ‘data controller’ refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: ‘Processing’ means any operation or set of operations which is carried out on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
- Contract data: Contract data refers to specific information relating to the formalisation of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment of contractual obligations and encompasses both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the nature of the agreed services or products, pricing arrangements, payment terms, termination rights, renewal options and any special terms or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
- Payment data: Payment data comprises all the information required to process payment transactions between buyers and sellers. This data is of crucial importance for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank account details, payment amounts, transaction dates, verification numbers and billing information. Payment data may also include information on payment status, chargebacks, authorisations and fees.
- Target audience creation: The term ‘Custom Audiences’ is used when target audiences are defined for advertising purposes, e.g. to display adverts. For example, based on a user’s interest in certain products or topics on the internet, it can be inferred that this user is interested in adverts for similar products or the online shop where they viewed the products. The term ‘Lookalike Audiences’ (or similar target groups) is used, on the other hand, when content deemed suitable is displayed to users whose profiles or interests are presumed to correspond to those of the users on whose profiles the Lookalike Audiences were based. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.