Privacy Policy
Privacy Policy
Preamble
With the following Privacy Policy, we would like to inform you about the types of your personal data (hereinafter also briefly referred to as "data") we process, for what purposes, and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
Status: April 19, 2026
Table of Contents
- Preamble
- Controller
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transfer of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of Data Subjects
- Business Services
- Payment Procedures
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Registration, Login, and User Account
- Contact and Inquiry Management
- Newsletter and Electronic Notifications
- Advertising Communication via Email, Mail, Fax or Telephone
- Web Analytics, Monitoring, and Optimization
- Online Marketing
- Presences on Social Networks (Social Media)
- Data Protection Information for Whistleblowers
- Amendment and Update
- Definitions of Terms
Controller
Kamptex by Björn Kampmann
Haarener Str. 51
52525 Heinsberg
Authorized representatives: Björn Kampmann
Email address: info@dornkind.de
Imprint: https://www.dornkind.de/pages/impressum
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of Data Processed
- Inventory data.
- Employee data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Employees.
- Prospects.
- Communication partners.
- Users.
- Business and contractual partners.
- Third parties.
- Whistleblowers.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target audience formation.
- Organizational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Whistleblower protection.
- Public relations.
- Sales promotion.
- Business processes and commercial procedures.
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 establishment. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the Privacy Policy.
- Consent (Art. 6 (1) sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 (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 (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 (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.
National Data Protection Regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This particularly includes the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG), which contains specific provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transfer as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Security Measures
In accordance with legal requirements and taking into account the state of the art, implementation costs, the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
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 their separation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized 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 information transferred between the website or app and the user's browser (or between two servers), thereby protecting 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 indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transfer of Personal Data
In the course of our processing of personal data, it may happen that these are transferred to other entities, companies, legally independent organizational units or persons, or are disclosed to them. Recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data 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 using third-party services or disclosing or transferring data to other persons, entities, or companies (which can be identified by the postal address of the respective provider or if the data protection declaration explicitly refers to data transfer to third countries), this is always done in compliance with legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. Additionally, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This dual protection ensures comprehensive safeguarding of your data: The DPF forms the primary layer of protection, while the standard contractual clauses serve as an additional security measure. Should there be any changes within the DPF framework, the standard contractual clauses will act as a reliable fallback option. This way, we ensure that your data always remains adequately protected, even in the event of political or legal changes.
For individual service providers, we will inform you whether they are DPF-certified and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, explicit consents, 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 legal provisions as soon as underlying consents are revoked or no further legal basis for processing exists. This applies to cases where the original processing purpose ceases to apply or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax 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 privacy notices contain additional information on data retention and deletion that specifically applies to certain processing operations.
If there are multiple specifications for the retention period or deletion periods of data, the longest period is always decisive. Data that is no longer used for its originally intended purpose, but is retained due to legal requirements or other reasons, will be processed by us exclusively for the reasons justifying its retention.
Data retention and deletion: 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, as well as 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 receipts, 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: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents, insofar as they are relevant for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already booking receipts and till rolls (§ 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 customary industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Start of period at the end of the year: If a period does not explicitly 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 where data is stored, the event triggering the period is the effective date of termination or other ending of the legal relationship.
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 Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you shall 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 your given consents at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with legal requirements, to demand the completion of incomplete data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be erased without undue delay, or, alternatively, to demand a restriction of the processing of the data in accordance with legal requirements.
- Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in accordance with legal requirements.
- Right to lodge a complaint with 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, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Business Services
We process personal data of our contractual and business partners, such as customers, clients, prospects, suppliers, and other cooperation partners (collectively "contractual partners"), for the initiation, execution, and processing of contractual relationships and similar legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.
The processing serves in particular to fulfill our primary and secondary contractual obligations. This includes the provision of agreed services, any update and information obligations, the handling of warranty and other service disruptions, the processing of cancellations, terminations of continuing obligations, reversals, refunds, and the processing of other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.
In particular, master data such as name, address and, if applicable, company, contact data such as email address and telephone number, contract and service data such as contract subject, contract term, order or transaction number, usage and service data, payment and billing data as well as communication content and histories are processed. To the extent necessary, we also process data that is disclosed or transmitted to us in the course of carrying out an order.
Furthermore, we process data to safeguard our rights and to comply with legal obligations. This includes, in particular, commercial and tax law retention obligations, documentation obligations and, if applicable, proof and accountability obligations. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in the protection of our business operations and our contractual partners against misuse, endangerment of data, secrets and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for the performance of the contract or for the fulfillment of legal obligations.
Personal data will only be passed on to third parties if this is necessary for the performance of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests or for the fulfillment of legal obligations. We will inform you separately about further processing, in particular for marketing purposes, within the framework of this data protection declaration.
We will inform the contractual partners about which data are required in individual cases as part of the data collection, for example in online forms through appropriate marking or in personal contact.
The data will be deleted as soon as they are no longer required for the aforementioned purposes and no legal retention obligations prevent deletion. Legal retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific order will be deleted by us after completion of the order and expiry of any retention periods, unless there are further legal or contractual obligations to store them.
The legal basis for processing is Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6 para. 1 lit. f GDPR. Insofar as the processing is based on Art. 6 para. 1 lit. f GDPR, it takes place to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business processes, the enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and development of our business operations. These interests consist in particular in ensuring a secure and legally compliant business operation as well as in maintaining our entrepreneurial capacity to act.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject matter of contract, term, customer category); Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, involved persons).
- Persons affected: Service recipients and clients; prospective customers. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and economic procedures.
- Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
- Legal bases: Performance of 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 notes on processing processes, procedures and services:
- Online shop, order forms, e-commerce and performance fulfillment: We process our customers' data to enable them to select, purchase or order the chosen products, goods and associated services, as well as their payment and provision, delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the order or comparable purchase process and includes the information required for delivery, provision and billing, as well as contact information to enable any inquiries; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Payment procedures
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to the data subjects and use other service providers in addition to banks and credit institutions for this purpose (collectively "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected from unauthorized access during transmission.
The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the entered data is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative notification of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this, we refer to the terms and conditions and the data protection notices of the payment service providers.
For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed on their respective websites or transaction applications. We also refer to these for further information and for asserting rights of revocation, information and other data subject rights.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of contract, term, customer category); Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, involved persons). Contact data (e.g., postal and email addresses or telephone numbers).
- Persons affected: Service recipients and clients; business and contractual partners. Prospective customers.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and economic procedures.
- Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
- Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures and services:
- American Express: Payment services (technical integration of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.americanexpress.com/de/. Privacy policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/.
- Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Pay: Payment services (technical integration of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://pay.google.com/intl/de_de/about/. Privacy policy: https://policies.google.com/privacy.
- Klarna: Payment services (technical integration of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy policy: https://www.klarna.com/de/datenschutz.
- Mastercard: Payment services (technical integration of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
- PayPal: Payment services (technical integration of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
- Stripe: Payment services (technical integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
- Visa: Payment services (technical integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO); Website: https://www.visa.de. Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offering and web hosting
We process user data to make our online services available to them. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the users' browser or end device.
- Types of data processed: Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, involved persons); Log data (e.g., log files concerning logins or data retrieval or access times). Content data (e.g., textual or pictorial messages and contributions and information relating to them, such as authorship or time of creation).
- Persons affected: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Retention and deletion: Deletion according to 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 notes on processing processes, procedures and services:
- Provision of online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files can include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, 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, for example to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and 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 are exempt from deletion until the final clarification of the respective incident.
- Email sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of recipients and senders as well as further information concerning the email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data can also be processed for the purpose of SPAM detection. Please note that emails are generally not sent encrypted on the internet. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume responsibility for the transmission path of emails between the sender and the reception on our server; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Use of Cookies
The term "cookies" refers to functions that store and retrieve information from users' end devices. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online offerings, as well as for analyzing visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain the users' consent in advance, if necessary. If consent is not required, we rely on our legitimate interests. This applies when the storage and retrieval of information are essential to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked 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 duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., in the context of obtaining consent), they should assume that these are permanent and the storage duration 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 object to the processing in accordance with legal requirements, including via their browser's privacy settings.
- Types of data processed: Meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, involved persons).
- Persons affected: Users (e.g., website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing procedures, procedures and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure serves to obtain, log, manage, and revoke consents, particularly concerning the use of cookies and similar technologies that are used to store, read out, and process information on users' end devices. Within the framework of this procedure, users' consents for the use of cookies and the associated processing of information, including the specific processing operations and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The declarations of consent are stored to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. If no specific information is available about the providers of consent management services, the following general information applies: The storage duration of the consent is up to two years. A pseudonymized user identifier is created, which is stored together with the time of consent, information about the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and end device used; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Registration, Login, and User Account
Users can create a user account. During registration, users are informed of the required mandatory information and processed for the purpose of providing the user account based on the fulfillment of contractual obligations. The processed data includes, in particular, login information (username, password, and an email address).
In the context of using our registration and login functions, as well as using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in protection against abuse and other unauthorized use. This data is generally not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions and information relating to them, such as 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). Log data (e.g., log files concerning logins or data retrieval or access times).
- Persons affected: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organizational and administrative procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion". Deletion upon termination.
- Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Registration with real name: Due to the nature of our community, we ask users to use our service only using real names. This means that the use of pseudonyms is not permitted; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- User profiles are not public: User profiles are not publicly visible or accessible.
- Deletion of data upon termination: If users have terminated their user account, their data related to the user account will be deleted, subject to legal permission, obligation, or consent of the users; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- No retention obligation for data: It is up to the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the contract period; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Contact and Inquiry Management
When contacting us (e.g., by mail, contact form, email, telephone, or via social media) and within the framework of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions and information relating to them, such as authorship or time of creation). Meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, involved persons).
- Persons affected: Communication partners.
- Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
- Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Contact form: When contacting us via our contact form, by email, or other communication channels, we process the personal data transmitted to us to respond to and process the respective inquiry. This usually includes details such as name, contact information, and, if applicable, other information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal basis: Performance of 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).
Newsletter and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the users' consent. To subscribe to our newsletter, providing your email address is usually sufficient. However, to provide you with personalized service, we may ask for your name for a personal address in the newsletter or for further information, if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, to be able to prove a previously given consent. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is simultaneously confirmed. In the case of obligations to permanently comply with objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called "blocklist").
The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider with the sending of emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Content:
Information about us, our services, promotions, and offers.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, involved persons). 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).
- Persons affected: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Direct marketing (e.g., via email or postal mail). Provision of contractual services and fulfillment of contractual obligations.
- Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Right to object (Opt-Out): You can unsubscribe from our newsletter at any time, i.e., revoke your consents, or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email, for this purpose.
Further information on processing processes, procedures and services:
- Measurement of open and click rates: The newsletters contain a "web beacon", i.e. a pixel-sized file that is retrieved from our server or that of a shipping service provider, if we use one, when the newsletter is opened. As part of this retrieval, technical information such as browser and system details, as well as your IP address and the time of retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Prerequisite for using free services: Consent to send mailings may be made a prerequisite for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
Promotional communication via email, post, fax or telephone
We process personal data for the purpose of promotional communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke their given consents at any time or to object to promotional communication at any time free of charge via the contact option mentioned above.
After revocation or objection, we store the data necessary to prove previous authorization for contact or sending for up to three years after the end of the year of revocation or objection, based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the users' revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, name).
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., textual or pictorial messages and posts, as well as related information such as authorship details or creation time).
- Affected individuals: Communication partners.
- Purposes of processing and legitimate interests: Direct marketing (e.g., via email or postal mail); marketing. Sales promotion.
- Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
- Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).
Web analysis, monitoring, and optimization
Web analysis (also referred to as "reach measurement") is used to evaluate the visitor flows of our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify when our online offering or its functions or content are most frequently used, or invite reuse. It also enables us to understand which areas require optimization.
In addition to web analysis, we may also use testing procedures to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles—i.e., data summarized for a usage process—may be created for these purposes, and information may be stored in a browser or on an end device and then read out. The data 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 details on usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.
Furthermore, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. Generally, within the scope of web analysis, A/B testing, and optimization, no clear data of users (such as email addresses or names) are stored, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, 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 duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Affected individuals: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
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Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain unique data, such as names or email addresses. It serves to assign analysis information to an end device to recognize which content users have accessed within one or various usage processes, which search terms they have used, re-accessed, or interacted with our online offering. Likewise, the time and duration of use are stored, as well as the sources of users referring to our online offering and technical aspects of their end devices and browsers.
Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log and store individual IP addresses for EU users. However, Analytics provides coarse geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, sub-continent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before 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 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out option: 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 and processed data). -
Google Tag Manager: We use Google Tag Manager, a Google software that allows us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that are used to record and analyze visitor activities. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, does not store cookies with user profiles, and does not carry out 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 Google Tag Manager, the user's IP address is transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in this process. However, this data processing only occurs when services are integrated via Tag Manager. For more precise information on these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data Processing Agreement:
https://business.safety.google/adsprocessorterms. Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).
Online Marketing
We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which information relevant to the display of the aforementioned content about the user is stored. This may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information, such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, within the scope of online marketing procedures, no clear user data (such as email addresses or names) are stored, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual user identity, but only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or by similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily when users are, for example, members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users can make additional arrangements with the providers, for example, by giving consent during registration.
We generally only gain access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract conclusion with us. The conversion measurement is used solely for the success analysis of our marketing measures.
Unless otherwise stated, please assume that cookies used are stored for a period of two years.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Information on revocation and objection:
We refer to the data protection notices of the respective providers and the objection options provided for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, there is the possibility, on the one hand, to disable cookies in your browser settings. However, this may restrict functions of our online offering. We therefore also recommend the following opt-out options, which are offered collectively for the respective areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-regional: https://optout.aboutads.info.
- Types of data processed: Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Affected individuals: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest/behavioral profiling, use of cookies); audience building; marketing; profiles with user-related information (creation of user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
- Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Google Ads and Conversion Measurement: Online marketing procedure for the purpose of placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e., whether users have used them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR), Legitimate Interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for Third-Country Transfers: Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Social Media Presences
We maintain online presences within social networks and, in this context, process user data to communicate with active users there or to offer information about ourselves.
We point out that user data may be processed outside the European Union. This may pose risks for users, for example, because the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These may in turn be used to display advertisements within and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on users' computers, in which the usage behavior and interests of the users are stored. In addition, data independent of the devices used by users can also be stored in the usage profiles (especially if they are members of the respective platforms and logged in there).
For a detailed description of the respective processing methods and objection options (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also, in the case of information requests and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need help, please contact us.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or visual messages and posts, as well as related information such as authorship details or creation time). 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).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
- Retention and deletion: Deletion in accordance with the information in the "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:
- Instagram: Social network that allows sharing photos and videos, commenting and liking posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
- Facebook Pages: Profiles within the Facebook social network - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook Page ("Fanpage"). This particularly includes information about user behavior (e.g., viewed or interacted content, actions performed) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the "Page Insights" service, which provide insights into how people interact with our page and its content. The basis for this is an agreement with Facebook ("Information on Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore address requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including a possible transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
Data Protection Information for Whistleblowers
In this section, you will find information about how we handle data from individuals who provide information (whistleblowers), as well as affected and involved parties within the framework of our whistleblowing procedure. Our goal is to provide an uncomplicated and
Legal bases (Germany): Insofar as we process data for the fulfillment of our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for the processing is Article 6 (1) sentence 1 lit. c) GDPR and, in the case of special categories of personal data, Art. 9 (2) lit. g) GDPR, § 22 BDSG, each in conjunction with § 10 HinSchG. This refers to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal tasks and, in the event of the use of data collected in the reporting procedure, the taking of further
Types of data processed: In the context of receiving and processing reports as well as in the subsequent whistleblower procedure, we may collect various data. These include in particular the data provided by a whistleblower, such as: Name, contact details and whereabouts of the person making the report, names and data of possible witnesses or persons affected by the report, names and data of the persons against whom the report is directed, data about the alleged misconduct, further relevant details, if provided by the
Special categories of personal data: It may happen that we collect special types of personal data in the course of our activities, especially when these are communicated by a whistleblower. These include: Health-related data of a person, data on racial or ethnic origin
Using 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 accessing them in your browser's 'incognito mode'. 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
Providing names: You have the option to submit reports anonymously. However, unless prohibited by national laws, we recommend providing your name and contact details. This allows us to follow up on the report more effectively and, if necessary, contact you directly.
If you provide your name and contact details, your identity will be kept strictly confidential
Disclosure of data to third parties: Data related to the submitted reports will only be disclosed to third parties by us under certain circumstances. This happens either a) if you have given us your explicit consent, or b) if there is a legal obligation to disclose the data. Possible third parties include public authorities, government, regulatory, or tax authorities if the disclosure is necessary to fulfill a legal or regulatory obligation. Furthermore, we may engage lawyers and other expert advisors within the framework of legal provisions. These are authorized to investigate alleged misconduct and take necessary measures after an investigation, such as initiating disciplinary or judicial proceedings. In addition, carefully selected and monitored service providers may receive data for these purposes (e.g., operators of a web-based reporting system). However, these service providers are contractually obliged to comply with applicable data protection regulations within the framework of order processing.
Data retention and deletion: Personal data will only be processed for as long as necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. In certain situations,
Technical and organizational measures: We have implemented the necessary contractual, technical and organizational measures to ensure the security of all data we process. This data is processed exclusively for the stated purposes. Incoming reports are handled by specially designated
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number,); Employee data (information about employees and other individuals in a); Contact data (e.g., postal and email addresses or); Content data (e.g., textual or visual messages and posts, as well as related information, such as authorship details). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with).
- Data Subjects: Employees (e.g., salaried employees, applicants, temporary staff, and other); Third parties. Whistleblowers.
- Purposes of Processing and Legitimate Interests: 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).
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation from your side (e.g., consent) or any other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we ask you to verify the information before making contact.
Definitions
In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.
- Employees: Employees are defined as individuals in an employment relationship, whether as staff, salaried employees, or in similar positions. An employment relationship is a legal bond between an employer and an employee, established by an employment contract or agreement. It involves the employer's obligation to pay the employee remuneration, while the employee provides their work performance. The employment relationship encompasses various phases, including its establishment, when the employment contract is concluded, its execution, during which the employee carries out their work activities, and its termination, when the employment relationship ends, whether by notice, mutual agreement, or otherwise. Employee data includes all information relating to these individuals and relevant to their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data, and performance reviews.
- Inventory Data: Inventory data comprises essential information necessary for the identification and management of contract partners, user accounts, profiles, and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems, enabling unique assignment and communication.
- Content Data: Content data includes information generated in the course of creating, editing, and publishing all types of content. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content 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 individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.
- Conversion Measurement: Conversion measurement (also referred to as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites where the marketing measures take place and then accessed again on the target website. For example, we can thus track whether the advertisements we placed on other websites were successful.
- Meta, Communication, and Process Data: Meta, communication, and process data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, author of a document, and revision histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the parties involved, timestamps, and transmission paths. Process data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit trails used for tracing and verifying operations.
- Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information that shows how users utilize applications, which features they prefer, how long they stay on certain pages, and through which paths they navigate an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, 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 ("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, comprises any type of automated processing of personal data consisting of the use of these personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.) to analyze, assess or predict them (e.g., interests in certain content or products, click behavior on a website, or location). 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 for analyzing system problems, security monitoring, or generating performance reports.
- Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, determine at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purpose of reach analysis, pseudonymized cookies and web beacons are often used to recognize recurring visitors and thus obtain more accurate analyses of the use of an online offering.
- Tracking: "Tracking" refers to the ability to monitor user behavior across multiple online offerings. Typically, behavioral and interest information regarding the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
- Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, evaluation, storage, transmission, or deletion.
- Contract Data: Contract data are specific information relating to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged, or sold. This data category 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 contract start and end dates, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions 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 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.
- Audience Building: Audience building (also known as "Custom Audiences") refers to the creation of target groups for advertising purposes, e.g., for displaying advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. "Lookalike Audiences" (or similar target groups) refer to when content deemed suitable is shown to users whose profiles or interests are presumably similar to the users for whom the profiles were created. Cookies and web beacons are typically used for building Custom Audiences and Lookalike Audiences.