Privacy Policy
Preamble
Preamble
In the following privacy policy, we would like to explain which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing 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 service").
The terms used are not gender-specific.
As of: April 21, 2023
Table of contents
- Preamble
- Controller
- Overview of processing activities Relevant legal bases Security measures
- Transfer of personal data
- Data processing in third countries
- Deletion of data
- Use of cookies
- Provision of the online service and web hosting
- Blogs and publication media
- Contact and inquiry management
- Communication via messenger
- Video conferences, online meetings, webinars, and screen-sharing audio content
- Application process
- Cloud services
- Newsletter and electronic notifications
- Promotional communication via email, mail, fax, or telephone; surveys and questionnaires
- Web analytics, monitoring, and optimization
- Online marketing
- Social media presence
- Plugins and embedded functions as well as content
- Changes and updates to the privacy policy
- Rights of data subjects
Controller
Native Creative GmbH
Belziger Str. 69-71
10823 Berlin
Authorized representatives:
Sabine Fentker
Email address: hallo@native-creative.de
Overview of processing activities
The following overview summarizes the types of data processed, the purposes of their processing, and refers to the data subjects concerned.
Types of processed data
- Inventory data.
- Contact data.
- Content data.
- Usage data.
- Meta, communication, and process data. Applicant data.
- Image and/or video recordings. Contact information (Facebook).
- Event data (Facebook).
Categories of data subjects
- Customers.
- Employees.
- Prospective customers.
- Communication partners.
- Users.
- Applicants.
- Participants.
- Depicted persons.
Purposes of processing
- Provision of contractual services and customer service.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion tracking.
- Target group segmentation.
- Administration and responding to inquiries.
- Application process.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- IT infrastructure.
Relevant legal bases
Below is an overview of the legal bases of the GDPR on 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 registered office. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6(1) sentence 1(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Presence on social networks (social media)
- Legitimate interests (Art. 6(1) sentence 1(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
- Application process as a pre-contractual or contractual relationship (Art. 6(1)(b) GDPR) – If special categories of personal data within the meaning of Art. 9(1) GDPR (e.g., health data such as severe disability status or ethnic origin) are requested from applicants during the application process so that the controller or the data subject can exercise their rights and fulfill their obligations under labor law and social security and social protection law, such processing is carried out in accordance with Art. 9(2)(b) GDPR. In the event of protecting the vital interests of the applicant or another person, processing is carried out pursuant to Art. 9(2)(c) GDPR, or for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services pursuant to Art. 9(2)(h) GDPR. In the case of a voluntary disclosure of special categories of data based on consent, processing is carried out on the basis of Art. 9(2)(a) GDPR.
In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (§ 26 BDSG), particularly with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.
Security measures
In accordance with legal requirements and taking into account the state of the art, implementation costs, 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 organizational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and reactions to threats to the data. Furthermore, we 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.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transmitted to other entities, companies, legally independent organizational units, or persons, or disclosed to them. 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 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) or the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or the disclosure or transmission of data to other persons, entities, or companies, this only occurs in accordance with legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications, or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Deletion of data
The data processed by us will be deleted in accordance with legal requirements as soon as the consent permitted for processing is withdrawn or other permissions cease to apply (e.g., if the purpose of processing this data has expired or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.
Our privacy policy may also contain further information on the storage and deletion of data, which shall take precedence for the respective processing operations.
Use of cookies
Cookies are small text files or other storage markers that store information on devices and read information from devices. For example, to save login status in a user account, shopping cart contents in an e-shop, the content accessed, or the functions used within an online service. Cookies can also be used for various purposes, such as for the functionality, security, and convenience of online services, as well as for creating analyses of visitor traffic.
Information on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, unless it is not required by law. Consent is, in particular, not necessary if the storage and reading of information, including cookies, is strictly necessary to provide users with a telemedia service they have expressly requested (i.e., our online service). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, the storage of user preferences and choices, or similar purposes related to the provision of the main and secondary functions of the online service requested by the users. The revocable consent is clearly communicated to users and contains information regarding the respective cookie usage.
Information on data protection legal bases: The legal basis under data protection law upon which we process users' personal data using cookies depends on whether we ask users for consent. If users provide consent, the legal basis for processing their data is that declared consent. Otherwise, data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the commercial operation of our online service and the improvement of its usability) or, if this occurs in the context of fulfilling our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which cookies are processed by us in the course of this privacy policy or in the context of our consent and processing processes.
Storage duration: With regard to storage duration, a distinction is made between the following types of cookies:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device is closed. This allows, for example, login status to be saved or preferred content to be displayed directly when the user visits a website again. Likewise, data collected via cookies can be used for reach measurement. Unless we provide users with explicit information regarding the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and that the storage duration can be up to two years.
General information on withdrawal and objection (opt-out): Users may withdraw their consent at any time and also object to the processing of their data in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g., by deactivating the use of cookies (which may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites
https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal basis: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); consent (Art. 6 (1) sentence 1 (a) GDPR).
Further information on processing operations, procedures, and services:
Processing of cookie data based on consent: We use a cookie consent management system to obtain, manage, and allow users to revoke their consent for the use of cookies or the processing and providers specified within the cookie consent management process. The declaration of consent is stored so that the query does not have to be repeated and to be able to prove consent in accordance with legal obligations. Storage may take place on the server side and/or in a cookie (a so-called opt-in cookie or using comparable technologies) in order to assign consent to a user or their device. Subject to individual information regarding providers of cookie management services, the following applies: The duration of consent storage can be up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and device used; Legal basis: Consent (Art. 6 (1) sentence 1 (a) GDPR).
Provision of online services and
web hosting
We process user data to provide our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
- Types of data processed: Usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); content data (e.g., entries in online forms).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures.
- Legal basis: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).
Further information on processing operations, procedures, and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web host"). Legal basis: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR)
- Collection of access data and log files: Access to our online services is logged in the form of "server log files." Server log files may include the address and name of the accessed websites and files, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and generally IP addresses and the requesting provider. Server log files may be used for security purposes, for example, to prevent server overload (particularly in the event of abusive attacks, such as DDoS attacks) and to ensure server utilization and stability. Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and subsequently deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally resolved.
- Email transmission and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information regarding email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent in an encrypted format on the internet. While emails are usually encrypted in transit, they are not encrypted on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We therefore cannot assume any responsibility for the transmission of emails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).
- WordPress.com: Hosting and software for the creation, provision, and operation of websites, blogs, and other online services; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/.
- netcup: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.netcup.de/; Privacy Policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php; Data Processing Agreement: https://www.netcup-wiki.de/wiki/Zusatzvereinbarung_zur_Auftragsverarbeitung.
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter "publication medium"). The data of readers is processed for the purposes of the publication medium only to the extent necessary for its display and communication between authors and readers, or for security reasons. Otherwise, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
- 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 forms); provision of our online services and user-friendliness; security measures; administration and response to inquiries.
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In such cases, we could be held liable for the comment or post ourselves and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests. On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting. Personal information provided in the context of comments and posts, any contact and website information, as well as the content details, are stored by us permanently until the user objects; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
- Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies – Within our WordPress blog, we use graphic emojis (or smilies), i.e., small graphic files that express feelings, to efficiently integrate content elements. These are sourced from external servers. The server providers collect the users' IP addresses. This is necessary so that the emoji files can be transmitted to the users' browsers; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://automattic.comPrivacy Policy: https://automattic.com/privacy.
- Medium: Hosting platform for blogs / websites; Service provider: A Medium Corporation, P.O. Box 602, San Francisco, CA 94104–0602, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://medium.com/Privacy Policy: https://medium.com/policy/medium-privacy-policy-f03bf92035c9.
Contact and inquiry management
When contacting us (e.g., by post, contact form, email, telephone, or via social media) as well as within the scope of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to contact requests and any requested measures.
- Types of data processed: Contact details (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication; management and response to inquiries; feedback (e.g., collecting feedback via online form); provision of our online services and user-friendliness.
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Further information on processing operations, procedures, and services:
- Contact form: When users contact us via our contact form, email, or other communication channels, we process the data provided in this context to handle the inquiry; legal basis: performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Communication via messenger
We use messenger services for communication purposes and therefore ask you to note the following information regarding the functionality of these services, encryption, the use of communication metadata, and your options for objection.
You can also contact us via alternative channels, such as telephone or email. Please use the contact options provided to you or those specified within our online services.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that communication content (i.e., the message content and attached images) is encrypted from end to end. This means that the content of the messages is not visible, not even to the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that message content is encrypted.
However, we also inform our communication partners that while messenger providers cannot view the content, they can determine that and when communication partners are communicating with us, as well as process technical information about the device used by the communication partners and, depending on your device settings, location information (so-called metadata).
Notes on legal basis: If we ask communication partners for permission before communicating with them via messenger, the legal basis for processing their data is their consent. Otherwise, if we do not request consent and you contact us on your own initiative, we use messengers in our dealings with contractual partners and in the context of contract initiation as a contractual measure, and in the case of other interested parties and communication partners, based on our legitimate interests in fast and efficient communication and in meeting our communication partners' needs for communication via messenger. Furthermore, please note that we do not transmit the contact details provided to us to messenger services for the first time without your consent.
Withdrawal, objection, and deletion: You may withdraw your consent at any time and object to communicating with us via messenger. In the event of communication via messenger, we will delete messages in accordance with our general deletion policies (i.e., 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 any inquiries from communication partners have been answered, provided that no reference to a previous conversation is expected and no legal retention obligations prevent deletion.
Right to refer to other communication channels: Finally, please note that for security reasons, we reserve the right not to respond to inquiries via messenger services. This applies, for example, if internal contract details require special confidentiality or if a response via messenger does not meet formal requirements. In such cases, we will direct you to more appropriate communication channels.
Types of data processed: Contact details (e.g., email, phone numbers); usage data (e.g., websites visited, interest in content, access times); meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status); content data (e.g., entries in online forms).
Data subjects: Communication partners.
Purposes of processing: Contact requests and communication; direct marketing (e.g., via email or post).
Legal basis: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Apple iMessage: Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.apple.com/Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
- Instagram: Messaging via the Instagram social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.comPrivacy Policy: https://instagram.com/about/legal/privacy.
- Facebook Messenger: Facebook Messenger with end-to-end encryption (end-to-end encryption in Facebook Messenger requires activation if it is not enabled by default); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.comPrivacy Policy: https://www.facebook.com/about/privacyData processing agreement: https://www.facebook.com/legal/terms/dataprocessingStandard contractual clauses (ensuring data protection level for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
- Signal: Signal Messenger with end-to-end encryption; Service provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite 120-223 Mountain View, CA 94041, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://signal.org/dePrivacy Policy: https://signal.org/legal/.
- Slack: Instant messaging service; Service provider: Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://slack.com/intl/en-us/; Privacy policy: https://slack.com/intl/en-us/legal; Data processing agreement: https://slack.com/intl/en-us/terms-of-service/data-processing; Standard contractual clauses (guaranteeing data protection level for processing in third countries): https://slack.com/intl/en-us/terms-of-service/data-processing; Further information: Security measures: https://slack.com/intl/en-us/security-practices.
- WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal.
- Wire: Wire Messenger with end-to-end encryption; Service provider: Wire Swiss GmbH, Untermüli 9, 6300 Zug, Switzerland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://wire.com/en; Privacy Policy: https://wire.com/de/legal/#terms.
Video conferences, online meetings, webinars, and screen sharing
We use platforms and applications from 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 "conferences"). We observe legal requirements when selecting conference platforms and their services.
Data processed by conference platforms: When participating in a conference, the conference platforms process the personal data of participants listed below. The scope of processing depends on which data is required for a specific conference (e.g., providing access credentials or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participant 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 (email address, phone number), access credentials (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet connection, information about the participants' devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e., entries in chats as well as audio and video data, and the use of other available functions (e.g., polls). Communication content is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, 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 polls), or video or audio recordings are logged, this will be communicated to participants transparently in advance, and they will be asked for their consent where necessary.
Participant data protection measures: Please refer to the conference platforms' privacy policies for details on how they process your data and select the optimal security and privacy settings within the conference platform settings. Furthermore, please ensure data and personal privacy in the background of your recording for the duration of a video conference (e.g., by notifying housemates, locking doors, and using the background blur function where technically possible). Links to conference rooms and access credentials must not be shared with unauthorized third parties.
Notes on legal basis: If we process user data in addition to the conference platforms and ask users for their consent to use the conference platforms or specific functions (e.g., consent to record conferences), the legal basis for processing is that consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g., in participant lists, in the case of processing meeting results, etc.). Otherwise, user data is processed based on our legitimate interests in efficient and secure communication with our communication partners.
- Types of data processed: Inventory data (e.g., names, addresses); contact details (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
- Data subjects: Communication partners; users (e.g., website visitors, users of online services); individuals depicted.
- Purposes of processing: Provision of contractual services and customer support; contact requests and communication; office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).
Further information on processing operations, procedures, and services:
- Adobe Connect: Conference and webinar software; Service provider: Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR); Website: https://www.adobe.com/de/products/adobeconnect.htmlPrivacy Policy: https://www.adobe.com/privacy.html.
- Google Hangouts / Meet: Conferencing and communication software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://hangouts.google.com/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause.
- Slack: Messenger and conferencing software; Service provider: Slack Technologies Limited, Level 1, Block A Nova Atria North, Sandyford Business District, Dublin 18, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://slack.com/intl/en-de/; Privacy Policy: https://slack.com/intl/en-de/legal; Data Processing Agreement: https://slack.com/intl/en-de/terms-of-service/data-processing; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://slack.com/intl/en-de/terms-of-service/data-processing.
- Zoom: Conference and communication software; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Data Processing Agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA); Standard Contractual Clauses (guaranteeing data protection level for processing in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA).
Audio content
We use hosting and analysis services from service providers to offer our audio content for listening or downloading and to obtain statistical information regarding the retrieval of this audio content.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); conversion measurement (measuring the effectiveness of marketing measures); profiles with user-related information (creating user profiles); provision of our online services and user-friendliness.
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Spotify: Spotify – Music hosting and widget; Service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.spotify.com/de; Privacy Policy: https://www.spotify.com/de/legal/privacy-policy/.
Application process
The application process requires that applicants provide us with the data necessary for their assessment and selection. Which information is required is stated in the job description or, in the case of online forms, in the information provided there.
In principle, the required information includes personal details such as name, address, a contact option, and proof of the qualifications necessary for a position. Upon request, we are happy to provide information on what details are required.
If provided, applicants can submit their applications to us using an online form. The data is transmitted to us encrypted in accordance with the state of the art. Applicants can also submit their applications to us via email. However, please note that emails on the internet are generally not sent in an encrypted format. As a rule, emails are encrypted during transit, but not on the servers from which they are sent and received. We therefore cannot accept responsibility for the transmission path of the application between the sender and receipt on our server.
For the purposes of applicant searching, submission of applications, and selection of applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.
Applicants are welcome to contact us regarding the method of submitting their application or to send us their application by post.
Processing of special categories of data: If special categories of personal data within the meaning of Art. 9(1) GDPR (e.g., health data, such as severe disability status or ethnic origin) are requested from applicants during the application process so that the controller or the data subject can exercise their rights arising from labor law and social security and social protection law and fulfill their obligations in this regard, such processing is carried out in accordance with Art. 9(2)(b) GDPR, in the case of protecting the vital interests of the applicants or other persons pursuant to Art. 9(2)(c) GDPR, or for the purposes of preventive medicine, medical diagnosis, the provision of care or treatment in the health or social sector, or the management of health or social care systems and services pursuant to Art. 9(2)(h) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9(2)(a) GDPR.
Deletion of data: In the event of a successful application, the data provided by applicants may 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 will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, deletion will take place no later than six months after the end of the process so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursements are archived in accordance with tax law requirements.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process, and that they can revoke their consent at any time for the future.
Duration of data retention in the applicant pool in months:
1 year
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); applicant data (e.g., personal details, postal and contact addresses, documents belonging to the application and the information contained therein, such as cover letters, CVs, certificates, and other information regarding their person or qualifications provided voluntarily by applicants or in relation to a specific position).
- Data subjects: Applicants.
- Purposes of processing: Application process (establishment and potential subsequent execution, as well as possible subsequent termination of the employment relationship).
- Legal basis: Application process as a pre-contractual or contractual relationship (Art. 6(1)(b) GDPR).
Cloud services
We use software services accessible via the internet and executed on the servers of their providers (so-called "cloud services," also referred to as "Software as a Service") for the storage and management of content (e.g., document storage and management, exchange of documents, content, and information with specific recipients, or publication of content and information).
In this context, personal data may be processed and stored on the providers' servers, provided that this data is part of communication processes with us or is otherwise processed by us as described in this privacy policy. This data may include, in particular, master data and contact details of users, data regarding transactions, contracts, other processes, and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.
If we provide forms or other documents and content for other users or publicly accessible websites with the help of cloud services, the providers may store cookies on the users' devices for web analysis purposes or to remember user settings (e.g., in the case of media control).
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); image and/or video recordings (e.g., photographs or video recordings of a person).
- Data subjects: Customers; employees (e.g., staff, applicants, former employees); prospective customers; communication partners; users (e.g., website visitors, users of online services).
- Purposes of processing: Office and organizational procedures; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); provision of contractual services and customer service.
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Adobe Creative Cloud: Applications and cloud storage for photo editing, video editing, graphic design, and web development; Service provider: Adobe Systems Software Ireland Companies, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.adobe.com/de/creativecloud.html; Privacy Policy: https://www.adobe.com/de/privacy.html; Data Processing Agreement: Provided by the service provider; Standard Contractual Clauses
- (guaranteeing data protection level for processing in third countries): Included in the Data Processing Agreement.
- Apple iCloud: Cloud storage service; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.apple.com/de/; Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Cloud services: Cloud infrastructure services and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Standard Contractual Clauses (guaranteeing data protection level for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause; Further information: https://cloud.google.com/privacy.
- Google Cloud Storage: Cloud storage, cloud infrastructure services, and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://cloud.google.com/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum; Standard contractual clauses (guaranteeing data protection levels for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause; Further information: https://cloud.google.com/privacy.
- Google Workspace: Cloud-based application software (e.g., word processing, spreadsheets, calendar and contact management), cloud storage, and cloud infrastructure services; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://workspace.google.com/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum; Standard contractual clauses (guaranteeing data protection levels for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause; Further information: https://cloud.google.com/privacy.
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the consent of the recipients or legal permission. If the content of the newsletter is specifically described during registration, it is decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
To sign up for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of personal address in the newsletter, or other information if it is required for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter generally takes place using a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people's email addresses. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose on a blocklist.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was conducted properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.
Content:
Information about us, our services, promotions, and offers.
- Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); usage data (e.g., websites visited, interest in content, access times).
- Data subjects: Communication partners; customers; prospective customers; users (e.g., website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g., via email or post); marketing; reach measurement (e.g., access statistics, recognition of returning visitors); conversion measurement (measuring the effectiveness of marketing measures); profiles with user-related information (creating user profiles).
Legal basis: Consent (Art. 6 (1) sentence 1 (a) GDPR); Legitimate interests (Art. 6 (1) sentence 1 (f) GDPR).
Right to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e., revoke your consent or object to receiving it in the future. You can find a link to unsubscribe from the newsletter at the end of each newsletter or use one of the contact options mentioned above, preferably email.
Further information on processing processes, procedures, and services:
- Measuring open and click rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from their server when the newsletter is opened. During this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve our newsletters based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. This information is assigned to individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open and click rates, the storage of measurement results in user profiles, and their further processing are based on the user's consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 (1) sentence 1 (a) GDPR).
- Google Analytics: Measuring the success of email campaigns and creating user profiles with a retention period of up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) sentence 1 (a) GDPR).
- GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and processed data).
- Mailchimp: Email delivery and email marketing platform; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Standard Contractual Clauses (ensuring data protection level for processing in third countries): included in the data processing agreement; Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Promotional communication via email, post, fax,
or telephone
We process personal data for promotional communication purposes, which may take place via various channels such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to promotional communication at any time.
Following a withdrawal or objection, we store the data required to prove previous authorization for contact or transmission for up to three years after the end of the year in which the withdrawal or objection occurred, based on our legitimate interests. The processing of this data is limited to the purpose of potentially defending against claims. Based on our legitimate interest in permanently respecting the user's withdrawal or objection, we also store the data necessary to avoid further contact (e.g., depending on the communication channel, the email address, phone number, or name).
- Types of data processed: Inventory data (e.g., names, addresses); contact details (e.g., email, phone numbers).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., via email or post).
- Legal basis: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).
Surveys and polls
We conduct surveys and polls to collect information for the specific purpose communicated for each survey or poll. The surveys and polls we conduct (hereinafter "surveys") are analyzed anonymously. Personal data is only processed to the extent necessary for the provision and technical implementation of the surveys (e.g., processing the IP address to display the survey in the user's browser or using a cookie to allow the survey to be resumed).
- Types of data processed: Contact details (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
- Data subjects: Communication partners; participants.
- Purposes of processing: Feedback (e.g., collecting feedback via online forms).
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Google Forms: Creation and analysis of online forms, surveys, feedback questionnaires, etc.; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.google.de/intl/de/formsPrivacy Policy: https://policies.google.com/privacyData Processing Agreement: https://cloud.google.com/terms/data-processing-addendumStandard Contractual Clauses (ensuring data protection levels for processing in third countries): https://cloud.google.com/terms/eu-model-contract-clause.
- SurveyMonkey: Conducting online surveys; Service provider: SurveyMonkey Inc., 1 Curiosity Way, San Mateo, California 94403, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.surveymonkey.de; Privacy policy: https://www.surveymonkey.de/mp/policy/privacy-policy/?ut_source=footer.
- Typeform: Creation of forms and surveys and management of participant submissions; Service provider: TYPEFORM SL, Carrer Bac de Roda, 163, local, 08018 – Barcelona, Spain; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.typeform.com/; Privacy policy: https://admin.typeform.com/to/dwk6gt/.
Web analytics, monitoring, and optimization
Web analytics (also referred to as "reach measurement") is used to evaluate visitor traffic to our online services and may include visitor behavior, interests, or demographic information, such as age or gender, as pseudonymous values. Reach analysis allows us to determine, for example, when our online services or their functions or content are used most frequently or encourage repeat visits. It also helps us identify areas that require optimization.
In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online services or their components.
Unless otherwise stated below, profiles—i.e., data grouped together for a specific usage process—may be created for these purposes, and information may be stored in a browser or on a device and retrieved from it. The data collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data to us or to the providers of the services we use, location data may also be processed.
Users' IP addresses are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect our users. In general, no clear data (such as email addresses or names) of users is stored in the context of web analytics, A/B testing, and optimization; only pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Remarketing; target group formation; reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g., interest-based/behavioral profiling, use of cookies); provision of our online services and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6(1)(a) GDPR).
Further information on processing operations, procedures, and services:
- Google Optimize: Software for the analysis and optimization of online services based on feedback functions as well as pseudonymized measurements and analyses of user behavior, which may include A/B testing (measuring the popularity and usability of different content and functions), tracking click paths, and interaction with content and functions of the online service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://optimize.google.comPrivacy policy: https://policies.google.com/privacyData processing agreement: https://business.safety.google/adsprocessortermsStandard contractual clauses (guaranteeing data protection levels for processing in third countries): https://business.safety.google/adsprocessortermsFurther information: https://privacy.google.com/businesses/adsservices (Types of processing and processed data).
- Google Analytics: Web analytics, reach measurement, and tracking of user traffic; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/Privacy policy: https://policies.google.com/privacyData processing agreement: https://business.safety.google/adsprocessortermsStandard contractual clauses (guaranteeing data protection levels for processing in third countries): https://business.safety.google/adsprocessortermsOpt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user's IP address, which is necessary to execute the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) sentence 1 (a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms.
Online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as measuring the effectiveness of such content.
For these purposes, so-called user profiles are created and stored in a file (a "cookie") or similar methods are used, by means of which information about the user relevant to the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information such as the browser used, the computer system used, and information on usage times and features used. If users have consented to the collection of their location data, this may also be processed.
Users' IP addresses 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 data of users (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing services know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is generally stored in cookies or by means of similar methods. These cookies can later generally be read on other websites that use the same online marketing service, analyzed for the purpose of displaying content, supplemented with other data, and stored on the server of the online marketing service provider.
In exceptional cases, clear data may be assigned to the profiles. This is the case if, for example, users are members of a social network whose online marketing service we use and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g., by giving consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurement, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used are stored for a period of two years.
- 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, and process data (e.g., IP addresses, timestamps, identification numbers, consent status); event data (Facebook) ("event data" is data that can be transmitted by us to Facebook, e.g., via the Facebook Pixel (via apps or other means) and relates to individuals or their actions; this data includes, for example, information about visits to websites, interactions with content, features, 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 written comments), login information, or contact information (i.e., no names, email addresses, or telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted upon the deletion of our Facebook account); contact information (Facebook) ("contact information" is data that (clearly) identifies data subjects, such as names, email addresses, and telephone numbers, which can be transmitted to Facebook, e.g., via the Facebook Pixel or upload for matching purposes to create Custom Audiences; after matching for the purpose of creating target groups, the contact information is deleted).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-based/behavioral profiling, use of cookies); conversion measurement (measuring the effectiveness of marketing activities); target group formation; marketing; profiles with user-related information (creating user profiles); provision of our online services and user-friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6(1) sentence 1(a) GDPR); Legitimate interests (Art. 6(1) sentence 1(f) GDPR).
- Right to object (opt-out): We refer to the privacy policies of the respective providers and the opt-out options provided for these providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict the functionality of our online services. We therefore recommend the following additional opt-out options, which are offered collectively for specific regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.
Further information on processing operations, procedures, and services:
- Facebook Pixel and audience building (Custom Audiences): With the help of the Facebook Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able, on the one hand, to determine the visitors to our online services as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to ensure that the Facebook ads we place are only shown to users on Facebook and within the services of partners cooperating with Facebook (the so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online services or who exhibit certain characteristics (e.g., interest in specific topics or products determined by the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook Pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not perceived as intrusive. Furthermore, the Facebook Pixel allows us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion tracking"); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1) sentence 1(a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Further information: User event data, i.e., behavioral and interest information, is used for the purposes of targeted advertising and audience building based on the joint controller agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum) processed. Joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transfer of data to the parent company, Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Advanced matching for the Facebook Pixel: In addition to processing event data as part of using the Facebook Pixel (or similar features, e.g., in apps), contact information (personally identifiable data such as names, email addresses, and phone numbers) is also collected by Facebook within our online services or transmitted to Facebook. The processing of this contact information serves to create target audiences (so-called "Custom Audiences") for displaying content and advertising tailored to the presumed interests of users. The collection, transmission, and matching with data already held by Facebook are not performed in plain text, but rather as so-called "hash values," which are mathematical representations of the data (a method commonly used for storing passwords). Once the data has been matched to create target audiences, the contact information is deleted. The processing of this contact information is based on a data processing agreement with Meta Platforms Ireland Limited ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (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). Further information on the processing of contact information can be found in the "Facebook Business Tools Terms", https://www.facebook.com/legal/technology_terms.; Legal basis: Consent (Art. 6(1)(a) GDPR).
- Facebook – Target audience creation via data upload: Creating target audiences for marketing purposes – We transmit contact information (names, email addresses, and phone numbers) in list form to Facebook to create target audiences (so-called "Custom Audiences") for displaying content and advertising tailored to the presumed interests of users. The transmission and matching with data already held by Facebook are not performed in plain text, but rather as so-called
- "hash values," which are mathematical representations of the data (a method commonly used for storing passwords). Once the data has been matched to create target audiences, the contact information is deleted. The processing of this contact information is based on a data processing agreement with Meta Platforms Ireland Limited ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (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). Further information on the processing of contact information can be found in the "Custom Audiences Terms", https://www.facebook.com/legal/terms/customaudience; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Standard contractual clauses (guaranteeing data protection level for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
- Facebook Ads: Displaying advertisements within the Facebook platform and evaluating ad performance; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) sentence 1(f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-out option: We refer to the privacy and advertising settings in the user's profile on Facebook platforms, as well as Facebook's consent procedures and contact options for exercising rights of access and other data subject rights in Facebook's privacy policy; Further information: User event data, i.e., behavioral and interest information, is used for the purposes of targeted advertising and audience building based on the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum) is processed. Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transfer of data to the parent company, Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and conversion tracking: Online marketing methods for the purpose of placing content and advertisements within the service provider's advertising network (e.g., in search results, videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e., whether users have used them as an opportunity to interact with the ads and take advantage of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1) sentence 1(a) GDPR), Legitimate interests (Art. 6(1) sentence 1(f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms between controllers and Standard Contractual Clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
- Instagram Ads: Displaying advertisements within the Instagram platform and evaluating ad performance; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy; Opt-out: Please refer to the privacy and advertising settings in the user's profile on the Instagram platform, as well as Instagram's consent procedures and contact options for exercising rights of access and other data subject rights as outlined in Instagram's privacy policy; Further information: User event data, i.e., behavioral and interest-based information, is processed for the purposes of targeted advertising and audience building based on the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum) is processed. Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Subsequent processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which particularly concerns the transmission of data to the parent company, Meta Platforms, Inc. in the USA (based on the Standard Contractual Clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Insight Tag / conversion tracking; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Standard Contractual Clauses (ensuring data protection levels for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Social Media Presence
We maintain an online presence within social networks and process user data in this context to communicate with users active there or to offer information about us.
Please note that user data may be processed outside the European Union. This may result in risks for users, for example, by making it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. These usage profiles can in turn be used, for example, to display advertisements inside and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are generally stored on users' computers, in which usage behavior and user interests are stored. Furthermore, data can also be stored in usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them). For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.
- Types of data processed: Contact details (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Contact requests and communication; feedback (e.g., collecting feedback via online forms); marketing.
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
- Facebook Pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights," to page operators so that they can gain 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 specifically regulates the security measures Facebook must observe and in which Facebook agrees to fulfill data subject rights (i.e., users can, for example, send requests for information or deletion directly to Facebook). The rights of users (in particular to information, deletion, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Page Insights Information" (https://www.facebook.com/legal/terms/information_about_page_insights_data ); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring data protection levels for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Joint controllership agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Subsequent data processing is the sole responsibility of Meta Platforms Ireland Limited, particularly regarding the transfer of data to the parent company, Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring data protection levels for processing in third countries): https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent company: Twitter Inc., 1355 Market Street, Suite 900, San
- Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Privacy Policy: https://policies.google.com/privacy; Opt-out option: https://adssettings.google.com/authenticated.
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.xing.com; Privacy Policy: https://privacy.xing.com/en/privacy-policy.
Plugins and embedded functions as well as
content
We integrate functional and content elements into our online services that are retrieved from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or maps (hereinafter collectively referred to as "content").
The integration always requires that the third-party providers of this content process the users' IP address, as they would not be able to send the content to the user's browser without it. The IP address is therefore necessary for the display of this content or these functions. We strive to use only content whose providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. These "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 details regarding the use of our online services, as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status); inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); content data (e.g., entries in online forms).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online services and user-friendliness.
- Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
- Google Fonts (hosted on Google servers): Provision of fonts (and icons) for the purpose of technically secure, maintenance-free, and efficient use of fonts and icons in terms of currency and loading times, their consistent display, and consideration of potential licensing restrictions. The user's IP address is shared with the font provider so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for providing the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA – When visiting our online services, users' browsers send HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and subsequently the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the webpage where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a specific font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts "Analytics" page. Finally, the referrer URL is logged so that the data can be used for production maintenance and to generate an aggregated report on top integrations based on the number of font requests. According to its own statements, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Further information: https://developers.google.com/fonts/faq/privacy?hl=en.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Ad settings: https://adssettings.google.com/authenticated.
Changes and updates to the
privacy policy
We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you as soon as these changes require your cooperation (e.g., consent) or other individual notification.
Where we provide addresses and contact information for companies and organizations in this privacy policy, please note that these addresses may change over time and we ask that you verify the details before contacting them.
Rights of data subjects
As a data subject under the GDPR, you have various rights, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
- Right of access: You have the right to request confirmation as to whether your data is being processed, to access this data, and to receive further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with legal requirements, you have the right to request the completion of your data or the correction of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request the immediate erasure of your data or, alternatively, to request a restriction on the processing of your data.
- Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request its transmission to another controller, in accordance with legal requirements.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data violates the requirements of the GDPR.