Privacy Policy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter "data") in the course of providing our services and within our online offering and the websites, functions and content connected with it (hereinafter jointly referred to as the "online offering"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller

Types of data processed

• Inventory data (e.g. personal master data, names, addresses)
• Contact data (e.g. email, telephone numbers)
• Content data (e.g. text entries, photographs, videos)
• Usage data (e.g. websites visited, interest in content, access times)
• Meta and communication data (e.g. device information, IP addresses)

Categories of data subjects

• Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as "users").

Purpose of processing

• Provision of the online offering, its functions and content
• Answering contact enquiries and communicating with users
• Security measures
• Anonymised web analysis

Terms used

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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.

"Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

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

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR we inform you of the legal bases of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEA, the following applies unless the legal basis is stated in this privacy policy:

The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR;

The legal basis for processing in order to perform our services and carry out contractual measures as well as to answer enquiries is Art. 6 (1) (b) GDPR;

The legal basis for processing in order to fulfil our legal obligations is Art. 6 (1) (c) GDPR;

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) GDPR serves as the legal basis.

The legal basis for processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) (e) GDPR.

The legal basis for processing to safeguard our legitimate interests is Art. 6 (1) (f) GDPR.

The processing of data for purposes other than those for which they were collected is governed by the requirements of Art. 6 (4) GDPR.

The processing of special categories of data (as defined in Art. 9 (1) GDPR) is governed by the requirements of Art. 9 (2) GDPR.

Security measures

In accordance with the legal requirements and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data as well as the access, input, disclosure, availability and separation relating to them. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data and a response to any threat to the data. We also take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Cooperation with processors, joint controllers and third parties

Where, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transmit data to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g. where a transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract), where users have consented, where a legal obligation provides for this, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

Where we disclose data to other companies within our group of companies, transmit data to them or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with the legal requirements.

Transfers to third countries

Where we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation), or where this occurs in the course of using third-party services or of disclosing or transmitting data to other persons or companies, this is done only where it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to express consent or a contractually required transfer, we process, or allow the processing of, data in third countries only where a recognised level of data protection exists — which includes in particular the EU-US Data Privacy Framework (DPF) — or on the basis of specific safeguards, such as a contractual obligation through the European Commission's standard contractual clauses, the existence of certifications or binding corporate rules (Art. 44 to 49 GDPR, information page of the European Commission).

Rights of data subjects

You have the right to request confirmation as to whether data concerning you are being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the legal requirements.

In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, in accordance with the legal requirements, to request a restriction of the processing of the data.

You have the right to request that data concerning you which you have provided to us be received in accordance with the legal requirements, and to request that they be transmitted to other controllers.

You also have the right, in accordance with the legal requirements, to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw consent you have given with effect for the future.

Right to object

You may object at any time, in accordance with the legal requirements, to the future processing of data concerning you. The objection may be made in particular against processing for direct marketing purposes.

Cookies and the right to object to direct marketing

"Cookies" are small files stored on users' computers. Different information can be stored within cookies. A cookie primarily serves to store information about a user (or about the device on which the cookie is stored) during or after their visit within an online offering. Cookies that are deleted after a user leaves an online offering and closes their browser are referred to as temporary cookies, "session cookies" or "transient cookies". Such a cookie can store, for example, the contents of a shopping basket in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users return after several days. Such a cookie can likewise store users' interests, which are used for audience measurement or marketing purposes. Cookies offered by providers other than the controller operating the online offering are referred to as "third-party cookies" (otherwise, if they are only that controller's cookies, they are referred to as "first-party cookies").

We may use temporary and permanent cookies and explain this within our privacy policy.

Where we ask users for consent to the use of cookies (e.g. as part of a cookie consent notice), the legal basis for this processing is Art. 6 (1) (a) GDPR. Otherwise, users' personal cookie data are processed in accordance with the explanations below within this privacy policy on the basis of our legitimate interests (i.e. an interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), or, where the use of cookies is necessary for the provision of our contractual services, pursuant to Art. 6 (1) (b) GDPR, or, where the use of cookies is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, pursuant to Art. 6 (1) (e) GDPR.

If users do not wish cookies to be stored on their computer, they are asked to deactivate the relevant option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site https://optout.aboutads.info/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by switching them off in the browser settings. Please note that in that case not all functions of this online offering may be usable.

Erasure of data

The data processed by us are erased, or their processing restricted, in accordance with the legal requirements. Unless expressly stated within this privacy policy, the data stored by us are erased as soon as they are no longer required for their intended purpose and the erasure does not conflict with any statutory retention obligations.

Where data are not erased because they are required for other and legally permissible purposes, their processing is restricted. This means the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Changes and updates to this privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We 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 participation on your part (e.g. consent) or any other individual notification.

Business-related processing

In addition, we process

• Contract data (e.g. subject matter of the contract, term, customer category)
• Payment data (e.g. bank details, payment history)

of our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Agency services

We process our customers' data within the scope of our contractual services, which include 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.

In doing so, we process inventory data (e.g. customer master data such as names or addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), contract data (e.g. subject matter of the contract, term), payment data (e.g. bank details, payment history), usage data and metadata (e.g. in the course of evaluating and measuring the success of marketing measures). As a rule we do not process special categories of personal data, except where these form part of a commissioned processing operation. Data subjects include our customers, prospective customers and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, invoicing and our customer service. The legal bases for the processing arise from Art. 6 (1) (b) GDPR (contractual services) and Art. 6 (1) (f) GDPR (analysis, statistics, optimisation, security measures). We process data that are necessary for the establishment and performance of the contractual services and point out that their provision is necessary. Disclosure to external parties takes place only where it is necessary in the context of an order. When processing data provided to us in the context of an order, we act in accordance with the instructions of the client and the legal requirements for processing on behalf of a controller pursuant to Art. 28 GDPR, and we process the data for no purposes other than those of the order.

We erase the data after the expiry of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, erasure takes place after their expiry (6 years pursuant to § 257 (1) HGB, 10 years pursuant to § 147 (1) AO). In the case of data disclosed to us by a client in the context of an order, we erase the data in accordance with the requirements of the order, generally after the end of the order.

Administration, financial accounting, office organisation, contact management

We process data in the course of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The bases for the processing are Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. The processing affects customers, prospective customers, business partners and website visitors. The purpose of, and our interest in, the processing lies in administration, financial accounting, office organisation and the archiving of data, that is, tasks that serve to maintain our business activities, perform our duties and provide our services. The erasure of data with regard to contractual services and contractual communication corresponds to the information given for those processing activities.

In this context we disclose or transmit data to the tax authorities, to advisers such as tax consultants or auditors, and to other fee offices and payment service providers.

Furthermore, on the basis of our business interests, we store information about suppliers, event organisers and other business partners, for example for the purpose of contacting them at a later date. As a rule we store these predominantly company-related data permanently.

Business analyses and market research

In order to operate our business economically and to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries and the like. In doing so, we process inventory data, communication data, contract data, payment data, usage data and metadata on the basis of Art. 6 (1) (f) GDPR; data subjects include contractual partners, prospective customers, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users along with information about, for example, the services they have used. The analyses serve to increase user-friendliness and to optimise our offering and its economic viability. The analyses are for our use alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.

Where these analyses or profiles are personal, they are erased or anonymised when users terminate their relationship with us, otherwise two years after conclusion of the contract. In all other respects, the overall business analyses and general trend determinations are prepared anonymously where possible.

Data protection information in the application procedure

We process applicant data only for the purpose and within the scope of the application procedure and in accordance with the legal requirements. The processing of applicant data is carried out to fulfil our (pre-)contractual obligations in the context of the application procedure within the meaning of Art. 6 (1) (b) GDPR. Where the data processing becomes necessary for us, for example in the context of legal proceedings, the processing is carried out on the basis of Art. 6 (1) (f) GDPR.

The application procedure requires applicants to provide us with the applicant data. Where we offer an online form, the necessary applicant data are marked as such; otherwise they follow from the job descriptions and, as a rule, include personal details, postal and contact addresses and the documents belonging to the application, such as a covering letter, curriculum vitae and references. In addition, applicants may voluntarily provide us with further information.

By submitting their application to us, applicants agree to the processing of their data for the purposes of the application procedure in the manner and to the extent set out in this privacy policy.

Where special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily provided in the course of the application procedure, their processing is additionally carried out pursuant to Art. 9 (2) (b) GDPR (e.g. health data such as severe disability status or ethnic origin). Where special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the course of the application procedure, their processing is additionally carried out pursuant to Art. 9 (2) (a) GDPR (e.g. health data where these are necessary for the exercise of the profession).

Where made available, applicants can submit their applications to us using an online form on our website. The data are transmitted to us in encrypted form in accordance with the state of the art.

Applicants can also send us their applications by email. Please note, however, that emails are generally not sent in encrypted form and that applicants must arrange for encryption themselves. We therefore cannot accept responsibility for the transmission path of the application between the sender and its receipt on our server, and we recommend using an online form or postal delivery instead. Rather than applying via the online form or by email, applicants also remain free to send us their application by post.

The data provided by applicants may, in the event of a successful application, be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants' data are erased. Applicants' data are likewise erased if an application is withdrawn, which applicants are entitled to do at any time.

Subject to a justified withdrawal by the applicant, erasure takes place after a period of six months, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the General Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Contacting us

When you contact us (e.g. by contact form, chat, email, telephone or via social media), the user's details are processed for the purpose of handling and dealing with the contact enquiry pursuant to Art. 6 (1) (b) GDPR (within the scope of contractual or pre-contractual relationships) and Art. 6 (1) (f) GDPR (other enquiries). Users' details may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation system.

We erase the enquiries once they are no longer required. We review the necessity every two years; statutory archiving obligations also apply.

Hosting and email delivery

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we, or rather our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospective customers and visitors to this online offering on the basis of our legitimate interests in the efficient and secure provision of this online offering pursuant to Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Collection of access data and log files

We, or rather our hosting provider, collect data about every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR. The access data include the name of the website and file accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and is then erased. Data whose further retention is necessary for evidentiary purposes are exempt from erasure until the respective incident has been finally clarified.

Audience measurement with XICTRAQ

For audience measurement we use XICTRAQ, a cookie-free analytics system operated by us. On each page view the following data are processed: the page visited and the referring page (referrer), campaign parameters, the approximate time on page, the device class (derived from screen size), browser and operating system category, the selected language, and the date and time of the visit.

No cookies are set and no information is stored or read on users' browsers; consent under § 25 (1) TDDDG is therefore not required. To distinguish visits, a short-lived technical value is formed from the IP address and a daily-rotating daily key (salt); attribution to a specific person is thereby impossible and technically excluded once the day has ended. The IP address is used solely to form this value and for approximate geographic classification and is not stored.

Processing is based on our legitimate interests (analysis, optimisation and the economic operation of our online offering, Art. 6 (1) (f) GDPR). The evaluated data are processed on servers controlled by us within the European Union and are not passed on to third parties.

Session recording (only with consent)

On the basis of your consent (Art. 6 (1) (a) GDPR, § 25 (1) TDDDG) we record anonymised session sequences (mouse, scroll and click movements, page interactions) using the open source library rrweb, which is served from our own domain. Input fields and content marked as sensitive are masked automatically; credit card and IBAN patterns are redacted. Recording does not start until you have given your consent in the consent banner and can be withdrawn at any time with effect for the future. The recordings are stored for a maximum of 90 days and are then deleted automatically. Without consent, no recording takes place.

AI chat assistant

We offer an AI-powered chat assistant on our website. When you use it, we process the messages you enter as well as technical connection data (e.g. shortened or pseudonymised identifiers) in order to answer your request and provide the service. If you voluntarily provide contact details in the chat for a follow-up, we process these to handle your enquiry.

The legal basis is our legitimate interest in efficiently answering enquiries (Art. 6 (1) (f) GDPR), and for contact requests the performance of pre-contractual measures (Art. 6 (1) (b) GDPR). To generate the responses we use a specialised service provider; processing may also take place outside the European Union, for which appropriate safeguards within the meaning of Art. 44 et seq. GDPR (in particular standard contractual clauses) are in place.

Chat histories are stored for a limited period for processing and quality assurance and are then deleted. No automated decision-making in individual cases with legal effect takes place. Please do not enter any special categories of personal data (e.g. health data) in the chat.