Privacy Policy

Table of contents

• Privacy Policy Introduction and Overview
• Scope
• Legal bases
• Contact details of the data protection controller
• Storage Period
• Rights in accordance with the General Data Protection Regulation
• Data transfer to third countries
• Security of data processing operations
• Communications
• Cookies
• Application Data
• Customer Data
• Registration
• Web hosting
• Web Analytics
• Email-Marketing
• Social Media
• Content Delivery Networks
• Cookie Consent Management Platform
• Payment providers
• Online Map Services Introduction
• Explanation of the terminology used
• Closing Remarks

Privacy Policy Introduction and Overview

We have written this privacy policy (version 17.03.2025-122965942) in order to explain to you, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 and applicable national laws, which personal data (data for short) we as the controller – and the processors commissioned by us (e.g. providers) – process, will process in the future and what legal options you have. The terms used are to be considered gender-neutral.
In short: We provide you with comprehensive information about any of your personal data we process.

Privacy policies usually sound very technical and use legal terminology. However, this privacy policy is intended to describe the most important things to you as simply and transparently as possible. So long as it aids transparency, technical terms are explained in a reader-friendly manner, links to further information are provided and graphics are used. We are thus informing in clear and simple language that we only process personal data in the context of our business activities if there is a legal basis for it. This is certainly not possible with brief, unclear and legal-technical statements, as is often standard on the internet when it comes to data protection. I hope you find the following explanations interesting and informative. Maybe you will also find some information that you have not been familiar with.
If you still have questions, we kindly ask you to contact the responsible body named below or in the imprint, follow the existing links and look at further information on third-party sites. You can of course also find our contact details in the imprint.

Scope

This privacy policy applies to all personal data processed by our company and to all personal data processed by companies commissioned by us (processors). With the term personal data, we refer to information within the meaning of Article 4 No. 1 GDPR, such as the name, email address and postal address of a person. The processing of personal data ensures that we can offer and invoice our services and products, be it online or offline. The scope of this privacy policy includes:

• all online presences (websites, online shops) that we operate
• Social media presences and email communication
• mobile apps for smartphones and other devices

In short: This privacy policy applies to all areas in which personal data is processed in a structured manner by the company via the channels mentioned. Should we enter into legal relations with you outside of these channels, we will inform you separately if necessary.

Legal bases

In the following privacy policy, we provide you with transparent information on the legal principles and regulations, i.e. the legal bases of the General Data Protection Regulation, which enable us to process personal data.
Whenever EU law is concerned, we refer to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can of course access the General Data Protection Regulation of the EU online at EUR-Lex, the gateway to EU law, at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679.

We only process your data if at least one of the following conditions applies:

1. Consent (Article 6 Paragraph 1 lit. a GDPR): You have given us your consent to process data for a specific purpose. An example would be the storage of data you entered into a contact form.
2. Contract (Article 6 Paragraph 1 lit. b GDPR): We process your data in order to fulfill a contract or pre-contractual obligations with you. For example, if we conclude a sales contract with you, we need personal information in advance.
3. Legal obligation (Article 6 Paragraph 1 lit. c GDPR): If we are subject to a legal obligation, we will process your data. For example, we are legally required to keep invoices for our bookkeeping. These usually contain personal data.
4. Legitimate interests (Article 6 Paragraph 1 lit. f GDPR): In the case of legitimate interests that do not restrict your basic rights, we reserve the right to process personal data. For example, we have to process certain data in order to be able to operate our website securely and economically. Therefore, the processing is a legitimate interest.

Other conditions such as making recordings in the interest of the public, the exercise of official authority as well as the protection of vital interests do not usually occur with us. Should such a legal basis be relevant, it will be disclosed in the appropriate place.

In addition to the EU regulation, national laws also apply:

• In Austria this is the Austrian Data Protection Act (Datenschutzgesetz), in short DSG.
• In Germany this is the Federal Data Protection Act (Bundesdatenschutzgesetz), in short BDSG.

Should other regional or national laws apply, we will inform you about them in the following sections.

Contact details of the data protection controller

If you have any questions about data protection or the processing of personal data, you will find below the contact details of the controller in accordance with Article 4(7) of the EU General Data Protection Regulation (GDPR):
Mag. Dr. Imran Daris Mehic , MBA
Braunhierschengasse 12-20/1
1150 Wien

E-Mail: info@sultan-drinks.com

Storage Period

It is a general criterion for us to store personal data only for as long as is absolutely necessary for the provision of our services and products. This means that we delete personal data as soon as any reason for the data processing no longer exists. In some cases, we are legally obliged to keep certain data stored even after the original purpose no longer exists, such as for accounting purposes.

If you want your data to be deleted or if you want to revoke your consent to data processing, the data will be deleted as soon as possible, provided there is no obligation to continue its storage.

We will inform you below about the specific duration of the respective data processing, provided we have further information.

Rights in accordance with the General Data Protection Regulation

In accordance with Articles 13, 14 of the GDPR, we inform you about the following rights you have to ensure fair and transparent processing of data:

• According to Article 15 DSGVO, you have the right to information about whether we are processing data about you. If this is the case, you have the right to receive a copy of the data and to know the following information:
  • for what purpose we are processing;
  • the categories, i.e. the types of data that are processed;
  • who receives this data and if the data is transferred to third countries, how security can be guaranteed;
  • how long the data will be stored;
  • the existence of the right to rectification, erasure or restriction of processing and the right to object to processing;
  • that you can lodge a complaint with a supervisory authority (links to these authorities can be found below);
  • the origin of the data if we have not collected it from you;
  • Whether profiling is carried out, i.e. whether data is automatically evaluated to arrive at a personal profile of you.
• You have a right to rectification of data according to Article 16 GDPR, which means that we must correct data if you find errors.
• You have the right to erasure (“right to be forgotten”) according to Article 17 GDPR, which specifically means that you may request the deletion of your data.
• According to Article 18 of the GDPR, you have the right to restriction of processing, which means that we may only store the data but not use it further.
• According to Article 20 of the GDPR, you have the right to data portability, which means that we will provide you with your data in a standard format upon request.
• According to Article 21 DSGVO, you have the right to object, which entails a change in processing after enforcement.
  • If the processing of your data is based on Article 6(1)(e) (public interest, exercise of official authority) or Article 6(1)(f) (legitimate interest), you may object to the processing. We will then check as soon as possible whether we can legally comply with this objection.
  • If data is used to conduct direct advertising, you may object to this type of data processing at any time. We may then no longer use your data for direct marketing.
  • If data is used to conduct profiling, you may object to this type of data processing at any time. We may no longer use your data for profiling thereafter.
• According to Article 22 of the GDPR, you may have the right not to be subject to a decision based solely on automated processing (for example, profiling).
• You have the right to lodge a complaint under Article 77 of the GDPR. This means that you can complain to the data protection authority at any time if you believe that the data processing of personal data violates the GDPR.

In short: you have rights – do not hesitate to contact the responsible party listed above with us!

If you believe that the processing of your data violates data protection law or your data protection rights have been violated in any other way, you can complain to the supervisory authority. For Austria, this is the data protection authority, whose website can be found at https://www.dsb.gv.at/. In Germany, there is a data protection officer for each federal state. For more information, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI). The following local data protection authority is responsible for our company:

Austria Data protection authority

Manager:Dr. Matthias Schmidl
Address: Barichgasse 40-42, 1030 Wien
Phone number.: +43 1 52 152-0
E-mail address: dsb@dsb.gv.at
Website: https://www.dsb.gv.at/

Data transfer to third countries

We only transfer or process data to countries outside the scope of the GDPR (third countries) if you consent to this processing or if there is another legal permission. This is particularly true when processing is legally required or necessary for the performance of a contractual relationship, and in any case, only to the extent permitted by law. Your consent is in most cases the primary reason for us to process data in third countries. Processing of personal data in third countries such as the USA, where many software providers offer services and have their server locations, may mean that personal data is processed and stored in unexpected ways.

We explicitly point out that, according to the opinion of the European Court of Justice, there is currently only an adequate level of protection for data transfers to the USA if a US company processing personal data of EU citizens in the USA is an active participant in the EU-US Data Privacy Framework. More information can be found at: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en

Data processing by US services that are not active participants in the EU-US Data Privacy Framework may result in data not being anonymized and processed, if applicable. Additionally, US government authorities may potentially have access to individual data. Furthermore, it may occur that collected data is linked with data from other services of the same provider, if you have a corresponding user account. Where possible, we try to use server locations within the EU, if offered.

We will inform you in the appropriate sections of this privacy policy in more detail about data transfers to third countries, if applicable.

Security of data processing operations

In order to protect personal data, we have implemented both technical and organisational measures. We encrypt or pseudonymise personal data wherever this is possible. Thus, we make it as difficult as we can for third parties to extract personal information from our data.

Article 25 of the GDPR refers to “data protection by technical design and by data protection-friendly default” which means that both software (e.g. forms) and hardware (e.g. access to server rooms) appropriate safeguards and security measures shall always be placed. If applicable, we will outline the specific measures below.

TLS encryption with https

The terms TLS, encryption and https sound very technical, which they are indeed. We use HTTPS (Hypertext Transfer Protocol Secure) to securely transfer data on the Internet.
This means that the entire transmission of all data from your browser to our web server is secured – nobody can “listen in”.

We have thus introduced an additional layer of security and meet privacy requirements through technology design Article 25 Section 1 GDPR). With the use of TLS (Transport Layer Security), which is an encryption protocol for safe data transfer on the internet, we can ensure the protection of confidential information.
You can recognise the use of this safeguarding tool by the little lock-symbol , which is situated in your browser’s top left corner in the left of the internet address (e.g. examplepage.uk), as well as by the display of the letters https (instead of http) as a part of our web address.
If you want to know more about encryption, we recommend you to do a Google search for “Hypertext Transfer Protocol Secure wiki” to find good links to further information.

Communications

If you contact us and communicate with us via phone, email or online form, your personal data may be processed.

The data will be processed for handling and processing your request and for the related business transaction. The data is stored for this period of time or for as long as is legally required.

Affected persons

The above-mentioned processes affect all those who seek contact with us via the communication channels we provide.

Telephone

When you call us, the call data is stored in a pseudonymised form on the respective terminal device, as well as by the telecommunications provider that is being used. In addition, data such as your name and telephone number may be sent via email and stored for answering your inquiries. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Email

If you communicate with us via email, your data is stored on the respective terminal device (computer, laptop, smartphone, …) as well as on the email server. The data will be deleted as soon as the business case has ended and the legal requirements allow for its erasure.

Online forms

If you communicate with us using an online form, your data is stored on our web server and, if necessary, forwarded to our email address. The data will be erased as soon as the business case has ended and the legal requirements allow for its erasure.

Legal bases

Data processing is based on the following legal bases:

• Art. 6 para. 1 lit. a GDPR (consent): You give us your consent to store your data and to continue to use it for the purposes of the business case;
• Art. 6 para. 1 lit. b GDPR (contract): For the performance of a contract with you or a processor such as a telephone provider, or if we have to process the data for pre-contractual activities, such as preparing an offer;
• Art. 6 para. 1 lit. f GDPR (legitimate interests): We want to conduct our customer inquiries and business communication in a professional manner. Thus, certain technical facilities such email programs, Exchange servers and mobile network operators are necessary to efficiently operate our communications.

Cookies

What are cookies?

Our website uses HTTP-cookies to store user-specific data.
In the following we explain what cookies are and why they are used, so that you can better understand the following privacy policy.

Whenever you surf the Internet, you are using a browser. Common browsers are for example, Chrome, Safari, Firefox, Internet Explorer and Microsoft Edge. Most websites store small text-files in your browser. These files are called cookies.

It is important to note that cookies are very useful little helpers. Almost every website uses cookies. More precisely, these are HTTP cookies, as there are also other cookies for other uses. HTTP cookies are small files that our website stores on your computer. These cookie files are automatically placed into the cookie-folder, which is the “brain” of your browser. A cookie consists of a name and a value. Moreover, to define a cookie, one or multiple attributes must be specified.

Cookies store certain user data about you, such as language or personal page settings. When you re-open our website to visit again, your browser submits these “user-related” information back to our site. Thanks to cookies, our website knows who you are and offers you the settings you are familiar to. In some browsers, each cookie has its own file, while in others, such as Firefox, all cookies are stored in one single file.

The following graphic shows a possible interaction between a web browser such as Chrome and the web server. The web browser requests a website and receives a cookie back from the server. The browser then uses this again as soon as another page is requested.

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, while third-party cookies are created by partner-websites (e.g. Google Analytics). Each cookie must be evaluated individually, as each cookie stores different data. The expiry time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other malware. Cookies also cannot access your PC’s information.

This is an example of how cookie-files can look:

Name: _ga
Value: GA1.2.1326744211.152122965942-9
Purpose: Differentiation between website visitors
Expiry date: after 2 years

A browser should support these minimum sizes:

• At least 4096 bytes per cookie
• At least 50 cookies per domain
• At least 3000 cookies in total

Which types of cookies are there?

The exact cookies that we use, depend on the used services, which will be outlined in the following sections of this privacy policy. Firstly, we will briefly focus on the different types of HTTP-cookies.

There are 4 different types of cookies:

Essential cookies
These cookies are necessary to ensure the basic functions of a website. They are needed when a user for example puts a product into their shopping cart, then continues surfing on different websites and comes back later in order to proceed to the checkout. These cookies ensure the shopping cart does not get deleted, even if the user closes their browser window.

Purposive cookies
These cookies collect information about user behaviour and whether the user receives any error messages. Furthermore, these cookies record the website’s loading time as well as its behaviour in different browsers.

Target-orientated cookies
These cookies ensure better user-friendliness. Thus, information such as previously entered locations, fonts sizes or data in forms stay stored.

Advertising cookies
These cookies are also known as targeting cookies. They serve the purpose of delivering customised advertisements to the user. This can be very practical, but also rather annoying.

Upon your first visit to a website you are usually asked which of these cookie-types you want to accept. Furthermore, this decision will of course also be stored in a cookie.

If you want to learn more about cookies and do not mind technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called “HTTP State Management Mechanism”.

Purpose of processing via cookies

The purpose ultimately depends on the respective cookie. You can find out more details below or from the software manufacturer that sets the cookie.

Which data are processed?

Cookies are little helpers for a wide variety of tasks. Unfortunately, it is not possible to tell which data is generally stored in cookies, but in the privacy policy below we will inform you on what data is processed or stored.

Storage period of cookies

The storage period depends on the respective cookie and is further specified below. Some cookies are erased after less than an hour, while others can remain on a computer for several years.

You can also influence the storage duration yourself. You can manually erase all cookies at any time in your browser (also see “Right of objection” below). Furthermore, the latest instance cookies based on consent will be erased is after you withdraw your consent. The legality of storage will remain unaffected until then.

Right of objection – how can I erase cookies?

You can decide for yourself how and whether you want to use cookies. Regardless of which service or website the cookies originate from, you always have the option of erasing, deactivating or only partially accepting cookies. You can for example block third-party cookies but allow all other cookies.

If you want to find out which cookies have been stored in your browser, or if you want to change or erase cookie settings, you can find this option in your browser settings:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want cookies, you can set up your browser in a way to notify you whenever a cookie is about to be set. This gives you the opportunity to manually decide to either permit or deny the placement of every single cookie. This procedure varies depending on the browser. Therefore, it might be best for you to search for the instructions in Google. If you are using Chrome, you could for example put the search term “delete cookies Chrome” or “deactivate cookies Chrome” into Google.

Legal basis

The so-called “cookie directive” has existed since 2009. It states that the storage of cookies requires your consent (Article 6 Paragraph 1 lit. a GDPR). Within countries of the EU, however, the reactions to these guidelines still vary greatly. In Austria, however, this directive was implemented in Section 165 (3) of the Telecommunications Act (2021). In Germany, the cookie guidelines have not been implemented as national law. Instead, this guideline was largely implemented in Section 15 (3) of the Telemedia Act (TMG), which has been replaced by the Digital Services Act (DSA) since May 2024.

For absolutely necessary cookies, even if no consent has been given, there are legitimate interests (Article 6 (1) (f) GDPR), which in most cases are of an economic nature. We want to offer our visitors a pleasant user experience on our website. For this, certain cookies often are absolutely necessary.

This is exclusively done with your consent, unless absolutely necessary cookies are used. The legal basis for this is Article 6 (1) (a) of the GDPR.

In the following sections you will find more detail on the use of cookies, provided the used software does use cookies.

Application Data

What is application data?

You can apply for a job at our company via email, online form, or a recruiting tool. All data we receive and process as part of an application is considered application data. This includes personal data such as name, date of birth, address, and phone number.

Why do we process application data?

We process your data to carry out a proper selection process for the advertised position. Additionally, we may retain your application documents in our applicant archive. Often, we are impressed by a candidate and their application but cannot proceed with collaboration for various reasons. With your consent, we archive your documents so we can easily contact you for future opportunities in our company.

We assure you that we handle your data with the utmost care and always process it within the legal framework. Within our company, your data is only shared with individuals directly involved in your application process. In short: Your data is safe with us!

What data is processed?

For example, when you apply via email, we naturally receive personal data as mentioned above. Even the email address itself is considered personal data. During the application process, only data relevant to deciding whether we would like to welcome you to our team is processed.

The specific data processed depends primarily on the job listing. However, it usually includes your name, date of birth, contact details, and proof of qualifications. If you submit your application via an online form, the data is transmitted to us in encrypted form. If you send your application via email, this encryption does not occur, and we cannot take responsibility for the transmission method. Once the data is on our servers, we are responsible for its lawful handling.

During the application process, information about your health or ethnic origin may also be requested. This helps us comply with legal obligations related to labor law, social security, and social protection. These are considered special category data.

Here is a list of possible data we receive and process:

• Name
• Contact address
• Email address
• Phone number
• Date of birth
• Information from cover letters and resumes
• Proof of qualifications (e.g., certificates)
• Special category data (e.g., ethnic origin, health data, religious beliefs)
• Usage data (visited websites, access data, etc.)
• Metadata (IP address, device information)

How long is the data stored?

If you join our team, your data will be further processed for employment purposes and retained at least until the employment relationship ends. All application documents will then become part of your employee file.

If we do not offer you the position, you decline our offer, or withdraw your application, we may retain your data for up to 6 months after the application process ends under legitimate interest (Art. 6(1)(f) GDPR). After that, both electronic data and physical documents will be fully deleted or destroyed. We retain your data, for example, to answer follow-up questions or to provide evidence of the application in case of legal disputes. If a legal dispute arises and we need the data beyond the 6-month period, we will delete it only when there is no longer any reason to retain it. If there are statutory retention obligations, we must store the data longer than 6 months.

Furthermore, we may retain your data longer if you provide explicit consent. This might be the case if we see potential for future collaboration. In such cases, your data will be included in our applicant pool. Of course, you can withdraw your consent for extended retention at any time. If no withdrawal is made and no new consent is given, your data will be deleted after a maximum of 2 years.

Legal Basis

The legal bases for processing your data are Art. 6(1)(a) GDPR (consent), Art. 6(1)(b) GDPR (contract or pre-contractual measures), Art. 6(1)(f) GDPR (legitimate interests), and Art. 9(2)(a) GDPR (processing special categories of data).

If we include you in our applicant tool, it is based on your consent (Art. 6(1)(a) GDPR). We emphasize that your consent to join our applicant pool is voluntary, does not affect the application process, and can be withdrawn at any time. The legality of processing until the point of withdrawal remains unaffected.

In cases where vital interests are at stake, data processing occurs under Art. 9(2)(c) GDPR. For purposes related to healthcare, occupational medicine, medical diagnosis, provision of health or social care, or the management of systems and services in health or social care, data is processed under Art. 9(2)(h) GDPR. If you voluntarily provide special category data, processing is based on Art. 9(2)(a) GDPR.

Customer Data

What is customer data?

In order to be able to offer our services and contractual services, we also process data from our customers and business partners. This data always includes personal data. Customer data is all information that is processed on the basis of contractual or pre-contractual agreements so that the offered services can be provided. Customer data is therefore all the information we collect and process about our customers.

Why do we process customer data?

There are many reasons why we collect and process customer data. The main reason is that we simply need specific data to provide our services. Sometimes for example your email address may be enough. But if you purchase a product or service, we may e. g. also need data such as your name, address, bank details or other contract data. This data will subsequently be used for marketing and sales optimisation so that we can improve our overall service for our customers and clients. Another important reason for data processing is our customer service, which is very important to us. We want you to have the opportunity to contact us at any time with questions about our offers. Thus, we may need certain data such as your email address at the very least.

What data is processed?

Exactly which data is stored can only be shown by putting them in categories. All in all, it always depends on which of our services you receive. In some cases, you may only give us your email address so that we can e. g. contact you or answer your questions. In other instances, you may purchase one of our products or services. Then we may need significantly more information, such as your contact details, payment details and contract details.

Here is a list of potential data we may receive and process:

• Name
• Contact address
• Email address
• Phone number
• Your birthday
• Payment data (invoices, bank details, payment history, etc.)
• Contract data (duration, contents)
• Usage data (websites visited, access data, etc.)
• Metadata (IP address, device information)

How long is the data stored?

We erase corresponding customer data as soon as we no longer need it to fulfill our contractual obligations and purposes, and as soon as the data is also no longer necessary for possible warranty and liability obligations. This can for example be the case when a business contract ends. Thereafter, the limitation period is usually 3 years, although longer periods may be possible in individual cases. Of course, we also comply with the statutory retention requirements. Your customer data will certainly not be passed on to third parties unless you have given your explicit consent.

Legal Basis

The legal basis for the processing of your data is Article 6 Paragraph 1 Letter a GDPR (consent), Article 6 Paragraph 1 Letter b GDPR (contract or pre-contractual measures), Article 6 Paragraph 1 Letter f GDPR (legitimate interests) and in special cases (e. g. medical services) Art. 9 (2) lit. GDPR (processing of special categories).

In the case of protecting vital interests, data processing is carried out in accordance with Article 9 Paragraph 2 Letter c. GDPR. For the purposes of health care, occupational medicine, medical diagnostics, care or treatment in the health or social sectors or for the administration of systems and services in health or social sectors, the processing of personal data takes place in accordance with Art. 9 Para. 2 lit. h. GDPR. If you voluntarily provide data of these special categories, the processing takes place on the basis of Article 9 Paragraph 2 lit. a GDPR.

Registration

If you register with us and provide any personal data, this data may be processed, possibly along with your IP address. Below you can explore what we mean by the rather broad term “personal data”.

Please only enter the data we need for the registration. In case you are registering on behalf of a third party, please only enter data for which you have the approval of the party you are registering for. If possible, use a secure password that you don’t use anywhere else and an email address that you check regularly.

In the following, we will inform you about the exact type of data processing we do. After all, we want you to feel at ease with the services we provide!

What is a registration?

When you register, we retain certain of your data in order to make it easy for you to log in with us online and use your account. An account with us has the advantage that you don’t have to re-enter everything every time. It saves time and effort and ultimately prevents any issues with the provision of our services.

Why do we process personal data?

In short, we process personal data to make account registration and usage possible for you. If we didn’t do this, you would have to enter all your data each time, wait for our approval and then enter everything again. This strenuous process would probably not only irritate us a little, but also many of our dear clients and customers.

Which data is processed?

Any data that you provided during registration or login and any data that you may enter as part of managing your account data.

During registration, we process the following types of data:

• First name
• Last name
• Email address
• Company name
• Street + house number
• Residence
• Postcode
• Country

During your registration, we process any data you enter, such as your username and password, along with data that is collected in the background such as your device information and IP addresses.

When using your account, we process any data you enter while using the account, as well as any data that is created while you use our services.

Storage time

We store the entered data for at least as long as the account associated with the data exists with us and is in use – and as long as there are contractual obligations between you and us. In case the contract ends, we retain the data until the respective claims get time-barred. Moreover, we store your data as long as we are subject to legal storage obligations, if applicable. Following that, we keep any accounting records (invoices, contract documents, account statements, etc.) of the contract for 10 years (§ 147 AO) and other relevant business documents for 6 years (§ 247 HGB) after accrual.

Right to object

You have registered, entered data and want to revoke the data processing? Not a problem. As you can see above, you retain this right under the General Data Protection Regulation also at and after registration, login or account creation with us. Contact the Data Protection Officer above to exercise your rights. If you already have an account with us, you can easily view and manage your data and texts in your account.

Legal Basis

By completing the registration process, you enter into a pre-contractual agreement with us, with the intention to conclude a contract of use for our platform (although there is no automatic payment obligation). You invest time to enter data and register and in return, we offer you our services after you log on to our system and view your customer account. We also meet our contractual obligations. Finally, we need to be able to email registered users about important changes. Article 6(1)(b) GDPR (implementation of pre-contractual measures, fulfilment of a contract) applies.

Where applicable, we will ask for your consent, e.g. in case you voluntarily provide more data than is absolutely necessary, or in case we may ask you if we may send you advertising. Article 6 paragraph 1 lit. a GDPR (consent) applies in this matter.

We also have a legitimate interest in knowing who who our clients or customers are, in order to get in touch if required. We also need to know who is using our services and whether they are being used in accordance with our terms of use, i.e. Article 6(1)(f) GDPR (legitimate interests) applies in this matter.

Note: the following sections are to be ticked by users (as required):

Registration with real names

Since business operations require us to know who our clients or customers are, registration is only possible with your real name (full name) and not with a pseudonym.

Registration with pseudonyms

You can use a pseudonym for the registration, which means you don’t have to register with your real name. This ensures that your real name cannot be processed by us.

Storage of the IP address

During registration, login and account use, we store your IP address for security reasons in order to be able to determine legitimate use.

Public Profile

User profiles are publicly visible, i.e. parts of the profiles can also be viewed on the Internet without the need to enter a username and password.

Two Factor Authentication (2FA)

Two Factor Authentication (2FA) offers additional security when logging in, as it prevents you from logging in without a smartphone, for example. This technical measure to secure your account protects you against the loss of data or unauthorised access, even if your username and password were leaked. During your registration process, login or within the account itself you can find out which 2FA is used.

Web hosting

What is web hosting?

Every time you visit a website nowadays, certain information – including personal data – is automatically created and stored, including on this website. This data should be processed as sparingly as possible, and only with good reason. By website, we mean the entirety of all websites on your domain, i.e. everything from the homepage to the very last subpage (like this one here). By domain we mean example.uk or examplepage.com.

When you want to view a website on a screen, you use a program called a web browser. You probably know the names of some web browsers: Google Chrome, Microsoft Edge, Mozilla Firefox, and Apple Safari.

The web browser has to connect to another computer which stores the website’s code: the web server. Operating a web server is complicated and time-consuming, which is why this is usually done by professional providers. They offer web hosting and thus ensure the reliable and flawless storage of website data.

Whenever the browser on your computer establishes a connection (desktop, laptop, smartphone) and whenever data is being transferred to and from the web server, personal data may be processed. After all, your computer stores data, and the web server also has to retain the data for a period of time in order to ensure it can operate properly.

Illustration:

Why do we process personal data?

The purposes of data processing are:

1. Professional hosting of the website and operational security
2. To maintain the operational as well as IT security
3. Anonymous evaluation of access patterns to improve our offer, and if necessary, for prosecution or the pursuit of claims.li>

Which data are processed?

Even while you are visiting our website, our web server, that is the computer on which this website is saved, usually automatically saves data such as

• the full address (URL) of the accessed website (e. g. https://www.examplepage.uk/examplesubpage.html?tid=122965942)
• browser and browser version (e.g. Chrome 87)
• the operating system used (e.g. Windows 10)
• the address (URL) of the previously visited page (referrer URL) (e. g. https://www.examplepage.uk/icamefromhere.html/)
• the host name and the IP address of the device from the website is being accessed from (e.g. COMPUTERNAME and 194.23.43.121)
• date and time
• in so-called web server log files

How long is the data stored?

Generally, the data mentioned above are stored for two weeks and are then automatically deleted. We do not pass these data on to others, but we cannot rule out the possibility that this data may be viewed by the authorities in the event of illegal conduct.

In short: Your visit is logged by our provider (company that runs our website on special computers (servers)), but we do not pass on your data without your consent!

Legal basis

The lawfulness of processing personal data in the context of web hosting is justified in Art. 6 para. 1 lit. f GDPR (safeguarding of legitimate interests), as the use of professional hosting with a provider is necessary to present the company in a safe and user-friendly manner on the internet, as well as to have the ability to track any attacks and claims, if necessary.

Hetzner Privacy Policy

We use Hetzner for our website, which is a web hosting provider, among other things. The provider of this service is the German company Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. You can find out more about the data that is processed through the use of Hetzner in their Privacy Policy at https://www.hetzner.com/de/rechtliches/datenschutz.

Web Analytics

What is Web Analytics?

We use software on our website, which is known as web analytics, in order to evaluate website visitor behaviour. Thus, data is collected, which the analytic tool provider (also called tracking tool) stores, manages and processes. Analyses of user behaviour on our website are created with this data, which we as the website operator receive. Most tools also offer various testing options. These enable us, to for example test which offers or content our visitors prefer. For this, we may show you two different offers for a limited period of time. After the test (a so-called A/B test) we know which product or content our website visitors find more interesting. For such testing as well as for various other analyses, user profiles are created and the respective data is stored in cookies.

Why do we run Web Analytics?

We have a clear goal in mind when it comes to our website: we want to offer our industry’s best website on the market. Therefore, we want to give you both, the best and most interesting offer as well as comfort when you visit our website. With web analysis tools, we can observe the behaviour of our website visitors, and then improve our website accordingly for you and for us. For example, we can see the average age of our visitors, where they come from, the times our website gets visited the most, and which content or products are particularly popular. All this information helps us to optimise our website and adapt it to your needs, interests and wishes.

Which data are processed?

The exact data that is stored depends on the analysis tools that are being used. But generally, data such as the content you view on our website are stored, as well as e. g. which buttons or links you click, when you open a page, which browser you use, which device (PC, tablet, smartphone, etc.) you visit the website with, or which computer system you use. If you have agreed that location data may also be collected, this data may also be processed by the provider of the web analysis tool.

Moreover, your IP address is also stored. According to the General Data Protection Regulation (GDPR), IP addresses are personal data. However, your IP address is usually stored in a pseudonymised form (i.e. in an unrecognisable and abbreviated form). No directly linkable data such as your name, age, address or email address are stored for testing purposes, web analyses and web optimisations. If this data is collected, it is retained in a pseudonymised form. Therefore, it cannot be used to identify you as a person.

The following example shows Google Analytics’ functionality as an example for client-based web tracking with JavaScript code.

The storage period of the respective data always depends on the provider. Some cookies only retain data for a few minutes or until you leave the website, while other cookies can store data for several years.

Duration of data processing

If we have any further information on the duration of data processing, you will find it below. We generally only process personal data for as long as is absolutely necessary to provide products and services. The storage period may be extended if it is required by law, such as for accounting purposes for example for accounting.

Right to object

You also have the option and the right to revoke your consent to the use of cookies or third-party providers at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data processing by cookies by managing, deactivating or erasing cookies in your browser.

Legal basis

The use of Web Analytics requires your consent, which we obtained with our cookie popup. According to Art. 6 para. 1 lit. a of the GDPR (consent), this consent represents the legal basis for the processing of personal data, such as by collection through Web Analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors, which enables us to technically and economically improve our offer. With Web Analytics, we can recognise website errors, identify attacks and improve profitability. The legal basis for this is Art. 6 para. 1 lit. f of the GDPR (legitimate interests). Nevertheless, we only use these tools if you have given your consent.

Since Web Analytics tools use cookies, we recommend you to read our privacy policy on cookies. If you want to find out which of your data are stored and processed, you should read the privacy policies of the respective tools.

If available, information on special Web Analytics tools can be found in the following sections.

Google Analytics Privacy Policy

What is Google Analytics?

On our website, we use the analytics tracking tool Google Analytics in the Google Analytics 4 (GA4) version provided by the American company Google Inc. For the European region, Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. Google Analytics collects data about your actions on our website. By combining various technologies such as cookies, device IDs, and login information, you can be identified as a user across different devices. This allows your actions to be analyzed across platforms as well.

For example, when you click on a link, this event is stored in a cookie and sent to Google Analytics. With the reports we receive from Google Analytics, we can better tailor our website and service to your needs. In the following, we will provide more information about the tracking tool and specifically inform you about the data processed and how you can prevent it.

Google Analytics is a tracking tool used for website traffic analysis. The basis for these measurements and analyses is a pseudonymous user identification number. This number does not include personally identifiable information such as name or address but is used to assign events to a device. GA4 utilizes an event-based model that captures detailed information about user interactions such as page views, clicks, scrolling, and conversion events. Additionally, GA4 incorporates various machine learning features to better understand user behavior and certain trends. GA4 employs modeling through machine learning capabilities, meaning that based on the collected data, missing data can be extrapolated to optimize the analysis and provide forecasts.

In order for Google Analytics to function properly, a tracking code is embedded in the code of our website. When you visit our website, this code records various events that you perform on our website. With GA4’s event-based data model, we, as website operators, can define and track specific events to obtain analyses of user interactions. This allows us to track not only general information such as clicks or page views but also specific events that are important for our business, such as submitting a contact form or making a purchase.

Once you leave our website, this data is sent to and stored on Google Analytics servers.

Google processes the data, and we receive reports on your user behavior. These reports can include, among others, the following:

• Audience reports: Audience reports help us get to know our users better and gain a more precise understanding of who is interested in our service.
• Advertising reports: Advertising reports make it easier for us to analyze and improve our online advertising.
• Acquisition reports: Acquisition reports provide helpful information on how we can attract more people to our service.
• Behavior reports: Here, we learn about how you interact with our website. We can track the path you take on our site and which links you click on.
• Conversion reports: Conversion refers to an action you take as a result of a marketing message, such as going from being a website visitor to becoming a buyer or newsletter subscriber. Through these reports, we gain insights into how our marketing efforts resonate with you, with the aim of improving our conversion rate.
• Real-time reports: With real-time reports, we can see what is currently happening on our website. For example, we can see how many users are currently reading this text.

In addition to the above-mentioned analysis reports, Google Analytics 4 also offers the following functions:

• Event-based data model: This model captures specific events that can occur on our website, such as playing a video, making a purchase, or subscribing to our newsletter.
• Advanced analytics features: With these features, we can gain a better understanding of your behavior on our website or certain general trends. For example, we can segment user groups, conduct comparative analyses of target audiences, or track your path on our website.
• Predictive modeling: Based on the collected data, missing data can be extrapolated through machine learning to predict future events and trends. This can help us develop better marketing strategies.
• Cross-platform analysis: Data collection and analysis are possible from both websites and apps. This enables us to analyze user behavior across platforms, provided you have consented to data processing.

Why do we use Google Analytics on our website?

Our goal with this website is clear: we want to provide you with the best possible service. The statistics and data from Google Analytics help us achieve this goal.

The statistically evaluated data gives us a clear picture of the strengths and weaknesses of our website. On one hand, we can optimize our site to make it more easily found by interested people on Google. On the other hand, the data helps us better understand you as a visitor. We know exactly what we need to improve on our website in order to provide you with the best possible service. The data also helps us conduct our advertising and marketing activities in a more personalized and cost-effective manner. After all, it only makes sense to show our products and services to people who are interested in them.

What data is stored by Google Analytics?

With the help of a tracking code, Google Analytics creates a random, unique ID associated with your browser cookie. This way, Google Analytics recognizes you as a new user, and a user ID is assigned to you. When you visit our site again, you are recognized as a “returning” user. All collected data is stored together with this user ID, making it possible to evaluate pseudonymous user profiles.

To analyze our website with Google Analytics, a property ID must be inserted into the tracking code. The data is then stored in the corresponding property. For each newly created property, the default is Google Analytics 4 Property. The data storage duration varies depending on the property used.

Through identifiers such as cookies, app instance IDs, user IDs, or custom event parameters, your interactions, if you have consented, are measured across platforms. Interactions encompass all types of actions you perform on our website. If you also use other Google systems (such as a Google account), data generated through Google Analytics can be linked to third-party cookies. Google does not disclose Google Analytics data unless we, as website operators, authorize it, except when required by law.

According to Google, IP addresses are not logged or stored in Google Analytics 4. However, IP address data is used by Google for deriving location data and is immediately deleted thereafter. All IP addresses collected from users in the EU are deleted before the data is stored in a data center or on a server.

Since GA4 focuses on event-based data, the tool uses significantly fewer cookies compared to previous versions such as Google Universal Analytics. However, there are still some specific cookies used by GA4. These can include:

Name: _ga
Value: 2.1326744211.152122965942-5
Purpose: By default, analytics.js uses the _ga cookie to store the user ID. It is used to distinguish website visitors.
Expiration: After 2 years

Name: _gid
Value: 2.1687193234.152122965942-1
Purpose: This cookie is also used to distinguish website visitors.
Expiration: After 24 hours

Name: gat_gtag_UA Value: 1
Purpose: Used to reduce the request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named dc_gtm .
Expiration: After 1 minute

Note: This list cannot claim to be exhaustive, as Google may change their choice of cookies from time to time. GA4 aims to improve data privacy and offers several options for controlling data collection. For example, we can determine the storage duration ourselves and control data.

Here we provide an overview of the main types of data collected by Google Analytics:

Heatmaps: Google creates heatmaps to show the exact areas you click on. This provides us with information about your interactions on our site.

Session Duration: Google refers to session duration as the time you spend on our site without leaving. If you are inactive for 20 minutes, the session automatically ends.

Bounce Rate: Bounce rate refers to when you view only one page on our website and then leave.

Account Creation: If you create an account or place an order on our website, Google Analytics collects this data.

Location: IP addresses are not logged or stored in Google Analytics. However, location data is derived shortly before the IP address is deleted.

Technical Information: Technical information includes your browser type, internet service provider, and screen resolution, among others.

Source of Origin: Google Analytics is interested in the website or advertisement that brought you to our site.

Additional data may include contact information, reviews, media playback (e.g., if you play a video on our site), sharing of content via social media, or adding to favorites. This list is not exhaustive and serves only as a general guide to the data storage by Google Analytics.

Where and how long are the data stored?

Google has servers distributed worldwide. You can find precise information about the locations of Google data centers at: https://www.google.com/about/datacenters/locations/?hl=en

Your data is distributed across multiple physical storage devices. This ensures faster access to data and better protection against manipulation. Each Google data center has emergency programs in place for your data. In the event of hardware failure or natural disasters, the risk of service interruption at Google remains low.

The retention period of data depends on the properties used. The storage duration is always set separately for each individual property. Google Analytics offers us four options for controlling the storage duration:

• 2 months: This is the shortest storage period.
• 14 months: By default, data is stored in GA4 for 14 months.
• 26 months: Data can also be stored for 26 months.
• Data is only deleted manually.

In addition, there is also the option for data to be deleted only if you do not visit our website within the selected time period. In this case, the retention period is reset every time you revisit our website within the defined time frame.

Once the defined period has expired, the data is deleted once a month. This retention period applies to data linked to cookies, user identification, and advertising IDs (e.g., cookies from the DoubleClick domain). Report results are based on aggregated data and are stored independently of user data. Aggregated data is a combination of individual data into larger units.

How can I delete my data or prevent data storage?

Under the data protection laws of the European Union, you have the right to access, update, delete, or restrict your data. By using the browser add-on to deactivate Google Analytics JavaScript (analytics.js, gtag.js), you can prevent Google Analytics 4 from using your data. You can download and install the browser add-on at: https://tools.google.com/dlpage/gaoptout?hl=en Please note that this add-on only disables data collection by Google Analytics.

If you want to disable, delete, or manage cookies in general, you can find the respective instructions for the most common browsers in the “Cookies” section.

Legal basis

The use of Google Analytics requires your consent, which we obtained through our cookie popup. According to Art. 6(1)(a) of the GDPR, this consent constitutes the legal basis for the processing of personal data that may occur during the collection by web analytics tools.

In addition to consent, we also have a legitimate interest in analyzing the behavior of website visitors to improve our offering technically and economically. By using Google Analytics, we can identify website errors, detect attacks, and improve efficiency. The legal basis for this is Art. 6(1)(f) of the GDPR (legitimate interests). However, we only use Google Analytics if you have given your consent.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find the Google Ads Data Processing Terms, which refer to the Standard Contractual Clauses, at: https://business.safety.google/intl/en/adsprocessorterms/

We hope we have provided you with the most important information regarding the data processing by Google Analytics. If you want to learn more about the tracking service, we recommend the following links: https://marketingplatform.google.com/about/analytics/terms/en/ and https://support.google.com/analytics/answer/6004245?hl=en

If you want to learn more about data processing, you can refer to the Google Privacy Policy at: https://policies.google.com/privacy?hl=en.

Google Analytics Reports on demographic characteristics and interests

We have turned on Google Analytics’ functions for advertising reports. These reports on demographic characteristics and interests contain details about age, gender and interests. Through them we can get a better picture of our users – without being able to allocate any data to individual persons. You can learn more about advertising functions at auf https://support.google.com/analytics/answer/3450482?hl=en&amp%3Butm_id=ad.

You can terminate the use of your Google Account’s activities and information in “Ads Settings” at https://adssettings.google.com/authenticated via a checkbox.

Google Analytics e-commerce Measurement

We also use the e-commerce measurement function of the web analysis tool Google Analytics for our website. This allows us to analyse very precisely how you and all our other customers interact with our website. E-commerce measurement is all about purchasing behaviour. Based on the data obtained, we can adapt and optimise our service to your wishes and expectations. With this data we can also use our online advertising measures in a more targeted manner, to only show our advertising to people who are interested in our products or services. The e-commerce measurement function records e. g. which orders were placed, how much time you took to decide on purchasing a product, the average order value or the shipping costs. All this data can be recorded and stored under a specific ID.

Google Analytics Google Signals Privacy Policy

We have activated Google signals in Google Analytics. Through this, any existing Google Analytics functions (advertising reports, remarketing, cross-device reports and reports on interests and demographic characteristics) are updated, to result in the summary and anonymisation of your data, should you have permitted personalised ads in your Google Account.

The special aspect of this is that it involves cross-device tracking. That means your data can be analysed across multiple devices. Through the activation of Google signals, data is collected and linked to the Google account. For example, it enables Google to recognise when you look at a product on a smartphone and later buy the product on a laptop. Due to activating Google signals, we can start cross-device remarketing campaigns, which would otherwise not be possible to this extent. Remarketing means, that we can show you our products and services across other websites as well.

Moreover, further visitor data such as location, search history, YouTube history and data about your actions on our website are collected in Google Analytics. As a result, we receive improved advertising reports and more useful information on your interests and demographic characteristics. These include your age, the language you speak, where you live or what your gender is. Certain social criteria such as your job, your marital status or your income are also included. All these characteristics help Google Analytics to define groups of persons or target audiences.

Those reports also help us to better assess your behaviour, as well as your wishes and interests. As a result, we can optimise and customise our products and services for you. By default, this data expires after 26 months. Please consider, that this data is only collected if you have agreed to personalised advertisement in your Google Account. The retained information is always exclusively summarised and anonymous data, and never any data on individual persons. You can manage or delete this data in your Google Account.

Google Analytics in Consent Mode

Depending on your consent, Google Analytics will progress your personal data in the so-called “consent mode”. You can choose whether or not you want to accept Google Analytics cookies, and thus which of your data Google Analytics may process. The retained data is mainly used to measure user behaviour on the website, to serve targeted advertising and to provide us with web analysis reports. Usually, you would consent to Google’s data processing via a cookie consent tool. If you do not consent to data processing, only aggregated data will be collected and processed. This means that data cannot be assigned to individual users and therefore no user profile will be created for you. You also have the option to only agree to statistical measurement, meaning that none of your personal data will be processed and used for advertising or advertising measurement sequences.

Google Analytics IP Anonymisation

We implemented Google Analytics’ IP address anonymisation to this website. Google developed this function, so this website can comply with the applicable privacy laws and the local data protection authorities’ recommendations, should they prohibit the retention of any full IP addresses.
The anonymisation or masking of IP addresses takes place, as soon as they reach Google Analytics’ data collection network, but before the data would be saved or processed.

You can find more information on IP anonymisation at https://support.google.com/analytics/answer/2763052?hl=en.

Google Remarketing Privacy Policy

What is Google Remarketing?

We use Google Remarketing as an online marketing measure to promote our products and services. Our goal is to make more people aware of the high quality of our offerings online. As part of our advertising measures, we use Google Remarketing provided by Google Inc. In Europe, the company responsible for all Google services is Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). This retargeting tool helps us better tailor and deliver our advertising to your interests and needs. In the following article, we will explain why we use Google Remarketing, what data is stored, and how you can prevent data storage.

Google Remarketing is a specialized online advertising method where targeted advertisements are displayed to users who have previously visited a specific website or app. This means that after visiting our website, the system recognizes which pages you viewed and your interests, enabling targeted online ads to be displayed based on this information. This works through the use of cookies and other tracking technologies that record your user behavior on our site and subsequently show relevant ads on other Google platforms (such as YouTube).

We are confident in the quality of our offerings and want as many people as possible to discover our website. In the online domain, Google Ads and its integrated Google Remarketing provide the best platform for this. Naturally, we also want a clear overview of the cost-effectiveness of our advertising campaigns, which is why we use Google Ads’ conversion tracking tool.

Why do we use Google Remarketing on our website?

We use Google Remarketing to highlight our offerings on other websites or Google platforms. The goal is to ensure our advertising campaigns reach only those genuinely interested in our offerings. With Google Remarketing, we can deliver targeted ads to you if you have previously visited our website and not completed a desired action. These ads aim to convince you that we have what you are looking for, thereby increasing the likelihood of further interaction or conversion. But what is a conversion? A conversion occurs when a purely interested website visitor becomes an acting visitor. This happens whenever you click on our ad and subsequently take another action, such as visiting our website.

This data helps us calculate our cost-effectiveness, measure the success of individual advertising efforts, and optimize our online marketing strategies. Additionally, the collected data allows us to make our website more engaging for you and customize our advertising offerings to your needs.

What data is stored by Google Remarketing?

We have integrated Google Remarketing into our website to analyze certain user actions better and display targeted ads. The data collected varies depending on the functions used and individual settings. Typically, information about which subpages you visit on our website, which products you view or purchase, how long you stay on a page, whether you abandon specific actions, or other conversions (purchase, button click, etc.) is collected.

As you can see, Google Remarketing primarily processes data related to your user behavior and does not process personal data such as names or email addresses. However, Google Remarketing processes your IP address, which is considered personal data under GDPR. Additionally, cookies or other tracking technologies may store information about your devices (browser, operating system, device type, etc.) and demographic data such as age or gender. All data is anonymized and aggregated to protect user privacy.

When you click on one of our Google Ads, the “Conversion” cookie is stored on your computer (usually in your browser) or mobile device. Cookies are small text files that store information on your computer.

Below are the details of the main cookies used for remarketing:

Name: Conversion
Value: EhMI_aySuoyv4gIVled3Ch0llweVGAEgt-mr6aXd7dYlSAGQ122965942-3
Purpose: This cookie stores every conversion you make on our site after arriving via a Google Ad.
Expiration: after 3 months

Name: _gac
Value: 1.1558695989.EAIaIQobChMIiOmEgYO04gIVj5AYCh2CBAPrEAAYASAAEgIYQfD_BwE
Purpose: This is a classic Google Analytics cookie used to record various actions on our website.
Expiration: after 3 months

Note: The _gac cookie appears only in conjunction with Google Analytics. The above list is not exhaustive, as Google regularly uses additional cookies for analytical purposes.

Once you complete an action on our website, Google recognizes the cookie and records your action as a conversion. As long as you browse our site and the cookie has not expired, we and Google can recognize that you returned to our site via a Google Ads ad. The cookie is read and the conversion data is sent back to Google Ads. Other cookies may also be used to measure conversions. Google Remarketing and the associated tracking can be further refined and enhanced with Google Analytics. For ads displayed by Google across the web, cookies named “__gads” or “_gac” may be set under our domain. Since September 2017, various campaign information from analytics.js has been stored in the _gac cookie. This cookie stores this data whenever you visit a page for which automatic tag labeling in Google Ads has been configured. Unlike cookies set for Google domains, Google can only read these conversion cookies while you are on our website.

How long and where is the data stored?

Google has servers distributed worldwide. You can read exactly where Google data centers are located here: https://www.google.com/about/datacenters/locations/?hl=de.

In general, Google processes data only as long as necessary to fulfill the purposes and as required by law. Please note that we have no control over how Google uses the data it collects. According to Google, data is encrypted and stored on secure servers. Most conversion cookies expire after 30 days and do not transmit personal data. The cookies named “Conversion” and “_gac” (used with Google Analytics) have an expiration date of 3 months.

How can I delete my data or prevent data storage?

You can opt out of Google Remarketing. By disabling Google Remarketing in your browser, you block tracking. In this case, you will not be included in the tool’s statistics. You can also change your browser’s cookie settings at any time. Each browser functions slightly differently. Under the “Cookies” section, you will find the corresponding links to the instructions for the most popular browsers.

If you generally do not want cookies, you can configure your browser to notify you whenever a cookie is set. This way, you can decide whether to allow or block each cookie. By downloading and installing this browser plug-in from https://support.google.com/ads/answer/7395996, you can disable all “advertising cookies.” Please note that disabling these cookies does not prevent ads but only personalized advertising.

In your Google account settings, under “Ads” or “Advertising,” you can disable personalized ads based on Google Remarketing. If you do not consent to data processing through Google Remarketing via the consent management tool on our website, no data will be collected.

Legal Basis

If you have consented to the use of Google Remarketing, the legal basis for this data processing is your consent. According to Art. 6 para. 1 lit. a GDPR (consent), this consent serves as the legal basis for processing personal data, such as the IP address collected through Google Remarketing.

We also have a legitimate interest in using Google Remarketing to optimize our online services and marketing measures. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). However, we only use Google Remarketing if you have given your consent.

Google processes your data, among other places, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which ensures the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (= Art. 46 para. 2 and 3 GDPR). Standard Contractual Clauses (SCC) are templates provided by the EU Commission to ensure that your data complies with European data protection standards even when transferred to third countries (such as the USA) and stored there. Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an EU Commission implementation decision. You can find the decision and the corresponding Standard Contractual Clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de.

Google provides a data processing agreement under Art. 28 GDPR, which serves as the legal basis for our customer relationship with Google. This agreement refers to the EU Standard Contractual Clauses. Here you can find the data processing terms: https://business.safety.google/intl/de/adsprocessorterms/.

Learn more about the data processed through the use of Google Remarketing in the privacy policy at https://policies.google.com/privacy?hl=de.

Google Tag Manager Privacy Policy

What is Google Tag Manager?

We use Google Tag Manager by the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) for our website.
This Tag Manager is one of Google’s many helpful marketing products. With it, we can centrally integrate and manage code sections of various tracking tools, that we use on our website.

In this privacy statement we will explain in more detail, what Google Tag Manager does, why we use it and to what extent your data is processed.

Google Tag Manager is an organising tool with which we can integrate and manage website tags centrally and via a user interface. Tags are little code sections which e.g. track your activities on our website. For this, segments of JavaScript code are integrated to our site’s source text. The tags often come from Google’s intern products, such as Google Ads or Google Analytics, but tags from other companies can also be integrated and managed via the manager. Since the tags have different tasks, they can collect browser data, feed marketing tools with data, embed buttons, set cookies and track users across several websites.

Why do we use Google Tag Manager for our website?

Everybody knows: Being organised is important! Of course, this also applies to maintenance of our website. In order to organise and design our website as well as possible for you and anyone who is interested in our products and services, we rely on various tracking tools, such as Google Analytics.
The collected data shows us what interests you most, which of our services we should improve, and which other persons we should also display our services to. Furthermore, for this tracking to work, we must implement relevant JavaScript Codes to our website. While we could theoretically integrate every code section of every tracking tool separately into our source text, this would take too much time and we would lose overview. This is the reason why we use Google Tag Manager. We can easily integrate the necessary scripts and manage them from one place. Additionally, Google Tag Manager’s user interface is easy to operate, and requires no programming skills. Therefore, we can easily keep order in our jungle of tags.

What data is stored by Google Tag Manager?

Tag Manager itself is a domain that neither uses cookies nor stores data. It merely functions as an “administrator“ of implemented tags. Data is collected by the individual tags of the different web analysis tools. Therefore, in Google Tag Manager the data is sent to the individual tracking tools and does not get saved.

However, with the integrated tags of different web analysis tools such as Google Analytics, this is quite different. Depending on the analysis tool used, various data on your internet behaviour is collected, stored and processed with the help of cookies. Please read our texts on data protection for more information on the articular analysis and tracking tools we use on our website.

We allowed Google via the account settings for the Tag Manager to receive anonymised data from us. However, this exclusively refers to the use of our Tag Manager and not to your data, which are saved via code sections. We allow Google and others, to receive selected data in anonymous form. Therefore, we agree to the anonymised transfer of our website data. However, even after extensive research we could not find out what summarised and anonymous data it is exactly that gets transmitted. What we do know is that Google deleted any info that could identify our website. Google combines the data with hundreds of other anonymous website data and creates user trends as part of benchmarking measures. Benchmarking is a process of comparing a company’s results with the ones of competitors. As a result, processes can be optimised based on the collected information.

How long and where is the data stored?

When Google stores data, this is done on Google’s own servers. These servers are located all over the world, with most of them being in America. At https://www.google.com/about/datacenters/inside/locations/?hl=en you can read in detail where Google’s servers are.

In our individual data protection texts on the different tools you can find out how long the respective tracking tools store your data.

How can I delete my data or prevent data retention?

Google Tag Manager itself does not set any cookies but manages different tracking websites’ tags. In our data protection texts on the different tracking tools you can find detailed information on how you can delete or manage your data.

Please note that when using this tool, your data may also be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data must not be transferred, stored and processed to insecure third countries, unless there are suitable guarantees (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

The use of the Google Tag Manager requires your consent, which we obtained via our cookie popup. According to Art. 6 para. 1 lit. a GDPR (consent), this consent is the legal basis for personal data processing, such as when it is collected by web analytics tools.

In addition to consent, we have a legitimate interest in analysing the behaviour of website visitors and thus technically and economically improving our offer. With the help of Google Tag Managers we can also improve profitability. The legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). We only use Google Tag Manager if you have given us your consent.

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find the Google Ads Data Processing Terms, which refer to the Standard Contractual Clauses, at: https://business.safety.google/intl/en/adsprocessorterms/

If you want to learn more about Google Tag Manager, we recommend their FAQs at https://support.google.com/tagmanager/?hl=en#topic=3441530.

Email-Marketing

What is Email-Marketing?

We use email marketing to keep you up to date. If you have agreed to receive our emails or newsletters, your data will be processed and stored. Email marketing is a part of online marketing. In this type of marketing, news or general information about a company, product or service are emailed to a specific group of people who are interested in it.

If you want to participate in our email marketing (usually via newsletter), you usually just have to register with your email address. To do this, you have to fill in and submit an online form. However, we may also ask you for your title and name, so we can address you personally in our emails.

The registration for newsletters generally works with the help of the so-called “double opt-in procedure”. After you have registered for our newsletter on our website, you will receive an email, via which you can confirm the newsletter registration. This ensures that you own the email address you signed up with, and prevents anyone to register with a third-party email address. We or a notification tool we use, will log every single registration. This is necessary so we can ensure and prove, that registration processes are done legally and correctly. In general, the time of registration and registration confirmation are stored, as well as your IP address. Moreover, any change you make to your data that we have on file is also logged.

Why do we use Email-Marketing?

Of course, we want to stay in contact with you and keep you in the loop of the most important news about our company. For this, we use email marketing – often just referred to as “newsletters” – as an essential part of our online marketing. If you agree to this or if it is permitted by law, we will send you newsletters, system emails or other notifications via email. Whenever the term “newsletter” is used in the following text, it mainly refers to emails that are sent regularly. We of course don’t want to bother you with our newsletter in any way. Thus, we genuinely strive to offer only relevant and interesting content. In our emails you can e.g. find out more about our company and our services or products. Since we are continuously improving our offer, our newsletter will always give you the latest news, or special, lucrative promotions. Should we commission a service provider for our email marketing, who offers a professional mailing tool, we do this in order to offer you fast and secure newsletters. The purpose of our email marketing is to inform you about new offers and also to get closer to our business goals.

Which data are processed?

If you subscribe to our newsletter via our website, you then have to confirm your membership in our email list via an email that we will send to you. In addition to your IP and email address, your name, address and telephone number may also be stored. However, this will only be done if you agree to this data retention. Any data marked as such are necessary so you can participate in the offered service. Giving this information is voluntary, but failure to provide it will prevent you from using this service. Moreover, information about your device or the type of content you prefer on our website may also be stored. In the section “Automatic data storage” you can find out more about how your data is stored when you visit a website. We record your informed consent, so we can always prove that it complies with our laws.

Duration of data processing

If you unsubscribe from our e-mail/newsletter distribution list, we may store your address for up to three years on the basis of our legitimate interests, so we can keep proof your consent at the time. We are only allowed to process this data if we have to defend ourselves against any claims.

However, if you confirm that you have given us your consent to subscribe to the newsletter, you can submit an individual request for erasure at any time. Furthermore, if you permanently object to your consent, we reserve the right to store your email address in a blacklist. But as long as you have voluntarily subscribed to our newsletter, we will of course keep your email address on file.

Withdrawal – how can I cancel my subscription?

You have the option to cancel your newsletter subscription at any time. All you have to do is revoke your consent to the newsletter subscription. This usually only takes a few seconds or a few clicks. Most of the time you will find a link at the end of every email, via which you will be able to cancel the subscription. Should you not be able to find the link in the newsletter, you can contact us by email and we will immediately cancel your newsletter subscription for you.

Legal basis

Our newsletter is sent on the basis of your consent (Article 6 (1) (a) GDPR). This means that we are only allowed to send you a newsletter if you have actively registered for it beforehand. Moreover, we may also send you advertising messages on the basis of Section 7 (3) UWG (Unfair Competition Act), provided you have become our customer and have not objected to the use of your email address for direct mail.

If available – you can find information on special email marketing services and how they process personal data, in the following sections.

SendGrid Privacy Policy

What is SendGrid?

We use SendGrid, an email delivery service, on our website. The service provider is the American company Twilio Inc., 889 Winslow St, Redwood City, California 94063, USA.

Founded in 2009, SendGrid aims to provide companies with powerful APIs and tools for sending, receiving, and tracking emails. Since its inception, the company has continuously grown, offering features such as email sending, spam filtering, mail processing, real-time tracking, and automatic scaling. In 2020, Twilio, the cloud communications platform, acquired SendGrid. SendGrid is now one of the largest providers globally, assisting businesses worldwide in efficient email communication.

By using SendGrid, personal data such as your IP address, geographical data, or contact information may be collected, stored, and processed. In this privacy policy, we provide detailed information on data processing through SendGrid to keep you well-informed.

Why do we use SendGrid on our website?

Primarily, we use an email marketing service to stay in touch with you, informing you about updates and attractive offers in our program. For our marketing efforts, we always seek the simplest and best solutions. Therefore, we chose the SendGrid service. Despite its user-friendly interface, the software offers a plethora of helpful features.

Using design templates, we customize each newsletter, and thanks to “Responsive Design,” our content is readable and visually appealing on your smartphone or any other mobile device.

The email marketing service also provides valuable analytical capabilities. When sending a newsletter, we can track whether and when you opened it. The software also recognizes and records if you clicked on any links in the newsletter. This information is crucial in tailoring and optimizing our service to your needs and preferences. Ultimately, we aim to provide you with the best possible service. In addition to the data mentioned earlier, information about your user behavior is also stored.

What data does SendGrid process?

When you subscribe to our newsletter through our website, you confirm your membership in a SendGrid email list via email. To prove that you have subscribed to the “list provider,” SendGrid stores the date of registration, the time, and your IP address.

With SendGrid’s help, we can keep you updated firsthand on what’s happening in our company. However, during the newsletter registration process, all data you enter (such as your email address or your first and last name) is stored and managed on our server and at SendGrid. This includes personal data. During the registration, you also consent to receiving the newsletter, and this privacy policy is referenced. Furthermore, data such as click behavior (open rates, click rates, and conversion data) in the newsletter may be processed. This information is used to send you emails and utilize specific other SendGrid functions, such as newsletter evaluation.

How long and where are the data stored?

In general, data at SendGrid is deleted when it is no longer needed for their purposes. Exceptions may occur, especially if legal obligations require longer retention of the data. Web server logs containing your IP address and technical data are also deleted by SendGrid when you unsubscribe from our newsletter. If you request SendGrid to delete specific data, they will comply with your request unless deleting this information prevents the company from performing necessary business functions. After closing our SendGrid account, customer data is deleted or at least transformed within 60 days, making it no longer identifiable. However, exceptions include, for example, invoice records that can be retained for up to 7 years after account closure or information that, for security reasons, can be kept for up to three years after account closure.

SendGrid is an American company, and consequently, the data is stored and processed in the United States. More details can be found in the section “Legal Basis” below.

Right to object

You have the option to unsubscribe from our newsletter at any time. To do this, you only need to revoke your consent to newsletter registration. This usually takes only a few seconds or one or two clicks. Most newsletters contain a link at the end of each email to unsubscribe from the newsletter. If the link is not found in the newsletter, please contact us by email, and we will promptly cancel your newsletter subscription. After unsubscribing, personal data is deleted from our server and SendGrid servers. You have the right to free information about your stored data and, if necessary, the right to deletion, blocking, or correction.

Legal basis

If you have consented to the use of SendGrid, the legal basis for the corresponding data processing is this consent. According to Art. 6 (1) lit. a DSGVO (Consent), this consent constitutes the legal basis for the processing of personal data that may occur during the collection by SendGrid.

From our side, there is also a legitimate interest in using SendGrid to optimize our online service and create beautiful and informative newsletters for you. The corresponding legal basis is Art. 6 (1) lit. f DSGVO (Legitimate interests). If consent is not required, newsletter dispatch is based on the legitimate interest in direct marketing (Article 6 (1) lit. f), if legally permitted. We record your registration process to always demonstrate compliance with our laws.

Twilio processes data from you, among other places, in the USA. SendGrid or Twilio is an active participant in the EU-US Data Privacy Framework, regulating the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Twilio uses so-called standard contractual clauses (= Art. 46 (2) and 3 DSGVO). Standard contractual clauses (SCC) are model templates provided by the EU Commission and are intended to ensure that your data also complies with European data protection standards when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the standard contractual clauses, Twilio commits to maintaining the European level of data protection when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses, among other places, here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de.

The data processing conditions (Data Processing Addendum), corresponding to the standard contractual clauses, can be found at https://www.twilio.com/legal/data-protection-addendum.

Learn more about the data processed by using SendGrid in the Privacy Policy at https://www.twilio.com/legal/privacy.

Social Media

What is Social Media?

In addition to our website, we are also active on various social media platforms. For us to be able to target interested users via social networks, user data may be processed. Additionally, elements of social media platforms may be embedded directly in our website. This is e.g. the case if you click a so-called social button on our website and are forwarded directly to our social media presence. So-called social media are websites and apps on which registered members can produce and exchange content with other members, be it openly or in certain groups and networks.

Why do we use Social Media?

For years, social media platforms have been the place where people communicate and get into contact online. With our social media presence, we can familiarise interested people better with our products and services. The social media elements integrated on our website help you switch to our social media content quickly and hassle free.

The data that is retained and processed when you use a social media channel is primarily used to conduct web analyses. The aim of these analyses is to be able to develop more precise and personal marketing and advertising strategies. The evaluated data on your behaviour on any social media platform can help to draw appropriate conclusions about your interests. Moreover, so-called user profiles can be created. Thus, the platforms may also to present you with customised advertisements. For this, cookies are usually placed in your browser, which store data on your user behaviour.

We generally assume that we will continue to be responsible under Data Protection Law, even when using the services of a social media platform. However, the European Court of Justice has ruled that, within the meaning of Art. 26 GDPR, in certain cases the operator of the social media platform can be jointly responsible with us. Should this be the case, we will point it out separately and work on the basis of a related agreement. You will then find the essence of the agreement for the concerned platform below.

Please note that when you use social media platforms or our built-in elements, your data may also be processed outside the European Union, as many social media channels, such as Facebook or Twitter, are American companies. As a result, you may no longer be able to easily claim or enforce your rights regarding your personal data.

Which data are processed?

Exactly which data are stored and processed depends on the respective provider of the social media platform. But usually it is data such as telephone numbers, email addresses, data you enter in contact forms, user data such as which buttons you click, what you like or who you follow, when you visited which pages, as well as information about your device and IP address. Most of this data is stored in cookies. Should you have a profile on the social media channel you are visiting and are logged in, data may be linked to your profile.

All data that are collected via social media platforms are also stored on the providers’ servers. This means that only the providers have access to the data and can provide you with appropriate information or make changes for you.

If you want to know exactly which data is stored and processed by social media providers and how you can object to the data processing, we recommend you to carefully read the privacy policy of the respective company. We also recommend you to contact the provider directly if you have any questions about data storage and data processing or if you want to assert any corresponding rights.

Duration of data processing

Provided we have any further information on this, we will inform you about the duration of the data processing below. The social media platform Facebook example stores data until they are no longer needed for the company’s own purposes. However, customer data that is synchronised with your own user data is erased within two days. Generally, we only process personal data for as long as is absolutely necessary for the provision of our services and products. This storage period can also be exceeded however, if it is required by law, such as e.g. in the case of accounting.

Right to object

You also retain the right and the option to revoke your consent to the use of cookies or third-party providers such as embedded social media elements at any time. This can be done either via our cookie management tool or via other opt-out functions. You can e.g. also prevent data collection via cookies by managing, deactivating or erasing cookies in your browser.

Since cookies may be used with social media tools, we also recommend you to read our privacy policy on cookies. If you want to find out which of your data is stored and processed, we advise you to read the privacy policies of the respective tools.

Legal basis

If you have consented to the processing and storage of your data by integrated social media elements, this consent serves as the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, provided you have given your consent, your data will also be stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) in maintaining fast and good communication with you and other customers and business partners. Nevertheless, we only use the tools if you have consented. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy on cookies carefully and to take a look at the privacy policy or cookie policy of the respective service provider.

in the following section you can find information on special social media platforms – provided this information is available.

Facebook Privacy Policy

What are Facebook tools?

We use selected Facebook tools on our website. Facebook is a social media network of the company Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. With the aid of this tool we can provide the best possible offers to you and anyone interested in our products and services.

If your data is collected and forwarded via our embedded Facebook elements or via our Facebook page (fanpage), both we and Facebook Ireland Ltd. are responsible for this. However, should any further processing occur, then Facebook is solely responsible for this data. Our joint commitments were also set out in a publicly available agreement at https://www.facebook. com / legal / controller_addendum . It e.g. states that we must clearly inform you about the use of Facebook tools on our website. We are also responsible for ensuring that the tools are securely integrated into our website and are in accordance with the applicable privacy laws. Facebook, on the other hand, is e.g. responsible for the data security of Facebook’s products. If you have any questions about Facebook’s data collection and processing, you can contact the company directly. Should you direct the question to us, we are obliged to forward it to Facebook.

In the following we will give you an overview on the different Facebook tools, as well as on what data is sent to Facebook and how you can erase this data.

Along with many other products, Facebook also offers so called “Facebook Business Tools”. This is Facebook’s official name for its tools, but it is not very common. Therefore, we decided to merely call them “Facebook tools”. They include the following:

• Facebook-Pixel
• Social Plugins (e.g. the “Like” or “Share“ button)
• Facebook Login
• Account Kit
• APIs (application programming interface)
• SDKs (Softwart developmept kits)
• Plattform-integrations
• Plugins
• Codes
• Specifications
• Documentations
• Technologies and Services

With these tools Facebook can extend its services and is able to receive information on user activities outside of Facebook.

Why do we use Facebook tools on our website?

We only want to show our services and products to people who are genuinely interested in them. With the help of advertisements (Facebook Ads) we can reach exactly these people. However, to be able to show suitable adverts to users, Facebook requires additional information on people’s needs and wishes. Therefore, information on the user behaviour (and contact details) on our website, are provided to Facebook. Consequently, Facebook can collect better user data and is able to display suitable adverts for our products or services. Thanks to the tools it is possible to create targeted, customised ad campaigns of Facebook.

Facebook calls data about your behaviour on our website “event data” and uses them for analytics services. That way, Facebook can create “campaign reports” about our ad campaigns’ effectiveness on our behalf. Moreover, by analyses we can get a better insight in how you use our services, our website or our products. Therefore, some of these tools help us optimise your user experience on our website. With the social plugins for instance, you can share our site’s contents directly on Facebook.

What data is stored by Facebook tools?

With the use of Facebook tools, personal data (customer data) may be sent to Facebook. Depending on the tools used, customer data such as name, address, telephone number and IP address may be transmitted.

Facebook uses this information to match the data with the data it has on you (if you are a Facebook member). However, before the customer data is transferred to Facebook, a so called “Hashing” takes place. This means, that a data record of any size is transformed into a string of characters, which also has the purpose of encrypting data.

Moreover, not only contact data, but also “event data“ is transferred. These data are the information we receive about you on our website. To give an example, it allows us to see what subpages you visit or what products you buy from us. Facebook does not disclose the obtained information to third parties (such as advertisers), unless the company has an explicit permission or is legally obliged to do so. Also, “event data“ can be linked to contact information, which helps Facebook to offer improved, customised adverts. Finally, after the previously mentioned matching process, Facebook deletes the contact data.

To deliver optimised advertisements, Facebook only uses event data, if they have been combined with other data (that have been collected by Facebook in other ways). Facebook also uses event data for the purposes of security, protection, development and research. Many of these data are transmitted to Facebook via cookies. Cookies are little text files, that are used for storing data or information in browsers. Depending on the tools used, and on whether you are a Facebook member, a different number of cookies are placed in your browser. In the descriptions of the individual Facebook tools we will go into more detail on Facebook cookies. You can also find general information about the use of Facebook cookies at https://www.facebook.com/policies/cookies.

How long and where are the data stored?

Facebook fundamentally stores data, until they are no longer of use for their own services and products. Facebook has servers for storing their data all around the world. However, customer data is cleared within 48 hours after they have been matched with their own user data.

How can I erase my data or prevent data retention?

In accordance with the General Data Protection Regulation (GDPR) you have the right of information, rectification, transfer and deletion of your data.

The collected data is only fully deleted, when you delete your entire Facebook account. Deleting your Facebook account works as follows:

1) Click on settings in the top right side in Facebook.

2) Then, click “Your Facebook information“ in the left column.

3) Now click on “Deactivation and deletion”.

4) Choose “Permanently delete account“ and then click on “Continue to account deletion“.

5) Enter your password, click on “continue“ and then on “Delete account“.

The retention of data Facebook receives via our site is done via cookies (e.g. with social plugins), among others. You can deactivate, clear or manage both all and individual cookies in your browser. How this can be done differs depending on the browser you use. The following instructions show, how to manage cookies in your browser:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

If you generally do not want to allow any cookies at all, you can set up your browser to notify you whenever a cookie is about to be set. This gives you the opportunity to decide upon the permission or deletion of every single cookie.

Legal basis

If you have consented to your data being processed and stored by integrated Facebook tools, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. Nevertheless, we only use these tools if you have given your consent. Most social media platforms also set cookies on your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or Facebook’s cookie policy.

Facebook processes data from you, among other things, in the USA. Facebook respectively Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Facebook uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Facebook commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Facebook Data Processing Term, which references the Standard Contractual Clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

We hope we could give you an understanding of the most important information about the use of Facebook tools and data processing. If you want to find out more on how Facebook use your data, we recommend reading the data policies at https://www.facebook.com/about/privacy/update.

Facebook Lookalike Audience Privacy Policy

We also use the advertising tool Facebook Lookalike Audience. The service provider is the American company Meta Platforms Inc. For the European area, the company Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) is responsible.

Meta Platforms processes data from you, among other things, in the USA. Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Meta Platforms uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Meta Platforms commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Facebook Data Processing Terms, which reference the Standard Contractual Clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

You can learn more about the data processed through the use of Facebook Lookalike Audience in the Privacy Policy at https://www.facebook.com/about/privacy.

Facebook Social Plugins Privacy Policy

We installed so-called social plugins from Facebook Inc. to our website. You can recognise these buttons by the classic Facebook logo, the “Like” button (hand with raised thumb) or by a “Facebook plugin” label. A social plugin is a small part of Facebook that is integrated into our page. Each plugin has its own function. The most used functions are the well-known “Like” and “Share” buttons.

Facebook offers the following social plugins:

• “Save” button
• “Like” button, Share, Send and Quote
• Page plugin
• Comments
• Messenger plugin
• Embedded posts and video player
• Group Plugin

At https://developers.facebook.com/docs/plugins you will find more information on how the individual plugins are used. On the one hand, we use the social plug-ins to offer you a better user experience on our site, and on the other hand because Facebook can optimise our advertisements with it.

If you have a Facebook account or have already visited facebook.com, Facebook has already placed at least one cookie in your browser. In this case, your browser sends information to Facebook via this cookie as soon as you visit our website or interact with social plugins (e.g. the “Like” button).

The received information will be deleted or anonymised within 90 days. According to Facebook, this data includes your IP address, the websites you have visited, the date, time and other information relating to your browser.

In order to prevent Facebook from collecting much data and matching it with your Facebook data during your visit to our website, you must log out of Facebook while you visit our website.

If you are not logged in to Facebook or do not have a Facebook account, your browser sends less information to Facebook because you have fewer Facebook cookies. Nevertheless, data such as your IP address or which website you are visiting can be transmitted to Facebook. We would like to explicitly point out that we do not know what exact data is collected. However, based on our current knowledge, we want to try informing you as best we can about data processing. You can also read about how Facebook uses the data in the company’s data policy at https://www.facebook.com/about/privacy/update.

At least the following cookies are set in your browser when you visit a website with social plugins from Facebook:

Name: dpr
Value: no information
Purpose:This cookie is used to make the social plugins work on our website.
Expiry date: after end of session

Name: fr
Value: 0jieyh4122965942c2GnlufEJ9..Bde09j…1.0.Bde09j
Purpose:The cookie is also necessary for the plugins to function properly
Expiry date: after 3 months

Note: These cookies were set after our test and may be placed even if you are not a Facebook member.

If you are registered with Facebook, you can change your settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can go to https://www.youronlinechoices.com/uk/your-ad-choices/ and manage your usage-based online advertising. There you have the option to deactivate or activate providers.

If you want to learn more about Facebook’s data protection, we recommend the company’s own data policies at https://www.facebook.com/policy.php.

Facebook Fanpage Privacy Policy

We also have a Facebook fan page for our website. The provider of this service is the American company Meta Platforms Inc. The responsible entity for the European area is the company Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).

Facebook processes data from you, among other things, in the USA. Facebook respectively Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Facebook uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Facebook commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Facebook Data Processing Term, which references the Standard Contractual Clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

You can find out more about the data that is processed by using Facebook in their Privacy Policy at https://www.facebook.com/about/privacy.

Instagram Privacy Policy

What is Instagram?

We have integrated functions of Instagram to our website. Instagram is a social media platform of the company Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. Since 2012, Instagram is a subsidiary company of Facebook Inc. and is a part of Facebook’s products. The inclusion of Instagram’s contents on our website is called embedding. With this, we can show you Instagram contents such as buttons, photos or videos directly on our website. If you open websites of our online presence, that have an integrated Instagram function, data gets transmitted to, as well as stored and processed by Instagram. Instagram uses the same systems and technologies as Facebook. Therefore, your data will be processed across all Facebook firms.

In the following, we want to give you a more detailed insight on why Instagram collects data, what data these are and how you can control data processing. As Instagram belongs to Facebook Inc., we have, on the one hand received this information from the Instagram guidelines, and on the other hand from Facebook’s Data Policy.

Instagram is one of the most famous social media networks worldwide. Instagram combines the benefits of a blog with the benefits of audio-visual platforms such as YouTube or Vimeo. To “Insta“ (how the platform is casually called by many users) you can upload photos and short videos, edit them with different filters and also share them to other social networks. Also, if you do not want to be active on Instagram yourself, you can just follow other interesting users.

Why do we use Instagram on our website?

Instagram is a social media platform whose success has skyrocketed within recent years. Naturally, we have also reacted to this boom. We want you to feel as comfortable as possible on our website. Therefore, we attach great importance to diversified contents. With the embedded Instagram features we can enrich our content with helpful, funny or exciting Instagram contents. Since Instagram is a subsidiary company of Facebook, the collected data can also serve us for customised advertising on Facebook. Hence, only persons who are genuinely interested in our products or services can see our ads.

Instagram also uses the collected data for tracking and analysis purposes. We receive summarised statistics and therefore more insight to your wishes and interests. It is important to mention that these reports do not identify you personally.

What data is stored by Instagram?

Whenever you land on one of our sites, which have Instagram functions (i.e. Instagram photos or plugins) integrated to them, your browser automatically connects with Instagram’s servers. Thereby, data is sent to, as well as saved and processed by Instagram. This always happens, whether you have an Instagram account or not. Moreover, it includes information on our website, your computer, your purchases, the advertisements you see and on how you use our offer. The date and time of your interaction is also stored. If you have an Instagram account or are logged in, Instagram saves significantly more data on you.

Facebook distinguishes between customer data and event data. We assume this is also the case for Instagram. Customer data are for example names, addresses, phone numbers and IP addresses. These data are only transmitted to Instagram, if they have been “hashed” first. Thereby, a set of data is transformed into a string of characters, which encrypts any contact data. Moreover, the aforementioned “event data“ (data on your user behaviour) is transmitted as well. It is also possible, that contact data may get combined with event data. The collected data data is matched with any data Instagram already has on you.

Furthermore, the gathered data are transferred to Facebook via little text files (cookies) which usually get set in your browser. Depending on the Instagram function used, and whether you have an Instagram account yourself, the amount of data that gets stored varies.

We assume data processing on Instagram works the same way as on Facebook. Therefore, if you have an account on Instagram or have visited www.instagram.com, Instagram has set at least one cookie. If this is the case, your browser uses the cookie to send information to Instagram, as soon as you come across an Instagram function. No later than 90 days (after matching) the data is deleted or anonymised. Even though we have studied Instagram’s data processing in-depth, we cannot tell for sure what exact data Instagram collects and retains.

In the following we will show you a list of the least cookies placed in your browser when click on an Instagram function (e.g. button or an Insta picture). In our test we assume you do not have an Instagram account, since if you would be logged in to your Instagram account, your browser would place significantly more cookies.

The following cookies were used in our test:

Name: csrftoken
Value: “”
Purpose: This cookie is most likely set for security reasons to prevent falsifications of requests. We could not find out more information on it.
Expiry date: after one year

Name: mid
Value: “”
Purpose: Instagram places this cookie to optimise its own offers and services in- and outside of Instagram. The cookie allocates a unique user ID.
Expiry date: after end of session

Name: fbsr_122965942124024
Value: no information
Purpose: This cookie stores the login request of Instagram app users.
Expiry date: after end of session

Name: rur
Value: ATN
Purpose: This is an Instagram cookie which guarantees functionality on Instagram.
Expiry date: after end of session

Name: urlgen
Value: “8221;194.96.75.33”: 1901:1iEtYv:Y833k2_UjKvXgYe122965942”
Purpose: This cookie serves Instagram’s marketing purposes.
Expiry date: after end of session

Note: We do not claim this list to be exhaustive. The cookies that are placed in each individual case, depend on the functions embedded as well as on your use of Instagram.

How long and where are these data stored?

Instagram shares the information obtained within the Facebook businesses with external partners and persons you are globally connected with. Data processing is done according to Facebook’s internal data policy. Your data is distributed to Facebook’s servers across the world, partially for security reasons. Most of these servers are in the USA.

How can I erase my data or prevent data retention?

Thanks to the General Data Protection Regulation (GDPR), you have the right of information, rectification, transfer and deletion of your data. Furthermore, you can manage your data in Instagram’s settings. If you want to delete your data on Instagram completely, you will have to delete your Instagram account permanently.

And this is how an Instagram account can be deleted:

First, open the Instagram app. Then, navigate to your profile page, select the three bars in the top right, choose “Settings” and then click “Help”. Now, you will be redirected to the company’s website, where you must click on “Managing Your Account” and then “Delete Your Account”.

When you delete your account completely, Instagram deletes posts such as your photos and status updates. Any information other people shared about you are not a part of your account and do therefore not get deleted.

As mentioned before, Instagram primarily stores your data via cookies. You can manage, deactivate or delete these cookies in your browser. Depending on your browser, managing them varies a bit. We will show you the instructions of the most relevant browsers here.

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

Generally, you can set your browser to notify you whenever a cookie is about to be set. Then you can individually decide upon the permission of every cookie.

Legal basis

If you have consented to the processing and storage of your data by integrated social media elements, this consent is the legal basis for data processing (Art. 6 para. 1 lit. a GDPR) . Generally, your data is also stored and processed on the basis of our legitimate interest (Art. 6 para. 1 lit. f GDPR) to maintain fast and good communication with you or other customers and business partners. We only use the integrated social media elements if you have given your consent. Most social media platforms also place cookies in your browser to store data. We therefore recommend you to read our privacy policy about cookies carefully and to take a look at the privacy policy or the cookie policy of the respective service provider.

Instagram processes data from you, among other things, in the USA. Instagram respectively Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Instagram uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Instagram commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

We have tried to give you the most important information about data processing by Instagram. On https://help.instagram.com/519522125107875
you can take a closer look at Instagram’s data guidelines.

Instagram Lookalike Audience Privacy Policy

We also use the advertising tool Instagram Lookalike Audience. The service provider is the American company Meta Platforms Inc. For the European area, the company Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) is responsible.

Meta Platforms processes data from you, among other things, in the USA. Meta Platforms is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Meta Platforms uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Meta Platforms commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The Instagram Data Processing Terms, which reference the Standard Contractual Clauses, can be found at https://www.facebook.com/legal/terms/dataprocessing.

You can learn more about the data processed through the use of Instagram Lookalike Audience in the Privacy Policy at https://privacycenter.instagram.com/policy/.

TikTok Privacy Policy

What is TikTok?

On our website, we use TikTok integration. The service provider is the Chinese company Beijing Bytedance Technology Ltd. For the European region, the responsible entity is the Irish company TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. TikTok is a popular social media platform, especially among young people, where users can create, share, and view short video clips.

In this privacy policy, we inform you about the data processed by TikTok, how long the data is stored, and how you can manage your privacy settings.

Why do we use TikTok on our website?

We have incorporated TikTok into our website so that you can watch TikTok videos if you wish and potentially interact with the videos. TikTok is known for its funny and creative content, and naturally, we don’t want to withhold such content from you. After all, we also enjoy watching creative TikTok videos ourselves.

What data is processed by TikTok?

When you watch TikTok videos on our website or interact with them, TikTok may collect information about your usage behavior and your device. This may include data such as your IP address, browser type, operating system, location, and other technical information. TikTok may also use cookies and similar technologies to collect information and personalize your user experience.

If you have a TikTok account, additional information may be collected and processed. This includes user information (such as name, birthdate, or email address) and data about your communication with other TikTok users.

How long and where are the data stored?

The storage duration and locations of the data collected by TikTok can vary significantly and are subject to TikTok’s privacy policies. TikTok may also store data on servers in the United States and other countries. The storage duration typically complies with applicable legal requirements and internal policies. However, we have not been able to determine the exact duration of data storage. We will inform you as soon as we have more information on this matter.

How can I delete my data or prevent data storage?

If you have a TikTok account, you can manage your privacy settings directly on TikTok. For example, in the settings of your TikTok account, you can specify which information can be shared and which cannot. Additionally, you can manage and disable cookies in your web browser to limit data collection. This is also possible without a TikTok account. However, please note that this may affect the functionality of our website and your TikTok experience.

Legal basis

If you have consented to TikTok processing and storing your data, this consent serves as the legal basis for data processing (Art. 6 para. 1 lit. a GDPR). In general, your data is also stored and processed based on our legitimate interest (Art. 6 para. 1 lit. f GDPR) in effective and efficient communication with you or other customers and business partners. However, we only use embedded social media elements if you have given your consent. TikTok may also set cookies in your browser to store data. Therefore, we recommend that you read our cookie privacy text carefully and view the privacy policy or cookie policies of the respective service provider.

TikTok processes data from you, including in the United States. We would like to inform you that, according to the opinion of the European Court of Justice, there is currently no adequate level of protection for data transfer to the United States. This may entail various risks for the legality and security of data processing.

As the basis for data processing with recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, especially in the United States) or data transfers to such countries, TikTok uses so-called Standard Contractual Clauses (= Art. 46 para. 2 and 3 GDPR). Standard Contractual Clauses (SCC) are model templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the United States). Through these clauses, TikTok commits to maintaining the European level of data protection when processing your relevant data, even when the data is stored, processed, and managed in the United States. These clauses are based on an implementing decision by the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en

For more information about TikTok’s privacy policy and data collection by TikTok, please visit the TikTok website at https://www.tiktok.com/legal/page/eea/privacy-policy/en and the general information about TikTok at https://www.tiktok.com/en/.

Content Delivery Networks

What is a Content Delivery Network?

On our website we use a so-called content delivery network or CDN. This helps to load our website quickly and easily, regardless of your location. Moreover, your personal data will also be stored, managed and processed on the respective CDN provider’s servers. In the following, we will go into more general detail on this service and the data processing associated with it. You can find detailed information on how your data is handled in the provider’s Privacy Policy.

Each content delivery network (CDN) is a network of regionally distributed servers that are connected to each other via the internet. Through this network, website content (especially very large files) can be delivered quickly and smoothly, even when large loading peaks occur. To make this possible, CDNs create a copy of our website on their servers. The website can be delivered quickly because these servers are distributed all around the world. Any data transfer to your browser is therefore significantly shortened by the CDN.

Why do we use a Content Delivery Network for our website?

A fast loading website is part of our service. Of course, we know how annoying it is when a website loads at a snail’s pace. Most of the time, you lose your patience and click away before the website is fully loaded. But of course we want to avoid that. Therefore, to us a fast loading website is an obligatory part of our website offer. With the use of a content delivery network, our website loads significantly faster in your browser. Furthermore, CDNs are particularly helpful when you are abroad, as the website is always delivered from a server in your area.

Which data are processed?

If you access a website or its content and it gets cached in a CDN, the CDN forwards the request to the server closest to you which then delivers the content. Content delivery networks are built in a way that JavaScript libraries can be downloaded and hosted on npm and Github servers. Alternatively, WordPress plugins can also be loaded on most CDNs, provided they are hosted on WordPress.org. Moreover, your browser can send personal data to the content delivery network we use. This includes data such as IP addresses, browser type, browser version, the accessed website or the time and date of the page visit. This data is collected and stored by the CDN. Whether cookies are used for data storage depends on the network that is being used. For more information on this, please read the Privacy Policy of the respective service.

Right to object

If you want to prevent this data transfer altogether, you can use a JavaScript blocker (see for example https://noscript.net/) on your computer. However, our website can then of course no longer offer its usual service (such as a fast loading speeds).

Legal basis

If you have consented to the use of a content delivery network, your consent represents the the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a (consent) your consent represents the legal basis for the processing of personal data, as it can occur when collected by a content delivery network.

We also have a legitimate interest in using a content delivery network to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit. f GDPR (legitimate interests). Nevertheless, we only use the tool if you have consented to it.

Provided this information is available, you can find out more about the particular content delivery networks in the following sections.

Cloudflare Privacy Policy

What is Cloudflare?

We use Cloudflare by the company Cloudflare, Inc. (101 Townsend St., San Francisco, CA 94107, USA) on our website to enhance its speed and security. For this, Cloudflare uses cookies and processes user data. Cloudflare, Inc. is an American company that offers a content delivery network and various security services. These services take place between the user and our hosting provider. In the following, we will try to explain in detail what all this means.

A content delivery network (CDN), as provided by Cloudflare, is nothing more than a network of servers that are connected to each other. Cloudflare has deployed servers around the world, which ensure websites can appear on your screen faster. Simply put, Cloudflare makes copies of our website and places them on its own servers. Thus, when you visit our website, a load distribution system ensures that the main part of our website is delivered by a server that can display our website to you as quickly as possible. The CDN significantly shortens the route of the transmitted data to your browser. Thus, Cloudflare does not only deliver our website’s content from our hosting server, but from servers from all over the world. Cloudflare is particularly helpful for users from abroad, since pages can be delivered from a nearby server. In addition to the fast delivery of websites, Cloudflare also offers various security services, such as DDoS protection, or the web application firewall.

Why do we use Cloudflare on our website?

Of course, we want our website to offer you the best possible service. Cloudflare helps us make our website faster and more secure. Cloudflare offers us web optimisations as well as security services such as DDoS protection and a web firewall. Moreover, this includes a Reverse-Proxy and the content distribution network (CDN). Cloudflare blocks threats and limits abusive bots as well as crawlers that waste our bandwidth and server resources. By storing our website in local data centres and blocking spam software, Cloudflare enables us to reduce our bandwidth usage by about 60%. Furthermore, the provision of content through a data centre near you and certain web optimizations carried out there, cut the average loading time of a website in about half. According to Cloudflare, the setting “I’m Under Attack Mode” can be used to mitigate further attacks by displaying a JavaScript calculation task that must be solved before a user can access a website. Overall, this makes our website significantly more powerful and less susceptible to spam or other attacks.

What data is stored by Cloudflare?

Cloudflare generally only transmits data that is controlled by website operators. Therefore, Cloudflare does not determine the content, but the website operator themselves does. Additionally, Cloudflare may collect certain information about the use of our website and may process data we send or data which Cloudflare has received certain instructions for. Mostly, Cloudflare receives data such as IP addresses, contacts and protocol information, security fingerprints and websites’ performance data. Log data for example helps Cloudflare identify new threats. That way, Cloudflare can ensure a high level of security for our website. As part of their services, Cloudflare process this data in compliance with the applicable laws. Of course, this also includes the compliance with the General Data Protection Regulation (GDPR).

Furthermore, Cloudflare uses a cookie for security reasons. The cookie (__cfduid) is used to identify individual users behind a shared IP address, and to apply security settings for each individual user. The cookie is very useful, if you e.g. use our website from a restaurant where several infected computers are located. However, if your computer is trustworthy, we can recognise that with the cookie. Hence, you will be able to freely and carelessly surf our website, despite the infected PCs in your area. Another point that is important to know, is that this cookie does not store any personal data. The cookie is essential for Cloudflare’s security functions and cannot be deactivated.

Cookies by Cloudflare

Name: __cfduid
Value: d798bf7df9c1ad5b7583eda5cc5e78122965942-3
Purpose: Security settings for each individual visitor
Expiry date: after one year

Cloudflare also works with third party providers. They may however only process personal data after the instruction of Cloudflare and in accordance with the data protection guidelines and other confidentiality and security measures. Without explicit consent from us, Cloudflare will not pass on any personal data.

How long and where is the data stored?

Cloudflare stores your information primarily in the United States and the European Economic Area. Cloudflare can transfer and access the information described above, from all over the world. In general, Cloudflare stores domains’ user-level data with the Free, Pro and Business versions for less than 24 hours. For enterprise domains that have activated Cloudflare Logs (previously called Enterprise LogShare or ELS), data can be stored for up to 7 days. However, if IP addresses trigger security warnings in Cloudflare, there may be exceptions to the storage period mentioned above.

How can I erase my data or prevent data retention?

Cloudflare only keeps data logs for as long as necessary and in most cases deletes the data within 24 hours. Cloudflare also does not store any personal data, such as your IP address. However, there is information that Cloudflare store indefinitely as part of their permanent logs. This is done to improve the overall performance of Cloudflare Resolver and to identify potential security risks. You can find out exactly which permanent logs are saved at https://developers.cloudflare.com/1.1.1.1/commitment-to-privacy/privacy-policy/privacy-policy/. All data Cloudflare collects (temporarily or permanently) is cleared of all personal data. Cloudflare also anonymise all permanent logs.

In their privacy policy, Cloudflare state that they are not responsible for the content you receive. For example, if you ask Cloudflare whether you can update or delete content, Cloudflare will always refer to us as the website operator. You can also completely prevent the collection and processing of your data by Cloudflare, when you deactivate the execution of script-code in your browser, or if you integrate a script blocker to your browser.

Legal basis

If you have consented to the use of Cloudflare, your consent is the legal basis for the corresponding data processing. According to Art. 6 paragraph 1 lit. a (Consent) your consent is the legal basis for the processing of personal data, as can occur when it is collected by Cloudflare.

We also have a legitimate interest in using Cloudflare to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit.f GDPR (legitimate interests). Nevertheless, we only use Cloudflare if you have given your consent to it.

Cloudflare processes data from you, among other things, in the USA. Cloudflare is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Cloudflare uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Cloudflare commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

You can find out more about the standard contractual clauses and the data that is processed by Cloudflare at https://www.cloudflare.com/en-gb/privacypolicy/.

Cookie Consent Management Platform

What is a cookie consent management platform?

We use a Consent Management Platform (CMP) software on our website that makes it easier for us and you to handle the scripts and cookies used correctly and securely. The software automatically creates a cookie pop-up, scans and controls all scripts and cookies, provides you with the cookie consent required under data protection law and helps you and us to keep track of all cookies. Most cookie consent management tools identify and categorize all existing cookies. As a website visitor, you then decide for yourself whether and which scripts and cookies you allow or not. The following graphic shows the relationship between browser, web server and CMP.

Why do we use a cookie management tool?

Our goal is to offer you the best possible transparency in the area of ​​data protection. We are also legally obliged to do so. We want to inform you as well as possible about all tools and all cookies that can save and process your data. It is also your right to decide for yourself which cookies you accept and which you do not. In order to grant you this right, we first need to know exactly which cookies actually landed on our website. Thanks to a cookie management tool, which regularly scans the website for all cookies present, we know about all cookies and can provide you with GDPR-compliant information. You can then use the consent system to accept or reject cookies.

Which data are processed?

As part of our cookie management tool, you can manage each individual cookie yourself and have complete control over the storage and processing of your data. The declaration of your consent is stored so that we do not have to ask you every time you visit our website and we can also prove your consent if required by law. This is saved either in an opt-in cookie or on a server. The storage time of your cookie consent varies depending on the provider of the cookie management tool. Usually this data (e.g. pseudonymous user ID, time of consent, detailed information on the cookie categories or tools, browser, device information) is stored for up to two years.

Duration of data processing

We will inform you below about the duration of the data processing if we have further information. In general, we only process personal data for as long as is absolutely necessary for the provision of our services and products. Data stored in cookies are stored for different lengths of time. Some cookies are deleted after you leave the website, others may be stored in your browser for a few years. The exact duration of the data processing depends on the tool used, in most cases you should be prepared for a storage period of several years. In the respective data protection declarations of the individual providers, you will usually receive precise information about the duration of the data processing.

Right of objection

You also have the right and the option to revoke your consent to the use of cookies at any time. This works either via our cookie management tool or via other opt-out functions. For example, you can also prevent data collection by cookies by managing, deactivating or deleting cookies in your browser.

Information on special cookie management tools can be found – if available – in the following sections.

Legal basis

If you agree to cookies, your personal data will be processed and stored via these cookies. If we are allowed to use cookies with your consent (Article 6 paragraph 1 lit. a GDPR), this consent is also the legal basis for the use of cookies and the processing of your data. In order to be able to manage the consent to cookies and to enable you to give your consent, a cookie consent management platform software is used. The use of this software enables us to operate the website in an efficient and legally compliant manner, which is a legitimate interest (Article 6 paragraph 1 lit. f GDPR).

Cookiebot Privacy Policy

What is Cookiebot?

We use functions of Cookiebot on our website. The company behind Cookiebot is Cybot A/S, Havnegade 39, 1058 Copenhagen, DK. Cookiebot offers us the opportunity to provide you with an extensive cookie notice (also known as a cookie banner or cookie notice).
By using this function, your data can be sent to Cookiebot or Cybot, where it may be saved and processed. In this privacy policy we will inform you on why we use Cookiebot, what data is transmitted and how you can prevent the transmission of data.

Cookiebot is a software product from Cybot. The software automatically creates a GDPR-compliant cookie notice for our website visitors. The technology behind Cookiebot also scans, controls and evaluates all cookies and tracking measures on our website.

Why do we use Cookiebot on our website?

We take data protection very seriously. We want to show you exactly what is happening on our website and which of your data is stored. Cookiebot helps us to get a good overview of all our cookies (first- and third-party cookies). This enables us to be transparent and to inform you precisely on the use of cookies on our website. Cookiebot ensures you always receive an up-to-date and GDPR compliant cookie notice, so you can decide yourself which cookies you allow or deny.

What data are stored by Cookiebot?

If you allow cookies, the following data will be transmitted to Cybot, where it is stored and processed.

• IP address (in anonymous form, the last 3 digits are replaced with 0)
• date and time of your consent
• our website‘s URL
• technical browser data
• encrypted, anonymous key
• the cookies you allowed (as status of consent)

If you have allowed the use of cookies, the following cookies get set by Cookiebot:

Name: CookieConsent
Value: ’P7to4eNgIHvJvDerjKneBsmJQd9122965942-2
Purpose:Your consent status is stored in this cookie. This enables our website to read and follow the current status even for future visits.
Expiry date: after one year

Name: CookieConsentBulkTicket
Value: kDSPWpA%2fjhljZKClPqsncfR8SveTnNWhys5NojaxdFYBPjZ2PaDnUw%3d%3122965942-6
Purpose:This cookie is placed if you allow all cookies and thus have activated “collective consent”. The cookie then stores its own, random and unique ID.
Expiry date: after one year

Note: Please keep in mind that this is an exemplary list and that we do not claim for this list to be exhaustive. In the cookie statement at https://www.cookiebot.com/en/cookie-declaration/ you can read which further cookies may be used.

According to Cybot’s privacy policy, the company does not sell any personal information. However, Cybot shares data with trustworthy third-parties or subcontractors who help the company achieve its business goals. Data may also be transferred if it is legally required.

How long and where is the data stored?

All collected data is only transferred and stored within the European Union. The data is saved in an Azure data centre (with the cloud provider Microsoft). At https://azure.microsoft.com/en-gb/global-infrastructure/regions/ you can find out more on all “Azure regions”. All user data will be deleted by Cookiebot 12 months after registration (cookie consent) or immediately after termination of the Cookiebot service.

How can I erase my data or prevent data retention?

You have the right to access and delete your personal data at any time. You can prevent data collection and storage, by e.g. rejecting the use of cookies via the cookie notice. Furthermore, your browser offers another option to prevent data processing or to manage it according to your wishes. Depending on the browser, the cookie settings work a little differently. Here you will find the instructions for the most popular browsers:

Chrome: Clear, enable and manage cookies in Chrome

Safari: Manage cookies and website data in Safari

Firefox: Clear cookies and site data in Firefox

Internet Explorer: Delete and manage cookies

Microsoft Edge: Delete cookies in Microsoft Edge

Legal basis

If you agree to cookies, your personal data will be processed and stored via these cookies. If we are allowed to use cookies with your consent (Article 6 (1) (a) GDPR), your consent is the legal basis for the use of cookies and the processing of your data. Cookiebot is used to give you the option to give your consent and to manage your cookie consent. The use of this software enables us to operate the website in an efficient and legally compliant manner, which is a legitimate interest (Article 6 (1) lit.f GDPR).

If you want to learn more about the data protection guidelines of “Cookiebot” or the company Cybot, we recommend you to read their privacy policy at https://www.cookiebot.com/en/privacy-policy/.

Payment providers

What is a payment provider?

On our website we use online payment systems, which enable us as well as you to have a secure and smooth payment process available. Among other things, personal data may also be sent to the respective payment provider, where it may also be stored and processed. Payment providers are online payment systems that enable you to place an order via online banking. The payment processing is carried out by the payment provider of your choice. We will then receive information about the payment. This method can be used by any user who has an active online banking account with a PIN and TAN. There are hardly any banks that do not offer or accept such payment methods.

Why do we use payment providers on our website?

With both our website and our embedded online shop, we of course want to offer you the best possible service, so you can feel comfortable on our site and take advantage of our offers. We know that your time is valuable and that payment processing in particular has to work quickly and smoothly. Thus, we offer various payment providers. You can choose your preferred payment provider and pay in the usual way.

Which data are processed?

What exact data that is processed of course depends on the respective payment provider. However, generally data such as name, address, bank details (account number, credit card number, passwords, TANs, etc.) do get stored. This data is necessary for carrying out any transactions. In addition, any contract data and user data, such as when you have visited our website, what content you are interested in or which sub-pages you have clicked, may also be stored. Most payment providers also store your IP address and information about the computer you are using.

Your data is usually stored and processed on the payment providers’ servers. We, so the website operator, do not receive this data. We only get information on whether the payment has gone through or not. For identity and credit checks, it may happen for payment providers to forward data to the appropriate body. The business and privacy policy principles of the respective provider always apply to all payment transactions. Therefore, please always take a look at the general terms and conditions and the privacy policy of the payment provider. You e.g. also have the right to have data erased or rectified at any time. Please contact the respective service provider regarding your rights (right to withdraw, right of access and individual rights).

Duration of data processing

Provided we have further information on this, we will inform you below about the duration of the processing of your data. In general, we only process personal data for as long as is absolutely necessary for providing our services and products. This storage period may be exceeded however, if it is required by law, for example for accounting purposes. We keep any accounting documents of contracts (invoices, contract documents, account statements, etc.) for 10 years (Section 147 AO) and other relevant business documents for 6 years (Section 247 HGB).

Right to object

You always have the right to information, rectification and erasure of your personal data. If you have any questions, you can always contact the person that is responsible for the respective payment provider. You can find contact details for them either in our respective privacy policy or on the relevant payment provider’s website.

You can erase, deactivate or manage cookies in your browser, that payment providers use for their functions. How this works differs a little depending on which browser you are using. Please note, however, that the payment process may then no longer work.

Legal basis

For the processing of contractual or legal relationships (Art. 6 para. 1 lit. b GDPR), we offer other payment service providers in addition to the conventional banking/credit institutions. In the privacy policy of the individual payment providers (such as Amazon Payments, Apple Pay or Discover) you will find a detailed overview of data processing and data storage. In addition, you can always contact the responsible parties should you have any questions about data protection issues.

Provided it is available, you can find information on the special payment providers in the following sections.

Apple Pay Privacy Policy

On our website we use Apple Pay, which is an online payment service. The provider of this service is the American company Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.

Apple also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Apple uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Apple to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about the data that is processed through the use of Apple Pay in their Privacy Policy at https://www.apple.com/ie/legal/privacy/en-ww/.

eps-Überweisung Privacy Policy

On our website we use eps-Überweisung, which is a service for online payment methods. The provider of this service is the Austrian company Stuzza GmbH, Frankgasse 10/8, 1090 Vienna, Austria. You can find out more about the data that is processed by using eps-Überweisung in their privacy policy at https://eservice.stuzza.at/de/datenschutzerklaerung.html.

Google Pay Privacy Policy

On our website we use the online payment provider Google Pay. The provider of this service is the American company Google Inc. The responsible entity for all Google services in the European region is Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland).

Google processes data from you, among other things, in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. More information can be found at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Additionally, Google uses so-called Standard Contractual Clauses (Article 46(2) and (3) GDPR). Standard Contractual Clauses (SCC) are template clauses provided by the EU Commission and are designed to ensure that your data complies with European data protection standards, even when transferred and stored in third countries (such as the USA). Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Google commits to maintaining the European data protection level when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

The data processing terms for Google advertising products (Google Ads Controller Data Protection Terms), which refer to the standard contractual clauses, can be found at https://business.safety.google/intl/en/adscontrollerterms/.

You can find out more about the data processed by using Google Pay in their Privacy Policy at https://policies.google.com/privacy?hl=en-GB.

Mastercard Privacy Policy

We use the payment service provider Mastercard on our website. The provider of this service is the American company Mastercard Inc. The responsible entity for the European region is the company Mastercard Europe SA (Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium).

Mastercard also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Mastercard uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Mastercard to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en

You can find out more about the data processed by using Mastercard in their Privacy Policy at https://www.mastercard.com/global/en/vision/corp-responsibility/commitment-to-privacy/privacy.html.

Mollie Privacy Policy

On our website we use the online payment provider Mollie. The provider of this service is the Dutch company Mollie B.V. Keizersgracht 126, 1015CW Amsterdam, Netherlands.

You can find out more about the data that is processed through the use of Mollie in their Privacy Policy at https://www.mollie.com/en/privacy.

PayPal Check-Out Privacy Policy

We also use the web payment tools by Paypal Check-Out for our business. The service provider is the American company PayPal, Inc. The responsible entity for the European region is the Luxembourgian company PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg.

You can find out more about the data processed by using PayPal Check-Out in their privacy policy at https://www.paypal.com/webapps/mpp/ua/privacy-full.

PayPal Privacy Policy

What is PayPal?

We use the online payment service PayPal on our website. The service provider is the American company PayPal Inc. For the European region, the responsible entity is PayPal Europe (S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg).
With PayPal, all users can send and receive money electronically. The company was founded in 1998 and has since grown to become one of the most well-known and largest online payment service providers worldwide, boasting over 325 million active customers.

Why do we use PayPal for our website?

There are various reasons why we use and offer PayPal on our website. As one of the most recognized online payment providers, many of our website visitors use and trust this service. PayPal also provides high-security standards for digital money transfers, utilizing various encryption methods to protect your personal data. We also appreciate the user-friendly interface of PayPal and the ability to make international payments in different currencies. Transactions typically proceed quickly, benefiting both us and you as customers.

What data does PayPal process?

In its privacy policy, PayPal distinguishes various categories of personal data that may be processed through the use of the service. These include registration and contact details, identification and signature data, payment information, information about imported contacts, data from your account profile, device data such as your IP address, location data, and so-called derived data. Derived data includes information that can be derived from transactions or other data, such as purchasing habits, behavioral patterns, creditworthiness, or personal preferences.
Additionally, there are personal data collected by third parties (such as identity verification providers, fraud detection providers, or your bank). These data may include information from credit agencies, transaction data, information about legal regulations, technical usage data, location data, and derived data once again.

PayPal and its partners also use tracking technologies like cookies, pixel tags, web beacons, and widgets to recognize you as a user, customize content, and conduct analyses for interest-based advertising.

How long and where are the data stored?

In general, PayPal retains data for as long as necessary to fulfill its obligations and within the scope of the purpose. Personal data necessary for the customer relationship is kept for up to 10 years after the relationship ends. If PayPal is subject to a legal obligation, the retention period for personal data complies with the applicable law (e.g., insolvency law). PayPal also stores personal data for as long as necessary if retention is advisable for legal disputes.
As PayPal is a globally operating company, the service has data centers worldwide where your data may be stored. This means your data may be stored outside your country and outside the scope of the GDPR on PayPal servers.

How can I delete my data or prevent data storage?

You have the right to access, correct, delete, and restrict the processing of your personal data at any time. You can also revoke your consent to data processing at any time.
If you want to disable, delete, or manage cookies in general, you can find the corresponding links to the instructions for the most popular browsers in the “Cookies” section.

Legal Basis

We have a legitimate interest in integrating PayPal as an external payment service to make our offer more attractive and improve it technically and economically. The legal basis for this is Art. 6 para. 1 lit. f GDPR (Legitimate interests). Please note that you can only use PayPal if you enter into a contractual relationship with PayPal. In this case, it may be necessary to provide additional data protection and contractual declarations (e.g., consent).
PayPal processes data from you, among other places, in the USA. We would like to inform you that, according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may entail various risks for the legality and security of data processing.

As the basis for data processing for recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, especially in the USA) or data transfers to such countries, PayPal uses so-called Standard Contractual Clauses (Art. 46 para. 2 and 3 GDPR). Standard Contractual Clauses (SCC) are model templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even when transferred and stored in third countries (such as the USA). Through these clauses, PayPal undertakes to comply with the European data protection level in processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses, among other things, here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

For more information on Standard Contractual Clauses and the data processed by using PayPal, please refer to the privacy policy at https://www.paypal.com/webapps/mpp/ua/privacy-full.

Paypal Express Privacy Policy

We also use the web payment tools by PayPal Express for our business. The service provider is the American company PayPal, Inc. The responsible entity for the European region is the Luxembourgian company PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg.

PayPal also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

PayPal uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige PayPal to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about the data processed by using PayPal Express in their privacy policy at https://www.paypal.com/webapps/mpp/ua/privacy-full.

Paypal Widget Privacy Policy

We also use Paypal Widgets for payments on our website. The service provider is the American company PayPal Inc. For the European region, the responsible entity is PayPal Europe (S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg).

PayPal also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

PayPal uses standard contractual clauses approved by the EU Commission as the basis for data processing by recipients based in third countries (i. e. outside the European Union, Iceland, Liechtenstein, Norway, and thus especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). Standard Contractual Clauses (SCC) are legal templates provided by the EU Commission. Their purpose is to ensure that your data complies with European data privacy standards, even if your data is transferred to and stored in third countries (such as the USA). With these clauses, PayPal commits to comply with the EU‘s level of data protection when processing relevant data, even if it is stored, processed and managed in the USA.

These clauses are based on an implementing order by the EU Commission. You can find the order and the standard contractual clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847.

For more information on the Standard Contractual Clauses and the data processed through the use of PayPal Widgets, refer to the privacy policy at https://www.paypal.com/webapps/mpp/ua/privacy-full.

Visa Privacy Policy

On our website we use Visa which is a global payment provider. The provider of this service is the American company Visa Inc. The responsible entity for the European region is the company Visa Europe Services Inc. (1 Sheldon Square, London W2 6TT, United Kingdom).

Visa also processes data in the USA, among other countries. We would like to note, that according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This can be associated with various risks to the legality and security of data processing.

Visa uses standard contractual clauses approved by the EU Commission as basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway and especially in the USA) or data transfer there (= Art. 46, paragraphs 2 and 3 of the GDPR). These clauses oblige Visa to comply with the EU‘s level of data protection when processing relevant data outside the EU. These clauses are based on an implementing order by the EU Commission. You can find the order and the clauses here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

You can find out more about the data processed through the use of Visa in the Privacy Policy at https://www.visa.co.uk/legal/privacy-policy.html.

Online Map Services Introduction

What are Online Map Services?

We also use online map services for our website as an extended service. Google Maps is probably the service you are most familiar with. But there are also other providers out there that specialise in creating digital maps. These services allow the display of locations, route maps or other geographical information directly via our website. Thanks to an integrated map service, you no longer have to leave our website to e. g. view the route to a location. In order to ensure that the online map can run on our website, we have integrated map sections within our HTML code. This way the services can display street maps, the earth’s surface, or aerial or satellite imagery. If you use the built-in map service, your data will be transferred to the tool used, where it will be retained. This may also include your personal data.

Why do we use Online Map Services on our website?

Generally speaking, it is imperative for us to offer you a pleasant time on our website. Of course, we know that you will most likely only enjoy your time here if you can easily find your way around and find all the information you need quickly and easily. Therefore, we decided that an online map system may be a significant optimisation of our website’s service. After all, you can use the map system to easily view route descriptions, locations or any other points of interest – without leaving our site. Needless to say, it is certainly also very practical that you can easily see where our company headquarters are so that you can find us quickly and safely. As you can see, there are just a lot of advantages – and we clearly consider online map services on our website to be part of our customer service.

What data is stored by Online Map Services?

If you open a page on our website with an online map function installed, your personal data may be transmitted to the relevant service, where it may be stored. This usually includes your IP address, which may also be used to determine your approximate location. In addition to your IP address, data such as the search terms you entered, as well as your longitude and latitude coordinates will be stored. If you e. g. enter an address for route planning, this data will also be stored. This data is not stored by us but instead on the servers of the integrated tools. You can think of it like this: You may be on our website, but when you interact with a mapping service, that interaction is actually happening on their website. Moreover, in order for the service to function properly, at least one cookie is usually set in your browser. As an example, Google Maps also uses cookies to record user behaviour, with which it can optimise its own service and offer personalised advertising. You can find out more about cookies in our “Cookies” section.

How long and where is the data stored?

Every online map service processes different user data. Provided we have further information, we will inform you about the duration of data processing in the corresponding sections on the individual tools below. Generally, personal data is only retained for as long as is necessary to provide the service. Google Maps e. g. stores certain data for a specified period of time, but you must erase other data yourself. At Mapbox, for example, your IP address is stored for 30 days after which it is deleted. As you can see, each tool stores data for different lengths of time. We thus recommend you take a closer look at the privacy policies of the tools used.

The providers may use cookies to store data on your user behaviour in relation to their map services. You can find more information about cookies in our “Cookies” section, but in the individual providers’ privacy policies you can most probably also find out which cookies may be used. In most cases, however, this is only an indicative list and is not exhaustive.

Right to object

You always have the possibility and the right to access your personal data and to object to its use and processing. You can also revoke the consent you gave to us at any time. This is usually easiest through the cookie consent tool. However, there are other opt-out tools that you can use. You can also manage, erase or deactivate any cookies set by the used providers yourself with just a few mouse clicks. However, this may lead to some service functions stopping to work as usual. It also depends on your browser how you can manage cookies there. In our “Cookies” section you will find links to instructions of the most popular browsers.

Legal Basis

If you have agreed to the use of an online map service, the legal basis for the corresponding data processing is this consent. According to Article 6 Paragraph 1 lit. (consent) this consent is the legal basis for the processing of personal data as may occur when collected by an online map service.

We also have a legitimate interest in using an online map service to optimise our service on our website. The corresponding legal basis for this is Article 6 (1) (f) GDPR (legitimate interests). However, we only use an online map service if you have given your consent. We definitely wanted to stress this point once again.

You can find information on specific online map services – if available – in the following sections.

Explanation of the terminology used

We always strive to make our privacy policy as clear and comprehensible as possible. However, this is not always easy, especially when it comes to technical and legal matters. It is often sensible to use legal terms (such as ‘personal data)’ or certain technical terms (such as ‘cookies’ or ‘IP address’). But we don’t want to use such terms without any explanation. This is why you will find an alphabetical list of important terms used below. These are terms we may not yet have sufficiently explained in the privacy policy. In case we have adopted any of these terms from the GDPR which are definitions, we will also list the GDPR texts here and add our own further explanations if necessary.

Processor

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Explanation: As a company and a website owner, we are responsible for all your data we process (i. e. the ‘controller’). In addition to the controller, there may also be so-called processors. This includes any company or person who processes personal data on our behalf. In addition to service providers such as tax consultants, processors can also be hosting or cloud providers, payment or newsletter providers or large companies such as Google or Microsoft.

Third party

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Explanation: The GDPR basically only explains what a “third party” is not. In practice, any “third party” who also has an interest in personal data, but not the persons mentioned above, are authorities or institutions. For example, a parent company can act as a “third party”. In this case, the subsidiary company is the controller and the parent company is the “third party”. However, this does not mean that the parent company may automatically view, collect or store personal data of the subsidiary.

Consent

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Explanation: With websites, such consent is usually given via a cookie consent tool. You’ve most certainly come across these. Whenever you visit a website for the first time, you will usually be asked via a banner whether you agree or consent to the data processing. You can usually also make individual settings and thus decide for yourself which level of data processing you want to allow. If you do not give your consent, no personal data may be processed. Consent can of course also be given in writing, i.e. not via a tool.

Recipient

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

Explanation: Any person or establishment that receives personal data is considered a recipient. We and our processors are therefore also so-called recipients. Only authorities that have an investigation mandate are not considered recipients.

Data concerning health

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Data concerning health” means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;

Explanation: Health data includes all stored information relating to your own health. It is often data that is also noted in patient files. This includes, for example, which medication you are using, X-rays, your entire medical history or your vaccination statuses.

Personal Data

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“personenal 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Explanation: Personal data is all data that can identify you as a person. This is usually data such as:

• name
• address
• email address
• postal address
• phone number
• birthday
• identification numbers such as social security number, tax identification number, ID card number or matriculation number
• banking data such as account number, credit information, account balances and more.

According to the European Court of Justice (ECJ), your IP address is also personal data. IT experts can use your IP address to determine at least the approximate location of your device and subsequently your location as the connection owner. Therefore, storing an IP address also requires a legal basis within the scope of the GDPR. There are also so-called “special categories” of personal data, which are particularly worthy of protection. These include:

• racial and ethnic origin
• political opinions
• religious or ideological beliefs
• Union membership
• genetic data such as data obtained from blood or saliva samples
• biometric data (this is information about psychological, physical or behavioural characteristics that can identify an individual).
  health Data
• Data relating to sexual orientation or sex life

Profiling

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Explanation: Profiling collects various personal data about an individual in order to learn more about that individual. On the internet, profiling is often used for advertising purposes or for credit checks. Web and advertising analysis programs e. g. collect data about your behaviour and interests on a website. This results in a special user profile that can be used to target advertising to specific target groups.

Controller

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Explanation: In our example, we are responsible for the processing of your personal data and are therefore the “controller”. If we pass on collected data to other service providers for processing, they are considered “contract processors”. For this, a “Data Processing Agreement (DPA)” must be concluded.

Processing

Definition according to Article 4 of the GDPR

For the purposes of this Regulation, the term means:

“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, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Note: When we talk about processing in our Privacy Policy, we talk about any type of data processing. As mentioned above in the original GDPR declaration, this includes not only the collection but also the storage and processing of data.

Closing Remarks

Congratulations! If you are reading these lines, you have most likely familiarised yourself with our entire Privacy Policy – or at least scrolled down here. As you can see from the scope of our Privacy Policy, we do not take the protection of your personal data lightly.
We find it important to inform you about the processing of your personal data to the best of our abilities. In doing so, we not only want to tell you which data is processed but also explain to you why we use various software programs. In general, Privacy Policies have very technical and legal jargon. However, since most of you are not web developers or solicitors, we wanted to take a different approach and explain the facts in simple and clear language. Of course, this is not always possible due to the subject matter. Therefore, you can also find a more detailed explanation of the most important terms at the end of the Privacy Policy.
If you have any questions about data protection on our website, please do not hesitate to contact us or the responsible body. We wish you all the best and hope to soon welcome you to our website again.

All texts are copyrighted.