Legal Notice - Data Policy

All that stuff that has to be on a website but nobody reads.

Imprint - Legal Notice

Company name:
Mission Butterfly

Owner:
Undine Wetter
c/o Grosch Postflex #2202
Emsdettener Str. 10
48268 Greven
mail@mission-butterfly.com
Phone: +49 (0)451 40039426

Responsible for the content according to §5 TMG:
Undine Wetter
mail@mission-butterfly.com

Responsible for the content according to § 18 Abs. 2 MStV
Undine Wetter
mail@mission-butterfly.com

Competent chamber:
IHK zu Lübeck
Fackeburger Allee 2
23554 Lübeck
https://www.ihk-schleswig-holstein.de/

European Online Dispute Resolution Platform
Since 15 February 2016, the EU Commission has provided a platform for out-of-court dispute resolution. As a consumer, this gives the opportunity to resolve disputes in connection with the online order first without the intervention of a court. The dispute resolution platform can be reached under the external link: https://ec.europa.eu/consumers/odr/main/index.cfm?event=main.home.chooseLanguage

Usage of pictures
Thanks to the follwing Artist for the usage of their photos by Pexels.com

Privacy Policy - Data Policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as „data“) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part 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: 18 October 2021

Responsible

Undine Wetter
Mission Butterfly
Stettiner Str. 12 d
23617 Stockelsdorf – Germany
e-mail address: mail@mission-butterfly.com
Phone: 0049 451 40039426.

Imprint: https://www.mission-butterfly.com/legal-notice

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

  • Event Data (Facebook) („Event Data“ is data that may be transmitted by us to Facebook, e.g. via the Facebook Pixel (via apps or other means), 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 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 written comments), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Inventory data (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. email, 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).

 

Special categories of data

  • Data showing racial and ethnic origin.

 

Categories of persons concerned

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

 

Purposes of the processing

  • Affiliate Tracking.
  • Provision of our online offer and user friendliness.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Office and organizational procedures.
  • Direct marketing (e.g. by e-mail or post).
  • Targeting.
  • 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).
  • Security Measures.
  • Provision of contractual services and customer service.
  • Managing and responding to requests.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Relevant legal bases

Below you will find an overview of the legal basis 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 be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6(1) p. 1 lit. a. DSGVO) – The data subject has given his or her consent to the processing of personal data relating to him or her for a specific purpose or purposes.
  • Contract performance and pre-contractual enquiries (Art. 6(1) p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

 

National data protection regulations in Germany:

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on 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, the processing for other purposes and the transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

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Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, entry, disclosure, assurance of availability and separation of the data. We also have procedures in place to ensure the exercise of data subjects‘ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development and selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address:
If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as „IP masking“). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. With the shortening of the IP address, the identification of a person by means of their IP address is to be prevented or made significantly more difficult.

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

Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. 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 appropriate contracts or agreements that serve to protect your data with the recipients of 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 the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognised 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. 44 to 49 DSGVO, 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 their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply 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 is limited 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 retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

As part of our privacy notice, we may provide users with additional information regarding the deletion and retention of data that is specific to the processing operation.

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

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his 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. Likewise, the interests of users used for reach measurement or marketing purposes can 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 may be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
  • Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behavior (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 referred to as „tracking“, i.e. tracking the potential interests of users. Insofar as we use cookies or „tracking“ technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.


Notes on legal bases:
The legal basis on which we process your personal data using cookies depends on whether we ask you for 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 is 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 fulfil our contractual obligations.

Storage period:
If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context 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 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 by means of your browser settings, e.g. by deactivating the use of cookies (whereby 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 by means of a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions 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 the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. In this context, the declaration of consent is stored in order not to have to repeat its request and to be able to prove the consent 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 his device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be 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) and the browser, system and end device used.

  • Types of data processed: Usage data (e.g. web pages 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 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • BorlabsCookie: Cookie consent management; Service provider: Borlabs; Website: https://de.borlabs.io/borlabs-cookie/; An individual user ID, language as well as types of consents and the time of their submission are stored server-side and in the cookie on the users‘ device.
  • Cookiebot: cookie consent management; service provider: Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/de; Privacy policy: https://www.cookiebot.com/de/privacy-policy/; Data stored (on the service provider’s server): the user’s IP number in anonymized form (the last three digits are set to 0), date and time of consent, browser details, the URL from which the consent was sent, An anonymous, random and encrypted key value; the user’s consent status.


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 as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the corporate organisation. We only disclose the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of 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 further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

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

Coaching:
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 our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

In the course of our activities, we may also process special categories of data, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. To this end, we obtain the explicit consent of clients where necessary and otherwise process the special categories of data where this serves the health of the clients, the data is public or other legal permissions exist.

If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the client has given his consent, we disclose or transfer the client’s data to third parties or agents, e.g. authorities, accounting offices as well as in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Consulting:
We process the data of our clients, customers 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 data processed, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.

If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, 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.

  • Types of data processed: 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. subject matter of contract, term, customer category).
  • Special categories of personal data: Health data (Art. 9(1) DGSVO), Data concerning sex life or sexual orientation (Art. 9(1) DGSVO), Religious or philosophical beliefs (Art. 9(1) DGSVO), Data revealing racial or ethnic origin.
  • Affected persons: Interested parties, business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organisational procedures, administration and response to requests.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


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 for reach measurement and interest-based marketing.

  • Types of data processed: 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. subject matter of contract, term, 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.
  • Purposes of processing: provision of contractual services and customer service.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

 

Services used and service providers:

  • Digistore24: online marketplace for e-commerce; service provider: Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany; website: https://www.digistore24.com/; privacy policy: https://www.digistore24.com/de/home/extern/cms/page/frontend/legal/privacy.
  • elopage: Online marketplace for e-commerce; Service provider: elopay GmbH, Skalitzer Straße 138, 10999 Berlin, Germany, Germany; Website: https://elopage.com/; Privacy policy: https://elopage.com/privacy.


Payment procedure
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to the data subjects and use other service providers in addition to banks and credit institutions for this purpose (collectively „payment service providers“).

The data processed by the payment service providers include 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 the contract, sum and recipient-related information. The information is required to complete the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the data protection information of the payment service providers.

For payment transactions, the terms and conditions and data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, 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 fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • PayPal: payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.


Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer 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 in the context of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated in the context of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents 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 further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of identifying SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files:
We ourselves (or our web hosting provider) collect data on each access to the server (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 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 also to ensure the utilization of the servers and their stability.

  • Types of data processed: 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 the processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • DomainFactory: services in the field of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); service provider: domainfactory GmbH, Oskar-Messter-Str. 33, 85737 Ismaning, Germany; websitehttps://www.df.eu; privacy policy: https://www.df.eu/de/datenschutz.


Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter „publication medium“). Readers‘ data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

Retrieval of WordPress emojis and smilies:
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphic files that express emotions, are used 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 users‘ browsers.

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

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

  • Types of data processed: 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. subject matter of contract, term, customer category).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of contractual services and customer service, feedback (e.g. collecting feedback via online form), security measures.
  • Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
  • Akismet Anti-Spam Check: Akismet Anti-Spam Check; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; website: https://automattic.com; privacy policy: https://automattic.com/privacy.
  • UpdraftPlus: backup software and backup storage; service provider: Simba Hosting Ltd, 11, Barringer Way, St Neots, Cambs., PE19 1LW, UK; website: https://updraftplus.com/; privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.


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 the metadata of the communication and on your objection options.

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

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note 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 messages is not viewable, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.

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

Notes on legal basis: 
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 they contact us, for example, of their own accord, we use Messenger in relation to our contractual partners as well as 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. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messenger for the first time without your consent.

Revocation, objection and deletion:
You may revoke any consent given 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., e.g., 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 provided by 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 reasons of your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, internal contractual information requires special confidentiality or an answer via Messenger does not meet the formal requirements. In such cases, we will refer you to more adequate communication channels.

  • Types of data processed: 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).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • Apple iMessage: Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Website: https://www.apple.com/de/; Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
  • Instagram: Messaging via the social network Instagram; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it should not be activated by default); Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; opt-out: https://www.facebook.com/adpreferences/ad_settings (login to Facebook is required).
  • Telegram Broadcasts: Telegram Broadcasts – Messenger with end-to-end encryption; Service provider: Telegram, Dubai; website: https://telegram.org/; privacy policy: https://telegram.org/privacy.
  • WhatsApp: WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; website: https://www.whatsapp.com/; privacy policy: https://www.whatsapp.com/legal.


Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as „conference platforms“) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as „conference“). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends on the one hand on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants‘ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants‘ terminal devices, their operating system, the browser and its technical and linguistic settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent – if necessary.

Data protection measures of the participants: Please observe the details of the processing of your data by the conference platforms and select the optimal security and data protection settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by notifying roommates, locking doors and using the function to make the background unrecognizable, if technically possible). Links to the conference rooms as well as access data, may not be passed on to unauthorized third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users‘ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in lists of participants, in the case of processing of call results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: 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: provision of contractual services and customer service, contact requests and communication, office and organisational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:


Music and podcasts
We use hosting and analytics services from service providers to make our audio content available for listening or downloading and to obtain statistical information about the retrieval of the audio content.

  • Types of data processed: Usage data (e.g. web pages 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), conversion measurement (measurement of the effectiveness of marketing measures), profiles with user-related information (creation of user profiles).


Services used and service providers:

  • Podigee: Podigee – music and podcast hosting; service provider: Podigee GmbH, Schlesische Straße 20, 10997 Berlin, Germany; website: https://www.podigee.com/de; privacy policy: https://www.podigee.com/de/about/privacy/.
  • Spotify: Spotify – music hosting and widget; service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; website: https://www.spotify.com/de; privacy policy: https://www.spotify.com/de/legal/privacy-policy/.


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 the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimization.

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

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

  • Types of data processed: 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. subject matter of contract, term, customer category).
  • Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of the processing: office and organisational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • Apple iCloud: cloud storage services; service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; website: https://www.apple.com/de/; privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Google Cloud Services: Cloud storage services; 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/; privacy policy: https://www.google.com/policies/privacy, security notices: https://cloud.google.com/security/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://cloud.google.com/terms/data-processing-terms; https://cloud.google.com/terms/data-processing-terms.


Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter „newsletter“) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. 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 for the purpose of a personal address in the newsletter, or further details if these are required for the purposes of the newsletter.

Double-Opt-In-Procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. Processing of this data will be limited to the purpose of possible defence of 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 block list (so-called „block list“) for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. 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 basis: The newsletter is sent on the basis of the recipients‘ consent 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 existing customer advertising. Insofar as 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 in order to prove 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-through 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 shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading 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 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. We use the analyses to identify 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 profiles of the users and their further processing are based on the consent of the users.

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

  • Types of data processed: 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).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: direct marketing (e.g. by e-mail or post), reach measurement (e.g. access statistics, recognition of returning visitors), conversion measurement (measurement of the effectiveness of marketing measures), profiles with user-related information (creation of user profiles).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • 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 above contact options, preferably e-mail, for this purpose.


Services used and service providers:

  • Google Analytics: measuring the success of email campaigns and building user profiles with a storage period of up to two years; 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://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad display settings: https://adssettings.google.com/authenticated.
  • Mailchimp: email delivery and email marketing platform; service provider: „Mailchimp“ – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com; privacy policy: https://mailchimp.com/legal/privacy/; standard contractual clauses as the basis for processing in the USA: https://mailchimp.com/legal/data-processing-addendum/; special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.


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

Recipients have the right to revoke consent given at any time or to object to promotional communications 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 deleting it. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Affected persons: Communication partners.
  • Purposes of the processing: direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Surveys and interviews
The surveys and questionnaires we conduct (hereinafter „surveys“) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable a resumption of the survey with the aid of a temporary cookie (session cookie)) or users have consented to this.

Notes on legal basis: If we ask participants for consent to process their data, this is the legal basis for the processing, otherwise the processing of participants‘ data is based on our legitimate interests in conducting an objective survey.

  • Types of data processed: 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: Communication partners.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • Google Form: Google Cloud Forms; 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://firebase.google.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad display settings: https://adssettings.google.com/authenticated.


Online Marketing
We process personal data for online marketing purposes, which may include, but are not limited to, marketing advertising space or displaying promotional and other content (collectively, „Content“) based on users‘ potential interests and measuring 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 information about the user 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 may also be processed.

The IP addresses of the 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 as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the 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 analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network links the profiles of the users with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

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

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

Facebook pixel and target group formation (Custom Audiences): 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), it is possible for Facebook to determine the visitors to 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 partners cooperating with Facebook (so-called „Audience Network“ https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident 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 the users and do not have a harassing effect. With the help of the Facebook Pixel, we can further track the effectiveness of the 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“).

We are jointly responsible with Facebook Ireland Ltd. for collecting or receiving in transmission (but not further processing) „Event Data“ that Facebook collects or receives in transmission through the Facebook Pixel and similar features (e.g., interfaces) running on our Online Service for the purposes of:
a) displaying content advertising information that is relevant to users‘ perceived interests;
b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger);
c) improving ad delivery and personalizing features and content (e.g., improving the identification of which content or advertising information is relevant to users‘ perceived interests);
d) improving the quality of content and personalization of features and content (e.g., improving the identification of which content or advertising information is relevant to users‘ perceived interests).
(e) improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be relevant to users‘ interests). We have entered into a specific agreement with Facebook („Responsible Party Addendum“, https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not obtain details of individual users and are anonymous to us), this processing is not carried out under shared responsibility, but on the basis of a contract for processing („Data Processing Terms „, https://www.facebook.com/legal/terms/dataprocessing) , the „Data Security Terms and Conditions“ (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses („Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). 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.

  • Types of data processed: 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 may be transmitted, e.g. via Facebook Pixel (via apps or in other ways) by us to Facebook and relates to individuals or their actions; The data includes e.g… 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 the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: marketing, profiling with user-related information (creating user profiles), remarketing, conversion measurement (measuring the effectiveness of marketing measures), target group formation, target group formation (determining target groups relevant for marketing purposes or other output of content).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Opt-out option: We refer to the data protection information of the respective providers and the opt-out options given 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 restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions: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:

  • Google Analytics: online marketing and web analytics; 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://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad display settings: https://adssettings.google.com/authenticated.
  • Facebook Pixel and targeting (Custom Audiences): Service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out: https://www.facebook.com/adpreferences/ad_settings (login to Facebook is required).


Affiliate programs and affiliate links

We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers in our online offer (collectively referred to as „affiliate links“). If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, „Commission“).

In order to be able to track whether the users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that the users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) serves the sole purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned assignment of the affiliate links, the affiliate links can be supplemented by certain values that are a component of the link or can be stored otherwise, e.g. in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

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 the third-party providers was agreed in this context. 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 refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Contractual data (e.g. subject matter of contract, term, customer category), 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: Affiliate tracking.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


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 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 the users, because, for example, the enforcement of the rights of the users could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the 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 usually stored on the computers of the users, in which the usage behavior and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (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 possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we 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: We are jointly responsible with Facebook Ireland Ltd for collecting (but not further processing) data from visitors to our Facebook page (known as a „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 users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see „Device Information“ in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under „How Do We Use This Information?“, Facebook also collects and uses information to provide analytics services, called „Page Insights,“ to Page operators to provide them with insights into how people interact with their Pages and the content associated with them. We have entered into a special agreement with Facebook („Page Insights Information“, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (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).

  • Types of data processed: 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 p. 1 lit. f. DSGVO).


Services used and service providers:

  • Instagram: social network; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; opt-out: settings for ads: https://www.facebook.com/adpreferences/ad_settings (login to Facebook is required).
  • LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.


Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers“). These can 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 without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to use only such 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. The „pixel tags“ can be used to evaluate 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 be linked to such information from other sources.

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

  • Types of data processed: 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 the processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO).


Services used and service providers:

  • Google Fonts: We integrate the fonts („Google Fonts“) of the provider Google, whereby the user 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 display, as well as 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 service „Google Maps“ of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed as part 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 display of ads: 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 plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad display settings: https://adssettings.google.com/authenticated.


Management, organization and auxiliary 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 the third-party providers. This may involve 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 contents.

If users are referred to third-party providers or their software or platforms in the course 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 the third-party providers was agreed in this context. 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 refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: 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 the processing: office and organisational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


Services used and service providers:

  • calendly: online appointment scheduling; service provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; website: https://calendly.com/de; privacy policy: https://calendly.com/pages/privacy.


Modification and updating of the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us 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.

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data in question is being processed and to be informed of such data and to obtain further information and a copy of the data in accordance with the law.
  • Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
  • Complaint to supervisory authority: In accordance with the law 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 where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Supervisory authority responsible for us:
Independent Centre for Data Protection Schleswig-Holstein (public law institution)
Holstenstrasse 98
24103 
Kiel

Marit Hansen, ULD – Independent Centre for Data Protection Schleswig Holstein
mail@datenschutzzentrum.de
Phone: 0049 431 988-1200

Definitions

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 primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Affiliate Tracking: Affiliate tracking logs links that the linking websites use to direct users to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include in particular the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as, for example, advertising material ID, partner ID and categorizations.
  • 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. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
  • Conversion measurement: Conversion measurement (also referred to 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 users‘ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to 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 „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of „profiles with user-related information“, or „profiles“ for short, includes any type of automated processing of personal data that consists in using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (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 referred to as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors‘ behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables 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: We speak of „remarketing“ or „retargeting“ when, for example, for advertising purposes, it is noted 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 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 upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
  • Target group formation: We speak of target group formation (or „Custom Audiences“) when target groups are determined for advertising purposes, e.g. 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 shop in which he viewed the products. In turn, we speak of „lookalike audiences“ (or similar target groups) 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