Privacy policy

28.02.2024

Table of contents

Responsible persons

Henry Albert Jupiter, Hommel / Turbular UG (limited liability)
Bommersheimer Weg 35a
61348, Bad Homburg v.d. Höhe, Germany
E-mail address: henry@turbular.com

Raffael Leon, Schön / Turbular UG (limited liability)
Hardtwaldallee 23a
61381, Friedrichsdorf-Seulberg, Germany
E-mail address: raffael@turbular.com

Overview of processing

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

Types of data processed

  • Inventory data.
  • Payment data.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.

Categories of affected persons

  • Customers.
  • Interested parties.
  • Communication partner.
  • Users.
  • Business and contractual partners.

Purposes of the processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Contact enquiries and communication.
  • Safety measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organisational procedures.
  • Managing and responding to enquiries.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Application procedure.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Only the German version of this document is legally binding, all other versions are provided for the convenience of the user only.

Relevant legal bases according to the GDPR: 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.
  • Contract fulfilment and pre-contractual enquiries (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.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.

Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

Safety measures

We take appropriate technical and organisational 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, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses 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 data protection-friendly default settings.

Transmission of personal data

As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organisational 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.

International data transfers

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 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 only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ . As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

Rights of the data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your 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 information about this data and further information and a copy of the data in accordance with the 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 the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions of an online service used. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the consent they have given. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (so-called 'opt-out'): Users can revoke the consent they have given at any time and object to the processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) 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 related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and efficient business management as well as in security measures to protect our contractual partners and our business operations from misuse, endangering their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. 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 labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

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. The statutory retention period is ten years for documents relevant under tax law and for trading books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting records, and six years for commercial and business letters received and reproductions of commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent or the accounting voucher was created, the record was made or the other documents were created.

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.

  • 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 contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Persons affected: Customers; interested parties. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; contact requests and communication; office and organisational procedures. Managing and responding to enquiries.
  • Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Customer account: Customers can create an account within our online offering (e.g. customer or user account, 'customer account' for short). If it is necessary to register a customer account, customers will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been cancelled, the customer account data will be deleted after the cancellation date, unless it is stored for purposes other than provision in the customer account or must be stored for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer's responsibility to back up their data when cancelling the customer account; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) .
  • Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as 'users') in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is labelled as such in the context of the conclusion of an order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) .

Providers and services used in the course of business activities

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers ('services' for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and secure provision, analysis, optimisation and economic operation of our online offering. We would like to point out that user data may be processed outside the European Union (EU) or the European Economic Area (EEA).

  • 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); content data (e.g. entries in online forms); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta and communication data (e.g. device information, IP addresses).
  • Data subjects: Customers; Interested parties; Users (e.g. website visitors, users of online services); Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
  • Legal basis: 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 is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies for the purpose of identity and credit checks. Please refer to the general terms and conditions and the data protection information of the payment service providers.

Payment transactions are subject to the terms and conditions and 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 cancellation, information and other data subject rights.

  • 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Persons affected: Customers. Interested parties.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

  • Stripe: Payment services (technical connection of online payment methods); Service provider:Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https: //stripe.com ; Privacy Policy: https: //stripe.com/de/privacy . Basis for third country transfers: Data Privacy Framework (DPF).

Provision of the online offer and web hosting

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

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Collection of access data and log files: Access to our online offering is logged in the form of so-called 'server log files'. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) . Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (user name, password and an e-mail address).

As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests and those of the user in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

  • 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); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; administration and responding to enquiries. Provision of our online services and user-friendliness.
  • Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Registration with real names: Due to the nature of our community, we ask users to only use our services using real names. This means that the use of pseudonyms is not permitted; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) .
  • Setting the visibility of profiles: Users can use settings to determine the extent to which their profiles are visible or accessible to the public or only to certain groups of people; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) .

Single sign-on login

Single sign-on' or 'single sign-on registration or authentication' refers to procedures that allow users to log in to a provider of single sign-on procedures (e.g. a social network), including our online offering, with the help of a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via a button.

Authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider under this user ID and an ID that cannot be used by us for other purposes (so-called 'user handle'). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, it can be different data, usually the e-mail address and the user name. The password entered with the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are asked to note that their details stored with us can be automatically synchronised with their user account with the single sign-on provider, but that this is not always possible or actually takes place. If, for example, users' e-mail addresses change, they must change them manually in their user account with us.

If agreed with the users, we can use single sign-on registration as part of or before the fulfilment of the contract, insofar as the users have been asked to do so, as part of consent processing and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure registration system.

Should users ever decide that they no longer wish to use the link to their user account with the single sign-on provider for the single sign-on procedure, they must cancel this link within their user account with the single sign-on provider. If users wish to delete their data with us, they must cancel their registration with us.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures. Registration procedure.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Google Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https: //www.google.de ; Privacy Policy: https: //policies.google.com/privacy ; Basis for third country transfers: Data Privacy Framework (DPF). Possibility of objection (opt-out): Settings for the display of adverts: https: //myadcenter.google.com/ .
  • Microsoft Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider:Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/security/business/identity-access/azure-active-directory-single-sign-on ; Privacy Policy: https: //privacy.microsoft.com/de-de/privacystatement ; Basis for transfers to third countries:Data Privacy Framework (DPF). Further information: https: //www.microsoft.com/de-de/trust-center .

Contact and enquiry management

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

  • 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • Affected persons: Communication partner.
  • Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) .

Newsletter and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter referred to as 'newsletters') with the consent of the recipient or with legal authorisation. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide 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 after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people's e-mail addresses. Subscriptions to 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 by the mailing 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 deleting 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 defence against claims. An individual request for erasure 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 block list solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is 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 dispatch system.

Contents:

Information about us, our services, promotions and offers.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); 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).
  • 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 cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail.

Further information on processing operations, procedures and services:

  • 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 behaviour based on their retrieval locations (which can be determined with the help of 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 they are deleted. The analyses help us to recognise 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 as well as the storage of the measurement results in the user profiles and their further processing are based on our legitimate interests in the alignment with the interests of the users; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) .

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 store the data required to prove the previous authorisation for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).

  • 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 bases: 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 optimisation

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

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

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

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, 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 processes.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers.
    Pseudonymised user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https: //marketingplatform.google.com/intl/de/about/analytics/ ; Security measures: IP masking (pseudonymisation of the IP address); Privacy Policy: https: //policies.google.com/privacy ; Data processing agreement: https: //business.safety.google/adsprocessorterms/ ; Basis for third country transfers: Data Privacy Framework (DPF); Opt-Out: Opt-out plug-in: https: //tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of adverts: https: //myadcenter.google.com/personalizationoff . Further information: https: //business.safety.google/adsservices/ (types of processing and processed data).

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 behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour 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 user's data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
  • 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).

Further information on processing operations, procedures and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https: //www.instagram.com ; Privacy Policy: https: //instagram.com/about/legal/privacy . Basis for third country transfers: Data Privacy Framework (DPF).
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https: //www.linkedin.com ; Privacy Policy: https: //www.linkedin.com/legal/privacy-policy ; Basis for third country transfers: Data Privacy Framework (DPF); Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out ; Further information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data for the purpose of creating the "page insights" (statistics) of our LinkedIn profiles.
    This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: h ttps:// www.linkedin.com/legal/privacy-policy
    We have concluded a special agreement with LinkedIn Ireland ('Page Insights Joint Controller Addendum (the 'Addendum' ) ' , https://legal.linkedin.com/pages-joint-controller-addendum ), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, which relates in particular to the transfer of data to the parent company LinkedIn Corporation in the USA.
  • Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https: //www.pinterest.com . Privacy Policy: https: //policy.pinterest.com/de/privacy-policy .
  • X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Privacy Policy: https: //twitter.com/privacy , (Settings: https: //twitter.com/personalization ).
  • Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https: //www.xing.com/ . Privacy Policy: https: //privacy.xing.com/de/datenschutzerklaerung .

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'). These may be, 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 endeavour 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 analyse 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.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible licensing restrictions. The IP address of the user is communicated to the provider of the fonts so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts 'Analytics' page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to place targeted adverts; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https: //fonts.google.com/ ; Privacy Policy: https: //policies.google.com/privacy ; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https: //developers.google.com/fonts/faq/privacy?hl=de .

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