PUREPROGRESS GmbH

Privacy policy

Introduction

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

The terms used are not gender-specific.

Status: October 31, 2021

Table of contents

Person responsible

PUREPROGRESS GmbH
Zollikerstr. 153
8008 Zurich
Switzerland

Persons authorized to represent the company: Alexander Haile.

E-mail address: info@pureprogress.ch.

Imprint: https://pureprogress-logistics.com/kontakt.

Overview of processing

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

Types of data processed

  • Event data (Facebook) (“event data” is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or in other ways), and relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include actual content (such as comments written, login information, product purchases, etc.).The event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.)
  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of affected persons

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

Purposes of the processing

  • Assessment of creditworthiness and credit standing.
  • Provision of our online services and user-friendliness.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
  • Office and organizational procedures.
  • Content Delivery Network (CDN).
  • Direct marketing (e.g. by e-mail or post).
  • Target group formation.
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

  • Credit report (decision based on a credit check).

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 2 lit. b GDPR are processed as part of the application procedure. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or data subject can exercise their rights under employment law and social security and social protection law and comply with their obligations in this regard, their processing is carried out in accordance with Art. 9 (1) GDPR. 2 lit. b. GDPR, in the case of the protection of vital interests of applicants or other persons acc. Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnosis, health or social care or treatment or for the management of health or social care systems and services in accordance with Article 6(1)(c) GDPR. Art. 9 para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

National data protection regulations in Switzerland: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Switzerland. This includes in particular the Federal Act on Data Protection (FADP). The DPA applies in particular if no EU/EEC citizens are affected and, for example, only data of Swiss citizens is processed.

Security measures

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted and we respond to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

Transmission of personal data

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

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 6 para. 1 lit. a GDPR). 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

As part of our data protection information, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.

Use of cookies

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

A distinction is made between the following cookie types and functions:

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

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

Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

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

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers named in the cookie consent management procedure can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Business services

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

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

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

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

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

Agency services: We process our clients’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services.

Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our consulting services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.

If it is necessary for the performance of our contract, for the protection of vital interests or by law, or if the client’s consent has been obtained, we disclose or transfer the client’s data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Brokerage and agency services: We process the data of our customers, clients and interested parties (uniformly referred to as “customers”) in accordance with the underlying mandate of the customers. We may also process information on the characteristics and circumstances of persons or items belonging to them if this is part of the subject matter of our order. This may include, for example, information on personal circumstances, movable or immovable property and the financial situation.

If necessary for the fulfillment of the contract or required by law or approved by the customer or based on our legitimate interests, we disclose or transmit the customer’s data to providers of the brokered services/properties, insurers, reinsurers, broker pools, technical service providers, other service providers, such as cooperating associations, as well as financial service providers, credit institutions and capital investment companies, social insurance carriers, tax authorities, tax consultants, legal advisors, auditors, insurance ombudsmen and the Federal Financial Supervisory Authority (BaFin) in the context of requests for cover, the conclusion and processing of contracts.B. cooperating associations, as well as financial service providers, credit institutions and investment companies as well as social insurance institutions, tax authorities, tax consultants, legal advisors, auditors, insurance ombudsmen and the Federal Financial Supervisory Authority (BaFin). Furthermore, subject to other agreements, we may engage subcontractors, such as sub-brokers.

Legal advice: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our contractual or pre-contractual services, in particular advisory services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.

If the client’s consent has been obtained, if it is necessary for the performance of our contract, by law or to protect vital interests, or if it is done on the basis of our legitimate interests in the efficient and secure performance of our activities, we disclose or transfer the client’s data to third parties or agents, such as authorities, courts or in the area of IT, office or comparable services, in compliance with the requirements of professional law.

Management consulting: We process the data of our customers, clients, interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and business relationship.

If it is necessary for the fulfillment of our contract or required by law, or if the customer has given their consent, we disclose or transfer the customer’s data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with professional regulations.

  • Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. email, telephone numbers), Contract data (e.g. subject matter of the contract, duration, customer category).
  • Persons concerned: Interested parties, business and contractual partners, clients, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to inquiries.
  • Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Sales via online marketplaces and platforms

We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms to measure reach and for interest-based marketing.

  • Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. e-mail, telephone numbers), Contract data (e.g. contract object, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Persons affected: Customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment procedure

As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively referred to as “payment service providers”).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the payment service provider’s terms and conditions and data protection information.

Payment transactions are subject to the terms and conditions and the data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.

  • Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contract data (e.g. subject matter of the contract, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Credit check

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.

We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.

If we obtain express consent from contractual partners, the legal basis for the credit report and the transfer of the customer’s data to the credit agencies is consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the security of our payment claims.

  • Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. email, telephone numbers), Contract data (e.g. subject matter of the contract, duration, customer category).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: Assessment of creditworthiness and credit standing.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Automated decisions in individual cases: Credit information (decision based on a credit check).

Services used and service providers:

Provision of the online offer and web hosting

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

The data processed as part of the provision of the hosting service may include all information relating to the users of our online service that is generated during use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server.

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

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

Content delivery network: We use a content delivery network (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, Content Delivery Network (CDN).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or contribution and are therefore interested in the identity of the author.

Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.

On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple votes.

The personal information provided as part of the comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects.

Retrieval of WordPress emojis and smilies: Graphic emojis (or smilies), i.e. small graphic files that express feelings, are used within our WordPress blog for the purpose of efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the user’s browser.

Akismet anti-spam check: We use the “Akismet” service on the basis of our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, details of the browser used and the computer system and the time of the entry.

Users are welcome to use pseudonyms or refrain from entering their name or e-mail address. You can completely prevent the transfer of data by not using our comment system. That would be a shame, but unfortunately we don’t see any alternatives that work just as effectively.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and customer support, Feedback (e.g. collecting feedback via online form), Security measures, Managing and responding to inquiries.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Contact and inquiry management

When contacting us (e.g. by contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The response to contact inquiries and the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to inquiries and maintaining user or business relationships.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms).
  • Affected persons: Communication partner.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your options to object.

You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.

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

However, we would also like to point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and process technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).

Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.

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

  • Processed data types: Contact data (e.g. e-mail, telephone numbers), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Content data (e.g. entries in online forms).
  • Affected persons: Communication partner.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Application procedure

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

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

If provided, applicants can send us their applications using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

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

Applicants are welcome to contact us about how to submit their application or send it to us by post.

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under employment law and social security and social protection law and comply with their obligations in this regard, their processing is carried out in accordance with Art. 9 para. 1 GDPR. 2 lit. b. GDPR, in the case of the protection of vital interests of applicants or other persons acc. Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for the provision of health or social care or treatment, or for the management of health or social care systems and services in accordance with Article 6(1)(c) GDPR. Art. 9 para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

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

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Processed data types: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
  • Persons concerned: Applicants.
  • Purposes of processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. The cloud service providers also process usage data and metadata that they use for security purposes and to optimize their services.

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

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

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Newsletter and electronic notifications

We only send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Our newsletters also contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to enter your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with other people’s e-mail addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

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

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

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

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

Measurement of opening and click rates: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The measurement of opening rates and click rates and the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user’s consent.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted.

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Meta/communication data (e.g. device information, IP addresses), Usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Option to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

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

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

Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.

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

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Affected persons: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas need to be optimized.

In addition to web analysis, we may also use test procedures, e.g. to test and optimize different versions of our online offering or its components.

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

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

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

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Online marketing

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

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

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

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

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

We only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.

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

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

We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on users’ presumed interests. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products that they were interested in on other online offers, this is referred to as “remarketing”.

With the help of the Facebook pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), Facebook is able to determine the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network”). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) (“event data” is data that can be transmitted by us to Facebook via Facebook pixels (via apps or other means), for example, and relates to individuals or their actions; the data includes, for example. Information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.)
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: marketing, profiles with user-related information (creation of user profiles), remarketing, target group formation (determination of target groups relevant for marketing purposes or other output of content), conversion measurement (measurement of the effectiveness of marketing measures), target group formation.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called “opt-out”) specified for the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may limit the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:

    a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:

Customer reviews and evaluation process

We take part in review and evaluation processes in order to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the evaluation platforms or procedures involved, the general terms and conditions or terms of use and the providers’ data protection notices also apply. As a rule, the evaluation also requires registration with the respective provider.

In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer’s consent. This data is used solely to verify the authenticity of the user.

Rating widget: We integrate so-called “rating widgets” into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. Although the corresponding content of the widget is displayed within our online offering, it is retrieved from the servers of the respective widget provider at that moment. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offering to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address), which is necessary so that the content of the widget can be delivered to the user’s browser.

Furthermore, the widget provider receives information that users have visited our website. This information can be stored in a cookie and used by the widget provider to recognize which online offers that participate in the evaluation process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes.

  • Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, users (e.g. website visitors, users of online services).
  • Purposes of processing: feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

  • Google Customer Reviews: Service for obtaining and/or presenting customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacyIn the context of obtaining customer reviews, an identification number and time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer’s e-mail address and their country of residence as well as the review details themselves are processed; further information on the types of processing and the data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Presence in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights.

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

For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

Facebook pages: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e.g. B. IP addresses, operating system, browser type, language settings, cookie data; see under “Device information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights”, for page operators to help them understand how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights”(https://www.facebook.com/legal/terms/information_about_page_insights_data).

  • Processed data types: Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Plugins and embedded functions and content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

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

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

Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP address of the users and can process it for the purposes of transmission of the software to the user’s browser and for security purposes, as well as for the evaluation and optimization of their offer.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services used and service providers:

  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually in the context of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-out plugin: https: //tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Maps APIs and SDKs: Interfaces to Google’s map and location services, which allow, for example, the addition of address entries, location determination, distance calculations or the provision of additional information on locations and other places; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy.
  • reCAPTCHA: We integrate the “reCAPTCHA” function in order to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Management, organization and support tools

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

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.

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

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

  • Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

Amendment and updating of the privacy policy

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

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

Rights of the data subjects

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

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

Definitions of terms

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

  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if the data subject consents, if they are necessary for the performance of a contract or if national laws permit these decisions.
  • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
  • IP masking: “IP masking” refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing procedures, especially in online marketing
  • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can track whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: The term “remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
  • Target group formation: Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products. The term “lookalike audiences” (or similar target groups) is used when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.

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Our company
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  • ✓ Fair prices
  • ✓ Fast service
  • ✓ Professional advice
  • ✓ Offices in three countries
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