Privacy policy

Privacy Policy

Controller

Michael Reichstamm

Email address: hi@mamawillow.com

Legal notice: https://mamawillow.com/policies/terms-of-service

Overview of processing

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

Types of data processed

Inventory data
Payment data
Location data
Contact data
Content data
Contract data
Usage data
Meta, communication and procedural data
Contact information (Facebook)
Event data (Facebook)

Special categories of data

Health data.

Categories of data subjects

Customers
Prospective customers
Communication partners
Users
Business and contractual partners
Persons depicted

Purposes of processing

Provision of contractual services and fulfilment of contractual obligations
Contact requests and communication
Security measures
Direct marketing
Reach measurement
Tracking
Office and organisational procedures
Remarketing
Conversion measurement
Click tracking
Target group formation
Affiliate tracking
Management and handling of enquiries
Feedback
Marketing
Profiles with user-related information
Cross-device tracking
Provision of our online services and user-friendliness
Information technology infrastructure

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find 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 rules may apply in your country of residence or in our country of establishment. Where more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6 (1) sentence 1 point (a) GDPR) - The data subject has given consent to the processing of personal data concerning them for a specific purpose or several specific purposes.

Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

Legal obligation (Art. 6 (1) sentence 1 point (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.

Legitimate interests (Art. 6 (1) sentence 1 point (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, fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection rules in Austria: In addition to the data protection rules of the GDPR, national data protection rules apply in Austria. These include in particular the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Datenschutzgesetz - DSG). The DSG contains in particular special provisions on the right of access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated individual decision-making.

Notice on the applicability of the GDPR and the Swiss FADP: This privacy notice serves to provide information both under the Swiss Federal Act on Data Protection (Swiss FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that, owing to the broader territorial scope and for ease of understanding, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss FADP, “processing” (“Bearbeitung”) of “personal data” (“Personendaten”), “overriding interest” and “sensitive personal data” (“besonders schützenswerte Personendaten”), the terms used in the GDPR are used, namely “processing” of “personal data”, “legitimate interest” and “special categories of data”. However, the legal meaning of the terms continues to be determined in accordance with the Swiss FADP within the scope of the Swiss FADP.

Transfer of personal data

In the course of our processing of personal data, it may happen that the data is transferred 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 embedded in a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the organisation: Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to it. Where this data disclosure takes place for administrative purposes, it is based on our legitimate business and commercial interests, or it takes place where it is necessary for the performance of our contractual obligations, or where the consent of the data subjects or a legal permission exists.

International data transfers

Data processing in third countries: Where we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this takes place only in accordance with the legal requirements. Where the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is ensured in another way, in particular by standard contractual clauses (Art. 46 (2) point (c) GDPR), explicit consent, or in the case of a transfer required by contract or by law (Art. 49 (1) GDPR). Furthermore, we inform you of the basis of the third-country transfer for the individual providers from the third country, with adequacy decisions taking precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognised the level of data protection as secure for certain companies from the USA, within the framework of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In this privacy notice, we inform you which of the service providers we use are certified under the Data Privacy Framework.

Erasure of data

The data processed by us will be erased in accordance with the legal requirements as soon as the consents permitting its 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 necessary for the purpose). Where the data is not erased because it is required for other and legally permissible purposes, its processing is restricted to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person. In the context of our privacy notice, we may provide users with further information on erasure and on the retention of data that applies specifically to the respective processing operations.

Rights of data subjects

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

Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Art. 6 (1) point (e) or (f) GDPR; this also applies to profiling based on those provisions. Where the personal data concerning you is processed for direct marketing purposes, 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 to the extent that it is related to such direct marketing.

Right to withdraw consent: You have the right to withdraw consents you have given at any time.

Right of access: You have the right to request confirmation as to whether the data in question is being processed, and to request access to this data as well as further information and a copy of the data in accordance with the legal requirements.

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

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

Right to data portability: You have the right to receive the data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.

Complaint to a supervisory authority: In accordance with the legal requirements, 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 habitually 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.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”), within the framework of contractual and comparable legal relationships and related measures, and with regard to communication with the contractual partners (or pre-contractually), for example to answer enquiries.

We use this data to fulfil our contractual obligations. These include in particular the obligations to provide the agreed services, any updating obligations, and remedies in the event of warranty and other performance disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as corporate organisation. Furthermore, we process the data on the basis of our legitimate interests in both proper and commercially sound business management and in security measures to protect our contractual partners and our business operations from misuse and from endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities). Within the framework of applicable law, we disclose the data of contractual partners to third parties only to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, for example for marketing purposes, within the framework of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or the like), or in person.

We erase the data after the expiry of statutory warranty and comparable obligations, i.e. in principle after four years, unless the data is stored in a customer account, e.g. for as long as it must be retained for legal archiving reasons (for tax purposes, for example, usually ten years). Data that has been disclosed to us by the contractual partner within the framework of an assignment is erased in accordance with the instructions and, in principle, after the end of the assignment.

Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).

Special categories of personal data: Health data.

Data subjects: Customers; prospective customers. Business and contractual partners.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; contact requests and communication; office and organisational procedures; management and handling of enquiries; conversion measurement (measuring the effectiveness of marketing measures). Profiles with user-related information (creating user profiles).

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); legal obligation (Art. 6 (1) sentence 1 point (c) GDPR). Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Customer account: Customers can create an account within our online services (e.g. customer or user account, “customer account” for short). Where the registration of a customer account is required, customers will be informed of this, as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times, in order to be able to prove the registration and to prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be erased after the time of termination, unless it is retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the responsibility of the customers to back up their data upon termination of the customer account; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

Economic analyses and market research: For business reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, prospective customers, customers, visitors and users of our online services. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may take into account, where available, the profiles of registered users together with their details, e.g. on the services they have used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e. anonymised, values. Furthermore, we respect the privacy of users and process the data for analysis purposes as far as possible in pseudonymised form and, where feasible, anonymously (e.g. as aggregated data); legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Online shop, order forms, e-commerce and delivery: We process the data of our customers in order to enable them to select, purchase or order the chosen products, goods and related services, as well as to pay for and receive delivery or performance of them. Where necessary for the fulfilment of an order, we use service providers, in particular postal, freight and shipping companies, to carry out the delivery or performance for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required details are marked as such in the course of the order or comparable purchasing process and include the details needed for delivery or provision and invoicing, as well as contact information in order to be able to hold any necessary consultation; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

Agency services: We process the data of our customers within the framework of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

Provision of software and platform services: We process the data of our users, registered users and any test users (hereinafter referred to collectively as “users”) in order to be able to provide them with our contractual services, and on the basis of legitimate interests, in order to be able to ensure the security of our services and to develop them further. The required details are marked as such in the course of the placing of the order, purchase or comparable conclusion of the contract and include the details needed for the provision of the service and invoicing, as well as contact information in order to be able to hold any necessary consultation; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

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

In the course of our activities, we may also process special categories of data, here in particular information on the health of clients, where applicable with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. For this purpose, we obtain, where necessary, the explicit consent of the clients 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.

Where it is necessary for the performance of our contract, for the protection of vital interests or required by law, or where the consent of the clients exists, we disclose or transmit the data of clients to third parties or agents, such as authorities, medical institutions, laboratories, billing offices and in the field of IT, office or comparable services, in compliance with professional regulations; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

Use of online platforms for offering and sales purposes

We offer our services on online platforms operated by other service providers. In this context, in addition to our privacy notice, the privacy notices of the respective platforms apply. 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.

Data subjects: Customers.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Marketing.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR). Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Amazon: Online marketplace for e-commerce; service provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://www.amazon.de/; privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010. Basis for third-country transfers: Data Privacy Framework (DPF).

shopify: Platform through which e-commerce services are offered and carried out. The services and the processes carried out in connection with them include in particular online shops, websites, their offers and content, community elements, purchase and payment processes, customer communication as well as analysis and marketing; service provider: Shopify International Limited, Victoria Buildings, 2nd floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://www.shopify.com/de/. Privacy policy: https://www.shopify.com/de/legal/datenschutz.

Providers and services used in the course of business activities

In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short), in compliance with the legal requirements. Their use is based on our interests in the proper, lawful and economical running of our business operations and our internal organisation.

Data subjects: Customers; prospective customers; users (e.g. website visitors, users of online services); business and contractual partners. Communication partners.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures. Contact requests and communication.

Legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Gorgias: Central handling of customer enquiries, chat function and automation; service provider: Gorgias Inc., 34 Harriet Street, CA 94103, San Francisco, USA; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://www.gorgias.com. Privacy policy: https://www.gorgias.com/privacy/privacy.

Payment methods

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

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related details. The details are required in order to carry out the transactions. However, the data entered is processed and stored only by the payment service providers. That is, we do not receive any account- or credit-card-related information, but only information confirming or declining the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit reference agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy notices of the payment service providers.

The terms and conditions and the privacy notices of the respective payment service providers apply to the payment transactions; these can be accessed within the respective websites or transaction applications. We also refer to these for further information and for the assertion of rights of withdrawal, access 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 the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status). Contact data (e.g. email, telephone numbers).

Data subjects: Customers. Prospective customers.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

Further information on processing operations, procedures and services:

Amazon Payments: Payment services (technical connection of online payment methods); service provider: Amazon Payments Europe S.C.A. 38 avenue J.F. Kennedy, L-1855 Luxembourg; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://pay.amazon.de/. Privacy policy: https://pay.amazon.de/help/201212490.

American Express: Payment services (technical connection of online payment methods); service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://www.americanexpress.com/de/. Privacy policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/.

Apple Pay: Payment services (technical connection of online payment methods); service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.

Google Pay: Payment services (technical connection of online payment methods); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://pay.google.com/intl/de_de/about/. Privacy policy: https://policies.google.com/privacy.

Klarna: Payment services (technical connection of online payment methods); service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://www.klarna.com/de. Privacy policy: https://www.klarna.com/de/datenschutz.

Mastercard: Payment services (technical connection of online payment methods); service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://www.mastercard.de/de-de.html. Privacy policy: https://www.mastercard.de/de-de/datenschutz.html.

PayPal: Payment services (technical connection of online payment methods) (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; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Stripe: Payment services (technical connection of online payment methods); service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://stripe.com; privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).

Visa: Payment services (technical connection of online payment methods); service provider: Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, UK; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR); website: https://www.visa.de; privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html. Basis for third-country transfers: Adequacy decision (UK).

Provision of the online services and web hosting

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

Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.

Legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Collection of access data and log files: Access to our online services is logged in the form of so-called “server log files”. 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, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation and stability of the servers; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymised. Data whose further retention is necessary for evidentiary purposes is exempt from erasure until the respective incident has been finally clarified.

Content delivery network: We use a “content delivery network” (CDN). A CDN is a service with the help of which the content of an online service, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely using regionally distributed servers connected via the internet; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Use of cookies

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

Notes on consent: We use cookies in accordance with the legal requirements. We therefore obtain prior consent from users, unless it is not required by law. Permission is in particular not necessary if the storing and reading of the information, including cookies, is strictly necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online services). The consent, which can be withdrawn, is clearly communicated to users and contains the information on the respective cookie use.

Notes on data protection legal bases: The data protection legal basis on which we process users’ personal data by means of cookies depends on whether we ask them for consent. If users accept, the legal basis for the use of their data is the consent given. Otherwise, the data processed by means of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online services and the improvement of their usability) or, if this takes place within the framework of the fulfilment of our contractual obligations, where the use of cookies is necessary in order to comply with our contractual obligations. We explain the purposes for which we use the cookies in the course of this privacy policy or within the framework of our consent and processing procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are erased at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).

Permanent cookies: Permanent cookies remain stored even after the end device has been closed. For example, the login status can be stored and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected by means of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General notes on withdrawal and objection (opt-out): Users can withdraw the consents they have given at any time and can also object to the processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

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

Further information on processing operations, procedures and services:

Processing of cookie data on the basis of consent: We use a consent management solution through which the consent of users to the use of cookies, or to the procedures and providers named within the consent management solution, is obtained. This procedure serves to obtain, log, manage and withdraw consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users’ end devices. Within the framework of this procedure, the consents of users to the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure, are obtained. Users also have the option of managing and withdrawing their consents. The consent declarations are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with the legal requirements. The storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies, in order to be able to assign the consent to a specific user or their device. Unless specific information on the providers of consent management services is available, the following general notes apply: The consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, the information on the scope of the consent (e.g. the categories of cookies and/or service providers concerned) and information on the browser, system and end device used; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR).

Blogs and publication media

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

Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone 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, time stamps, identification numbers, consent status).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness; security measures. Management and handling of enquiries.

Legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (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 on the basis of our legitimate interests. This is done for our security, in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right to process users’ details for the purpose of spam detection on the basis of our legitimate interests.

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

The personal information provided in the course of comments and posts, any contact and website information, as well as the content details, are stored by us permanently until the users object; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media), as well as within the framework of existing user and business relationships, the details of the persons making enquiries are processed to the extent necessary to respond to the contact requests and any measures requested.

Types of data processed: Contact data (e.g. email, telephone 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, time stamps, identification numbers, consent status).

Data subjects: Communication partners.

Purposes of processing: Contact requests and communication; management and handling of enquiries; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.

Legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR).

Further information on processing operations, procedures and services:

Contact form: When users contact us via our contact form, email or other means of communication, we process the data communicated to us in this context in order to deal with the matter raised; legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 point (b) GDPR), legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Communication via messenger

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

You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options communicated to you or the contact options stated 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 the communication content (i.e. the content of the message and attached images) is encrypted end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messengers with encryption activated so that the encryption of the message content is ensured.

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

Notes on legal bases: Where 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, where we do not ask for consent and they contact us of their own accord, for example, we use messengers in relation to our contractual partners and in the course of initiating a contract as a contractual measure, and in the case of other prospective customers and communication partners on the basis of our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messenger. We also point out that we will not transmit the contact data communicated to us to the messengers for the first time without your consent.

Withdrawal, objection and erasure: You can withdraw a consent you have given at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we erase the messages in accordance with our general erasure policies (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information requests from the communication partners, if no reference back to a previous conversation is to be expected and there are no statutory retention obligations to the contrary.

Reservation of the right to refer to other means of communication: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer enquiries made via messenger. This is the case, for example, where contractual internals require special confidentiality or where a reply via messenger does not meet formal requirements. In such cases, we refer you to more appropriate means of communication.

Types of data processed: Contact data (e.g. email, telephone numbers); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).

Data subjects: Communication partners.

Purposes of processing: Contact requests and communication. Direct marketing (e.g. by email or post).

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

Further information on processing operations, procedures and services:

WhatsApp: WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://www.whatsapp.com/; privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: Data Privacy Framework (DPF).

Video conferences, 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 course of participation in a conference, the conference platforms process the personal data of the participants listed 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 real names) and which optional details are provided by the participants. In addition to processing for the purpose of conducting the conference, the participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal details (first name, last name), contact information (email 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’ end devices, their operating system, the browser and its technical and language settings, information on the content-related communication processes, i.e. entries in chats as well as audio and video data, and the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the 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 surveys) and video or audio recordings are logged, participants will be informed of this transparently in advance and - where necessary - asked for their consent.

Data protection measures by the participants: For details of the processing of your data by the conference platforms, please refer to their privacy notices and select the security and privacy settings that are optimal for you within the settings of the conference platforms. Please also ensure data protection and the protection of personality rights in the background of your recording for the duration of a video conference (e.g. by notifying people you live with, locking doors and, where technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.

Notes on legal bases: Where, in addition to the conference platforms, we also process the users’ data and ask the users for their consent to the use of the conference platforms or certain functions (e.g. consent to the 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 participant lists, in the case of the follow-up of conversation results, etc.). Otherwise, the users’ data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; contact requests and communication. Office and organisational procedures.

Legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Zoom: Conference and communication software; service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://zoom.us; privacy policy: https://explore.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). Basis for third-country transfers: Data Privacy Framework (DPF).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Where the contents of the newsletter are specifically described in the course of registration for it, they are decisive for the users’ consent. Otherwise, our newsletters contain information about our services and about ourselves.

To subscribe to our newsletter, it is in principle sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or further details, where these are necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter takes place in principle in a so-called double opt-in procedure. This means that, after registering, you will receive an email in which you are asked to confirm your registration. This is necessary so that nobody can register with other people’s email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Erasure and restriction of processing: We may store the email addresses that have been unsubscribed for up to three years on the basis of our legitimate interests before erasing them, in order to be able to prove a consent previously given. The processing of this data is restricted to the purpose of a potential defence against claims. An individual request for erasure is possible at any time, provided that the former existence of a 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 in a block list (so-called “blocklist”).

The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. Where we commission a service provider with the sending of emails, this takes place on the basis of our legitimate interests in an efficient and secure mailing system.

Option to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e. withdraw your consents or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter, or you can otherwise use one of the contact options stated above, preferably email, for this purpose.

Further information on processing operations, procedures and services:

Measurement of 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 mailing service provider, from its server when the newsletter is opened. In the course of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or of the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until erasure. The evaluations serve 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 open and click rates, the storage of the measurement results in the users’ profiles and their further processing take place on the basis of the users’ consent. A separate withdrawal of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, the stored profile information will be erased; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR).

Klaviyo: Email and SMS marketing platform; service provider: Klaviyo, 225 Franklin St., Boston, Massachusetts 02110, USA; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://www.klaviyo.com/; privacy policy: https://www.klaviyo.com/legal/privacy-notice. Basis for third-country transfers: Data Privacy Framework (DPF).

Promotional communication via email, post, fax or telephone

We process personal data for the purposes of promotional communication, which can take place via various channels, such as email, telephone, post or fax, in accordance with the legal requirements.

The recipients have the right to withdraw consents given at any time or to object to promotional communication at any time.

After withdrawal or objection, we store the data required to prove the previous authorisation to make contact or send communications for up to three years after the end of the year of the withdrawal or objection, on the basis of our legitimate interests. The processing of this data is restricted to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the users’ withdrawal or objection, we also store the data required to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).

Types of data processed: Inventory data (e.g. names, addresses). Contact data (e.g. email, telephone numbers).

Data subjects: Communication partners.

Purposes of processing: Direct marketing (e.g. by email or post).

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

Web analytics, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online services and may include behaviour, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online services or their functions or content are used most frequently, or invite repeat use. It also enables us to understand which areas require optimisation.

In addition to web analytics, we may also use testing procedures, for example to test and optimise different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes and information may be stored in a browser or in an end device and then read out. 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. Where users have consented to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.

In addition, the users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

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

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creating user profiles); provision of our online services and user-friendliness. Tracking (e.g. interest/behaviour-based profiling, use of cookies).

Security measures: IP masking (pseudonymisation of the IP address).

Legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR).

Further information on processing operations, procedures and services:

Google Analytics: We use Google Analytics to measure and analyse the use of our online services on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognise which content users have accessed within one or several usage sessions, which search terms they have used, accessed again or whether they have interacted with our online services. The time of use and its duration are also stored, as well as the sources of the users who refer to our online services and technical aspects of their end devices and browsers.

In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately erased. It is not logged, is not accessible and is not used for any further purposes. When Google Analytics collects measurement data, all IP queries are carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://marketingplatform.google.com/intl/de/about/analytics/; security measures: IP masking (pseudonymisation of the IP address); privacy policy: https://policies.google.com/privacy; data processing agreement: https://business.safety.google/adsprocessorterms/; basis for third-country transfers: Data Privacy Framework (DPF); option to object (opt-out): opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and of the data processed).

Google Tag Manager: We use Google Tag Manager, a tool from Google, in order to be able to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that serve, among other things, to measure and analyse visitor activity. This technology helps us to improve our website and the offering on it. Google Tag Manager itself does not create user profiles, does not store cookies and does not carry out any independent analyses. It merely serves to integrate the tools and services that we use for our website more simply and efficiently. Nevertheless, when Google Tag Manager is used, the users’ IP address is transmitted to Google, which is technically necessary in order to run the various services we use. It is important to know that this data processing only takes place if services that require it are integrated via Tag Manager. For details on these services and how they process data, we refer to the further sections in this privacy policy; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; data processing agreement:

https://business.safety.google/adsprocessorterms. Basis for third-country transfers: Data Privacy Framework (DPF).

Microsoft Clarity: Web analytics, reach measurement and analysis of user behaviour with regard to use and interests concerning functions and content as well as their duration of use, on the basis of a pseudonymous user identification number and profile building; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://clarity.microsoft.com; privacy policy: https://privacy.microsoft.com/de-de/privacystatement; data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF).

Online marketing

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

For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”), or similar procedures are used by means of which the information about the user that is relevant for the display of the aforementioned content is stored. This 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 and functions used. Where users have consented to the collection of their location data, this too may be processed.

In addition, the users’ IP addresses are stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) is stored in the context of the online marketing procedure, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

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

By way of exception, it is possible to assign clear data to the profiles, primarily where the users are, for example, members of a social network whose online marketing procedures we use and the network links the user profiles with the aforementioned information. We ask you to note that users can make additional arrangements with the providers, for example by giving consent in the course of registration.

In principle, we only have access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. for example to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

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

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 procedural data (e.g. IP addresses, time stamps, 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 by other means), and that relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of building target groups for content and advertising information (Custom Audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is erased by Facebook after a maximum of two years, and the target groups formed from it upon the erasure 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 in order to build Custom Audiences. After the matching for the purpose of building target groups, the contact information is erased).

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/behaviour-based profiling, use of cookies); conversion measurement (measuring the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creating user profiles); provision of our online services and user-friendliness; remarketing; click tracking. Cross-device tracking (cross-device processing of user data for marketing purposes).

Security measures: IP masking (pseudonymisation of the IP address).

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

Option to object (opt-out): We refer to the privacy notices of the respective providers and the options to object (so-called “opt-out”) stated for the providers. Where no explicit opt-out option has been stated, you can, on the one hand, switch off cookies in your browser settings. However, this may restrict functions of our online services. We therefore additionally recommend the following opt-out options, which are offered collectively 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-regional: https://optout.aboutads.info.

Further information on processing operations, procedures and services:

Amazon: Marketing of advertising materials and advertising space; service provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://www.amazon.de; privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010. Basis for third-country transfers: Data Privacy Framework (DPF).

Meta pixel and target group formation (Custom Audiences): With the help of the Meta pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), the company Meta 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 “Meta Ads”). Accordingly, we use the Meta pixel to display the Meta Ads placed by us only to those users on Meta’s platforms and within the services of Meta’s cooperating partners (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online services or who have certain characteristics (e.g. interest in certain topics or products, which become apparent from the websites visited) that we transmit to Meta (so-called “Custom Audiences”). With the help of the Meta pixel, we also want to ensure that our Meta Ads correspond to the potential interest of users and do not have a nuisance effect. With the help of the Meta pixel, we can also trace the effectiveness of the Meta Ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta Ad (so-called “conversion measurement”); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (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; basis for third-country transfers: Data Privacy Framework (DPF); further information: Users’ event data, i.e. information on behaviour and interests, is processed for the purposes of targeted advertising and target group formation on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by, and transmission of data to, Meta Platforms Ireland Limited, a company established in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

Advanced matching for the Meta pixel: In addition to the processing of event data in the course of using the Meta pixel (or comparable functions, e.g. in apps), contact information (data identifying individual persons, such as names, email addresses and telephone numbers) is also collected by Meta within our online services or transmitted to Meta. The processing of the contact information serves to build target groups (so-called “Custom Audiences”) for the display of content and advertising information oriented to the presumed interests of users. The collection, or transmission and matching with data held by Meta, does not take place in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, when storing passwords). After the matching for the purpose of building target groups, the contact information is erased; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); privacy policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://www.facebook.com/legal/terms/data_security_terms.

Meta - target group formation via data upload: Building target groups for marketing purposes - We transmit contact information (names, email addresses and telephone numbers) in list form to Meta for the purpose of building target groups (so-called “Custom Audiences”) for the display of content and advertising information oriented to the presumed interests of users. The transmission and matching with data held by Meta does not take place in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, when storing passwords). After the matching for the purpose of building target groups, the contact information is erased; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (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. Basis for third-country transfers: Data Privacy Framework (DPF).

Facebook advertisements: Placing advertisements within the Facebook platform and evaluating the advertisement results; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; basis for third-country transfers: Data Privacy Framework (DPF); option to object (opt-out): We refer to the privacy and advertising settings in the users’ profile on the Facebook platforms, as well as to Facebook’s consent procedures and contact options for exercising rights of access and other data subject rights, as described in Facebook’s privacy policy; further information: Users’ event data, i.e. information on behaviour and interests, is processed for the purposes of targeted advertising and target group formation on the basis of the joint controllership agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by, and transmission of data to, Meta Platforms Ireland Limited, a company established in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

Google Ad Manager: We use the service “Google Ad Manager” to place advertisements in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Google Ad Manager is characterised by the fact that advertisements are displayed in real time on the basis of the presumed interests of users. This allows us to display advertisements for our online services to users who may have a potential interest in our offering or who were previously interested in it, and to measure the success of the advertisements; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; basis for third-country transfers: Data Privacy Framework (DPF); further information: Types of processing and of the data processed: https://business.safety.google/adsservices/; data processing terms for Google advertising products: Information on the services, data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms. Where Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.

Google Ads and conversion measurement: Online marketing procedure for the purpose of placing content and advertisements within the service provider’s advertising network (e.g. in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the advertisements, i.e. whether the users took them as an occasion to interact with the advertisements and to use 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 bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR), legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR); website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; basis for third-country transfers: Data Privacy Framework (DPF); further information: Types of processing and of the data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.

Google Ads remarketing: Google remarketing, also called retargeting, is a technology by which users who use an online service are included in a pseudonymous remarketing list, so that advertisements can be displayed to the users on other online services on the basis of their visit to the online service; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy; basis for third-country transfers: Data Privacy Framework (DPF); further information: Types of processing and of the data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.

Enhanced conversions for Google Ads: When customers click on our Google advertisements and subsequently use the advertised service (so-called “conversion”), the data entered by the user, such as the email address, name, home address or telephone number, may be transmitted to Google. The hash values are then matched with users’ existing Google accounts in order to be able to better evaluate and improve the users’ interaction with the advertisements (e.g. clicks or views) and thus their performance; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.

Outbrain: Display of personalised advertisements; service provider: Outbrain United Kingdom Limited, 175 High Holborn, London WC1V 7AA, United Kingdom; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://www.outbrain.com; privacy policy: https://www.outbrain.com/privacy/. Erasure of data: The stored personal data is erased or anonymised after 13 months.

Pinterest Tag: Interest- and behaviour-based measurement and analysis of users’ interaction with our online services (in particular page visits, search entries, transactions, video and page views as well as time and period) for the purpose of building target groups for the display of content and advertising content within the Pinterest platform and the partners participating in its advertising network; service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://help.pinterest.com/en/business/article/track-conversions-with-pinterest-tag; privacy policy: https://policy.pinterest.com/de/privacy-policy; option to object (opt-out): https://help.pinterest.com/de/article/personalized-ads-on-pinterest. Further information: Joint controllership agreement in the “Pinterest Advertising Services Agreement, Annex B: Pinterest Joint Controller Addendum” https://business.pinterest.com/de/pinterest-advertising-services-agreement/.

Taboola: Provision of functions for the display of personalised advertising on the basis of interest- and behaviour-based information, which includes demographic characteristics, interests and the browsing history of users and is stored in user profiles; service provider: Taboola, Inc. 16 Madison Square West 7th Floor New York, New York 10010, USA; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR); website: https://www.taboola.com/de; privacy policy: https://www.taboola.com/privacy-policy; data processing agreement: Provided by the service provider; basis for third-country transfers: Standard contractual clauses (provided by the service provider); erasure of data: Taboola stores user information collected directly for the purpose of ad delivery for a maximum of eighteen (18) months after the user’s last interaction with the Taboola services and anonymises it by removing personal identifiers or aggregating the data. Taboola stores anonymous or aggregated data that cannot identify a person or a device and is used for reporting and analysis purposes for as long as this is commercially necessary. Option to object (opt-out): https://www.taboola.com/privacy-policy#user-choices-and-optout.

UTM parameters: Analysis of sources and user actions on the basis of an extension of web addresses referring to us with an additional parameter, the “UTM” parameter. For example, a UTM parameter “utm_source=platformX &utm_medium=video” can tell us that a person clicked on the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. post, link, image and video). With the help of this information, we can, for example, check our visibility on the internet or the effectiveness of our campaigns; legal bases: Legitimate interests (Art. 6 (1) sentence 1 point (f) GDPR).

Facebook Conversions API: We use Facebook’s “Conversions API”. The Conversions API is an interface by which event data is sent directly from our servers to Facebook. The way the Conversions API works and the way data is processed in the course of it corresponds to the way the Facebook pixel works and processes data, which is why, in this respect, we refer to the privacy notices on the Facebook pixel and target group formation; legal bases: Consent (Art. 6 (1) sentence 1 point (a) GDPR).

Privacy policy

Privacy Policy

Controller

Overview of processing

Types of data processed

Special categories of data

Categories of data subjects

Purposes of processing

Relevant legal bases

Transfer of personal data

International data transfers

Erasure of data

Rights of data subjects

Business services

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Use of online platforms for offering and sales purposes

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Providers and services used in the course of business activities

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Payment methods

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Provision of the online services and web hosting

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Use of cookies

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Blogs and publication media

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Contact and enquiry management

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Communication via messenger

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Video conferences, online meetings, webinars and screen sharing

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Newsletters and electronic notifications

Contents:

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Promotional communication via email, post, fax or telephone

Web analytics, monitoring and optimisation

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Online marketing

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