Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: April 2, 2025

Table of Contents

Controller

Sören Rabsahl, Michael Hümke, Bernd Siemon
Group Factory Consulting GmbH i.G.
Katharina-Braeckeler-Str.11,
41462 Neuss

Authorized Representatives: Sören Rabsahl

E-mail address: consulting@group-factory.com

Imprint: https://group-factory.com/impressum/

Overview of Processing Activities

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

Types of Data Processed

  • Inventory data.
  • Employee data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Applicant data.
  • Image and/or video recordings.
  • Sound recordings.
  • Log data.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Interested parties.
  • Communication partners.
  • Users.
  • Applicants.
  • Business and contractual partners.
  • Depicted persons.
  • Third parties.
  • Whistleblowers.
  • Customers.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Reach measurement.
  • Office and organizational procedures.
  • Conversion measurement.
  • Organizational and administrative procedures.
  • Application procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Establishment and implementation of employment relationships.
  • Information technology infrastructure.
  • Whistleblower protection.
  • Financial and payment management.
  • Business processes and business management procedures.
  • Artificial Intelligence (AI).

Relevant Legal Bases

Relevant Legal Bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severe disability or ethnic origin) are requested from applicants as part of the application procedure so that the controller or the data subject can exercise his or her rights arising from labor law and the law of social security and social protection and comply with his or her obligations in this regard, their processing takes place in accordance with Art. 9 para. 2 lit. b. GDPR, in the case of protecting the vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services pursuant to Art. 9 para. 2 lit. h. GDPR. In the event of notification of special categories of data based on voluntary consent, their processing takes place on the basis of Art. 9 para. 2 lit. a. GDPR.
  • Processing of special categories of personal data relating to healthcare, occupation and social security (Art. 9 para. 2 lit. h) GDPR) – Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to a contract with a health professional.

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 Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz – BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transfer and automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

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

Security Measures

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

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, ensuring availability and separation relating to them. In addition, we have established procedures that ensure the exercise of data subject rights, the erasure of data and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of Personal Data

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

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which is recognizable from the postal address of the respective provider or if the data protection declaration expressly refers to the data transfer to third countries), this always takes place in accordance with the legal requirements.

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

This dual protection ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should there be any changes within the framework of the DPF, the standard contractual clauses will serve as a reliable fallback option. This ensures that your data is always adequately protected, even in the event of political or legal changes.

We will inform you about whether the individual service providers are certified according to the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

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

General Information on Data Storage and Deletion

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

In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are several details regarding the retention period or deletion periods of a date, the longest period shall always prevail.

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

We process data that is no longer retained for the originally intended purpose but due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Further information on processing operations, procedures and services:

  • Retention and deletion of data: The following general periods apply to retention and archiving under German law:
    • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the working instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
    • 8 years – Booking documents, such as invoices and expense receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
    • 6 years – Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating expense sheets, calculation documents, price tags, but also payroll documents insofar as they are not already booking documents and cash register receipts (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
    • 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries, based on past business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not data concerning you are being processed, and to access such data and further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right to obtain the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with legal requirements.
  • Right to erasure and restriction of processing: You have the right to request that data concerning you be erased without undue delay in accordance with legal requirements, or alternatively to request restriction of processing of the data in accordance with legal requirements.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you also have the right, in accordance with legal requirements, to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business Services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”), within the framework of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We use this data to fulfill our contractual obligations. These include in particular the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other performance disruptions. In addition, we use the data to protect our rights and for the purpose of the administrative tasks associated with these obligations as well as the organization of the company. We also process the data on the basis of our legitimate interests both in proper and economic business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or financial authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or within the framework of data collection, e.g. in online forms, by means of special labeling (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

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

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and e-mail addresses or telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category). Applicant data (e.g. personal details, postal and contact addresses, documents belonging to the application and the information contained therein, such as cover letters, curriculum vitae, certificates and other information provided by applicants with regard to a specific position or voluntarily about their person or qualification).
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Applicants.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Consulting: We process the data of our clients as well as prospective clients and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The procedures that belong to the framework and purposes of consulting include: Contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, collecting and managing client-specific information and data, scheduling and organizing appointments, providing consulting resources and materials, billing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

    If it is necessary for our performance of the contract, to protect vital interests or is required by law, or if the clients have given their consent, we disclose or transmit the data of the clients to third parties or agents, such as authorities, subcontractors or in the area of IT, office or comparable services, in compliance with the professional regulations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Recruiting services: Within the framework of our services, which include in particular the search for potential job candidates, contacting them and placing them, we process the data of the job candidates and the personal data of the potential employers or their employees.

    We process the information and contact details provided by the job candidates for the purposes of establishing, implementing and, if applicable, terminating a contract for job placement. In addition, we may ask interested parties at a later date, in accordance with legal requirements, for feedback on the success of our placement service.

    We process the data of both the job candidates and the employers in order to fulfill our contractual obligations in order to be able to process the requests for job placement submitted to us to the satisfaction of the parties involved.

    We may log the placement processes in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with the statutory accountability obligations (Art. 5 para. 2 GDPR). This information is stored for a period of three to four years in case we need to prove the original request (e.g. in order to be able to prove the authorization to contact the job candidates); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Business consulting: We process the data of our customers, clients as well as prospective clients and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The processed data, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.

    If it is necessary for our performance of the contract or is required by law, or if the customers have given their consent, we disclose or transmit the data of the customers to third parties or agents, such as authorities, courts or in the area of IT, office or comparable services, in compliance with the professional regulations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business Processes and Procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected is used to fulfill contractual obligations and to design operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organization of the company.

Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. The data will be deleted after the expiry of statutory retention periods or if the purpose of processing no longer applies. This also includes data that must be stored for longer periods due to tax law and statutory documentation obligations.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation); Contract data (e.g. subject matter of the contract, term, customer category); Log data (e.g. log files relating to logins or the retrieval of data or access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partners; Business and contractual partners; Third parties. Customers.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures; Business processes and business management procedures; Communication. Financial and payment management.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further information on processing operations, procedures and services:

  • Customer management and Customer-Relationship-Management (CRM): Procedures that are necessary within the framework of customer management and Customer-Relationship-Management (CRM) (e.g. customer acquisition in compliance with data protection regulations, measures to promote customer loyalty and loyalty, effective customer communication, complaint management and customer service taking data protection into account, data management and analysis to support the customer relationship, management of CRM systems, secure account management, customer segmentation and target group formation); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Contact management and contact maintenance: Procedures that are necessary within the framework of the organization, maintenance and security of contact information (e.g. the establishment and maintenance of a central contact database, regular updates of contact information, monitoring of data integrity, implementation of data protection measures, ensuring access controls, performing backups and restorations of contact data, training employees in the effective use of contact management software, regular review of communication history and adaptation of contact strategies); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Procedures that are necessary for the recording, management and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. posting and booking of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Providers and Services Used in the Course of Business

In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (referred to as “services” for short) in compliance with the statutory requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other employees).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures; Business processes and business management procedures; Conversion measurement (measurement of the effectiveness of marketing measures); Marketing. Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Provision of the Online Offer and Web Hosting

We process the data of users in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the browser or the user’s terminal device.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • STRATO: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: STRATO AG, Pascalstraße 10,10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.strato.de; Data protection declaration: https://www.strato.de/datenschutz/. Data processing agreement: Is provided by the service provider.

Use of Cookies

The term “cookies” refers to functions that store information on users’ end devices and read it out from them. Cookies can also be used in relation to various concerns, such as for the purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows. We use cookies in accordance with the statutory provisions. To this end, we obtain the consent of users in advance, if required. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. These include, for example, the storage of settings and the ensuring of the functionality and security of our online offer. Consent can be withdrawn at any time. We provide clear information about their scope and which cookies are used.

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

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes his or her end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be stored and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. within the framework of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their given consents at any time and also declare an objection to the processing in accordance with the statutory requirements, also by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which the consent of users is obtained for the use of cookies or for the procedures and providers mentioned in the context of the consent management solution. This procedure serves to obtain, log, manage and revoke consents, in particular in relation to the use of cookies and comparable technologies that are used to store, read and process information on the end devices of users. Within the framework of this procedure, the consents of users are obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consents. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with the statutory requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or his device. Unless specific information is available on the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. categories of cookies and/or service providers concerned) and information about the browser, the system and the end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Real Cookie Banner: Consent management: Procedure for obtaining, logging, managing and revoking consents, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing; Service provider: Execution on servers and/or computers under own data protection responsibility; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://devowl.io/de/wordpress-real-cookie-banner/. Data protection declaration: https://devowl.io/de/datenschutzerklaerung/.

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). The data of the readers are processed for the purposes of the publication medium only to the extent that it is necessary for its presentation and the communication between authors and readers or for reasons of security. Otherwise, we refer to the information on the processing of visitors to our publication medium within the framework of these data protection notices.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form); Provision of our online offer and user-friendliness. Security measures.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Retrieval of WordPress emojis and smileys: Retrieval of WordPress emojis and smileys – Within our WordPress blog, graphical emojis (or smileys), i.e. small graphical files that express feelings, are used for the purpose of efficiently integrating content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the browsers of the users; Service provider: Aut O’Mattic A8C Irland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://automattic.com; Data protection declaration: https://automattic.com/privacy; Data processing agreement: Is provided by the service provider. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Are provided by the service provider), Data Privacy Framework (DPF)Standard Contractual Clauses (Are provided by the service provider).
  • Akismet Anti-Spam Check: Akismet Anti-Spam Check – We use the “Akismet” service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment information is sent to a server in the USA, where it is analyzed and stored for comparison purposes for four days. If a comment has been classified as spam, the data will be stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used and the computer system and the time of entry.

    Users are welcome to use pseudonyms or refrain from entering their name or e-mail address. They can completely prevent the transmission of data by not using our comment system. That would be a pity, but unfortunately we see no alternatives that work just as effectively; Service provider: Aut O’Mattic A8C Irland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://automattic.com; Data protection declaration: https://automattic.com/privacy/; Data processing agreement: Is provided by the service provider. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Are provided by the service provider), Data Privacy Framework (DPF)Standard Contractual Clauses (Are provided by the service provider).

Contact and Inquiry Management

When contacting us (e.g. by post, contact form, e-mail, telephone or via social media) as well as within the framework of existing user and business relationships, the information of the requesting persons is processed insofar as this is necessary to answer the contact requests and any requested measures.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contacting and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Contact Form 7: Form. Website: https://contactform7.com/.

Artificial Intelligence (AI)

We use Artificial Intelligence (AI), whereby personal data is processed. The specific purposes and our interest in the use of AI are mentioned below. In accordance with the term “AI system” pursuant to Article 3 No. 1 of the AI Regulation, we understand AI to mean a machine-based system that is designed for operation with varying degrees of autonomy, can be adaptable after deployment, and generates results such as predictions, content, recommendations, or decisions from the inputs it receives, which can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for Artificial Intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human control, purpose limitation, data minimization and integrity, as well as confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can either be the consent of the data subjects or a legal permission.

When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with the applicable provisions. We also observe our obligations when using or operating the AI services obtained. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or legal authorization. We attach particular importance to transparency, fairness and the preservation of human control over AI-supported decision-making processes.

To protect the processed data, we implement appropriate and robust technical and organizational measures. These ensure the integrity and confidentiality of the processed data and minimize potential risks. Through regular reviews of the AI providers and their services, we ensure the ongoing compliance with current legal and ethical standards.

  • Types of data processed: Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g. website visitors, users of online services). Third parties.
  • Purposes of processing: Artificial Intelligence (AI).
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • ChatGPT: AI-based service designed to understand and generate natural language and related inputs and data, analyze information, and make predictions (“AI,” i.e., “Artificial Intelligence,” is to be understood in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openai.com/product; Data protection declaration: https://openai.com/de/policies/eu-privacy-policy. Objection option (Opt-Out): https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
  • DeepL: Translation of texts into various languages and provision of synonyms as well as context examples. Support for correcting and improving texts in various languages; Service provider: DeepL SE, Maarweg 165, 50825 Cologne, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.deepl.com; Data protection declaration: https://www.deepl.com/de/privacy. Data processing agreement: Is provided by the service provider.

Video Conferences, Online Meetings, Webinars and Screen Sharing

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

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the following personal data of the participants. The scope of the processing depends, on the one hand, on which data is required in the context of a specific conference (e.g. provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the data of the participants may also be processed by the conference platforms for security purposes or service optimization. The data processed includes data on the person (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the end devices of the participants, their operating system, the browser and its technical and linguistic settings, information on the content communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). Contents of the communications are encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, then further data can be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be communicated transparently to the participants in advance and they will be asked for their consent – if required.

Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the security and data protection settings that are optimal for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and personal protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, closing doors and using, as far as technically possible, the function to obscure the background). Links to the conference rooms as well as access data must not be passed on to unauthorized third parties.

Information on legal bases: If, in addition to the conference platforms, we also process the data of the users and ask the users for their consent to the use of the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing of discussion results, etc.). Otherwise, the data of the users will be processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Image and/or video recordings (e.g. photographs or video recordings of a person); Sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times.).
  • Data subjects: Communication partners; Users (e.g. website visitors, users of online services). Depicted persons.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication. Office and organizational procedures.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Web Analysis, Monitoring and Optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offer and can include behavior, interests or demographic information on the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used, or invite to reuse. It is also possible for us to understand which areas need optimization.

In addition to web analysis, we may also use testing methods to test and optimize different versions of our online offer or its components.

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

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

Information on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis for the data processing is the consent. Otherwise, the user 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.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section. 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 (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It serves to assign analysis information to an end device in order to recognize which content the users have accessed within one or more usage processes, which search terms they have used, have accessed them again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.
    Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log and store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: City (and the derived latitude and longitude of the city), continent, country, region, sub-continent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Data protection declaration: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google.com/adsprocessorterms), Data Privacy Framework (DPF)Standard Contractual Clauses ( https://business.safety.google.com/adsprocessorterms); Objection option (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing as well as the processed data).
  • Google as recipient of consent: The consent given by users in the context of a consent dialog (also known as “cookie opt-in/consent”, ‘cookie banner’, etc.) serves several purposes. On the one hand, it serves us to fulfill our obligation to obtain consent to the storage and reading of information on and from the user’s end device (in accordance with ePrivacy guidelines). On the other hand, it covers the processing of personal data of users in accordance with data protection requirements. In addition, this consent also applies to Google, as the company is required to obtain consent for personalized services under the Digital Markets Act. Therefore, we share the status of consents given by users with Google. Our consent management software informs Google whether consents have been given or not. The aim is to ensure that the consents given or not given by users are taken into account when using Google Analytics and when integrating functions and external services. In this way, users’ consents and their revocation can be dynamically adapted within the framework of Google Analytics and other Google services in our online offer and depending on the user’s selection; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de. Data protection declaration: https://policies.google.com/privacy.
  • Google Tag Manager: We use the Google Tag Manager, a software from Google that enables us to centrally manage so-called website tags via a user interface. Tags are small code elements on our website that serve to record and analyze visitor activities. This technology supports us in improving our website and the content offered on it. The Google Tag Manager itself does not create user profiles, does not store cookies with user profiles and does not perform independent analyses. Its function is limited to simplifying and making more efficient the integration and management of tools and services that we use on our website. Nevertheless, when using the Google Tag Manager, the IP address of the users is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set. However, this data processing only takes place when services are integrated via the Tag Manager. For more detailed information on these services and their data processing, please refer to the further sections of this data protection declaration; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Data protection declaration: https://policies.google.com/privacy; Data processing agreement:
    https://business.safety.google/adsprocessorterms. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Data Privacy Framework (DPF)Standard Contractual Clauses ( https://business.safety.google.com/adsprocessorterms).

Plug-ins and Embedded Functions as well as Content

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

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

Information on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis for the data processing is the permission. Otherwise, the user 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.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers etc.)).
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Yoast SEO: Optimization of websites for search engines; Service provider: Yoast B.V., Don Emanuelstraat 3, 6602 GX Wijchen, Netherlands; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://yoast.com/; Data protection declaration: https://yoast.com/privacy-notice/. Further information: Operation within its own hosting environment.

Processing of Data in the Context of Employment Relationships

In the context of employment relationships, the processing of personal data takes place with the aim of effectively designing the establishment, implementation and termination of such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relations.

The data processing covers various aspects, ranging from the initiation of the contract to the termination of the contract. Included are the organization and management of daily working hours, the management of access rights and permissions, as well as the handling of personnel development measures and employee discussions. The processing also serves the billing and the management of wage and salary payments, which are critical aspects of the contract implementation.

In addition, the data processing takes into account legitimate interests of the responsible employer, such as ensuring safety in the workplace or recording performance data for the evaluation and optimization of operational processes. Furthermore, the data processing includes the disclosure of employee data in the context of external communication and publication processes, where this is necessary for operational or legal purposes.

The processing of this data always takes place in compliance with the applicable legal framework, whereby the goal is always to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymization or deletion of data after fulfillment of the processing purpose or in accordance with statutory retention periods.

  • Types of data processed: Employee data (information on employees and other persons in an employment relationship).
  • Data subjects: Employees (e.g. employees, applicants, temporary staff and other employees).
  • Purposes of processing: Establishment and implementation of employment relationships (processing of employee data in the context of the establishment and implementation of employment relationships). Business processes and business management procedures.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to health care, occupation and social security (Art. 9 para. 2 lit. h) GDPR).

Application Procedure

The application procedure presupposes that applicants provide us with the data required for their assessment and selection. Which information is required results from the job description or, in the case of online forms, from the information provided there.

In principle, the required information includes information on the person, such as the name, the address, a contact option and the evidence of the qualifications necessary for a position. On request, we will also be happy to provide information on which information is required.

If available, applicants are welcome to submit their applications via our online form, which is encrypted according to the latest state of the art. Alternatively, it is also possible to send applications to us by e-mail. However, we would like to point out that e-mails on the Internet are generally not sent in encrypted form. Although e-mails are usually encrypted during transmission, this is not done on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the security of the application on its transmission path between the sender and our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may, in compliance with legal requirements, use applicant management or recruitment software and platforms and services from third-party providers.

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

Processing of special categories of data: Insofar as special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severe disability or ethnic origin) are requested from applicants or communicated by them within the framework of the application procedure, their processing takes place so that the controller or the data subject can exercise the rights arising from labor law and the law of social security and social protection and comply with his or her obligations in this regard, in the case of the protection of vital interests of the applicants or other persons or for the purposes of preventive health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnostics, for the provision of care or treatment in the health or social sector or for the management of systems and services in the health or social sector.

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

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, takes place on the basis of consent. The applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application procedure and that they can revoke their consent at any time for the future.

Duration of data retention in the applicant pool in months: 12

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation); Applicant data (e.g. information on the person, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letters, curriculum vitae, certificates as well as further information on their person or qualification communicated by applicants with regard to a specific position or voluntarily). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Applicants. Communication partners.
  • Purposes of processing: Application procedure (establishment and any later implementation as well as possible later termination of the employment relationship); Communication. Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Contact Form 7: Management of contact requests and communication; Service provider: Rock Lobster, LLC; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://contactform7.com/. Further information: Operation within its own hosting environment.

Data Protection Information for Whistleblowers

In this section, you will find information on how we handle data from persons who provide information (whistleblowers) as well as from affected and involved parties in the context of our whistleblower procedure. Our goal is to provide a straightforward and secure way to report possible misconduct by us, our employees or service providers, especially for actions that violate laws or ethical guidelines. We also ensure that reports are processed and handled appropriately.

Use of our online forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend that you access them in the so-called ‘incognito mode’ of your browser. Here’s how to open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

When you access our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your end device. This data is temporarily stored in a log file and automatically deleted after a maximum of 30 days.

The processing of the IP address serves technical and administrative purposes of establishing a connection to our website. It ensures the security, stability and functionality of the whistleblower form and is an important component of our measures to ensure confidential reporting.

The processing of the logged data is based on Article 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest lies in the need for security and the necessity to ensure the technical prerequisites for a smooth and trouble-free submission of information.

  • Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Employee data (information on employees and other persons in an employment relationship); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data subjects: Employees (e.g. employees, applicants, temporary staff and other employees); Third parties. Whistleblowers.
  • Purposes of processing: Whistleblower protection.
  • Retention and deletion: Deletion in accordance with the information in the “General Information on Data Storage and Deletion” section.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Amendment and Update

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

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us.

Definition of Terms

In this section, you will find an overview of the terms used in this data protection declaration. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to serve understanding.

  • Employees: Employees are defined as persons who are in an employment relationship, be it as employees, salaried employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee, which is determined by an employment contract or an agreement. It includes the obligation of the employer to pay the employee remuneration while the employee performs his or her work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the implementation, in which the employee performs his or her work, and the termination, when the employment relationship ends, be it by termination, termination agreement or otherwise. Employee data is all information that relates to these persons and is in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance appraisals.
  • Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities or systems by enabling unique assignment and communication.
  • Content data: Content data includes information that is generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content that is published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes telephone numbers, postal addresses and e-mail addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thus understand whether the advertisements placed by us on other websites were successful.
  • Artificial Intelligence (AI): The purpose of processing data by Artificial Intelligence (AI) includes the automated analysis and processing of user data in order to recognize patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of the data, the training and application of AI models and the continuous review and optimization of the results and takes place exclusively with the consent of the users or on the basis of legal permission bases.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Meta-data, also known as data about data, includes information that describes the context, origin and structure of other data. They may include information on file size, creation date, author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs that are used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and through which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists in using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. the interests in certain content or products, the click behavior on a website or the place of residence). Cookies and web beacons are often used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to create performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offer and may include the behavior or interests of the visitors in certain information, such as content of websites. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and for which content they are interested. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used in order to recognize returning visitors and thus obtain more accurate analyses of the use of an online offer.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it the collection, the evaluation, the storage, the transmission or the deletion.
  • Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is critical for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
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