Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process for what purposes and to what extent in the context of providing our application.

The terms used are not gender-specific.

Table of Contents

Controller

Overview of Processing

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

Types of Data Processed

• Inventory data
• Contact data
• Content data
• Usage data
• Meta, communication and procedural data
• Log data

Categories of Data Subjects

• Communication partners
• Users

Purposes of Processing

• Communication
• Security measures
• Organizational and administrative procedures
• Feedback
• Provision of our online services and user-friendliness
• Information technology infrastructure
• Public relations

Relevant Legal Bases

Relevant Legal Bases under the GDPR: Below you will receive an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 s. 1 lit. 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 para. 1 s. 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the application of GDPR and Swiss DPA: These data protection notices serve to provide information under both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA "processing" of "personal data", "overriding interest" and "particularly sensitive personal data", the terms used in the GDPR "processing" of "personal data" as well as "legitimate interest" and "special categories of data" are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DPA within the scope of the application of the Swiss DPA.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing availability and separation of data. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data and responses to data threats. Furthermore, we take the protection of personal data into account already during the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Transmission of Personal Data

In the context of our processing of personal data, it occurs that the data is transmitted to or disclosed to other places, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons, places or companies (which becomes apparent from the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this always takes place in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual protection ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of potential political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, express consent or legally required transfers. Information on third country transfers and applicable 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.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or no other legal basis for processing exists. This applies to cases where the original purpose of processing ceases to apply or the data is no longer needed. Exceptions to this rule exist when legal obligations or special interests require longer retention or archiving of data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that specifically applies to certain processing processes.

When multiple retention periods or deletion deadlines are specified for a datum, the longest period is always decisive. Data that is no longer retained for the originally intended purpose but due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply for retention and archiving under German law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
• 8 years - Accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
• 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating statement sheets, calculation documents, price markings, but also payroll documents insofar as they are not already accounting documents and till receipts (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
• 3 years - Data that is required to consider potential warranty and damage claims or similar contractual claims and rights as well as to process related inquiries, based on previous business experience and common industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

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

• Right to object: You have the right to object at any time to processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR, on grounds relating to your particular situation; this also applies to profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw consent at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and information about this data as well as further information and a copy of the data in accordance with legal provisions.
• Right to rectification: You have the right in accordance with legal provisions to request the completion of personal data concerning you or the rectification of inaccurate personal data concerning you.
• Right to erasure and restriction of processing: You have the right in accordance with legal provisions to request that personal data concerning you be erased without undue delay, or alternatively to request restriction of processing of the data in accordance with legal provisions.
• Right to data portability: You have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal provisions or to request its transmission to another controller.
• 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 consider that the processing of personal data relating to you infringes the GDPR.

Provision of Online Services and Web Hosting

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

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Log data (e.g. log files concerning logins or the retrieval of data or access times).
• 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.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).

Further information on processing processes, 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". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and usually IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid server overload (especially in case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR). Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidence purposes is excluded from deletion until final clarification of the respective incident.

Contact and Inquiry Management

When contacting us (e.g. by mail, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to contact inquiries and any requested measures.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

• Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, further information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).

Social Media Presence

We maintain online presences within social networks and process user data in this context to communicate with users active there or to offer information about us.

We point out that user data may be processed outside the territory of the European Union. This may result in risks for users because, for example, the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests of users. The usage profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For this purpose, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need help, then you can contact us.

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Instagram: Social network, enables sharing of photos and videos, commenting and favoriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
• X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR); Website: https://x.com. Privacy Policy: https://x.com/de/privacy.

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online service that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of users, since they could not send the content to their browser without the IP address. The IP address is thus required for the presentation of this content or functions. We strive to use only content whose respective 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 referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time as well as other information about the use of our online service, but may also be linked to such information from other sources.

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

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online services and user-friendliness.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion". Storage of cookies of up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
• Legal bases: Consent (Art. 6 para. 1 s. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Google Fonts (obtained from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user's IP address 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 the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online service, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then 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 web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. In the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on Google Fonts' "Analytics" page. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations based on the number of font requests can be generated. According to Google, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertising; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.