The following information is provided in accordance with German legal requirements for provider identification (Impressum) under §5 of the German Telemedia Act (TMG).
Responsible under press regulation (VisdP)
Postal address
Cornelia Lichtner
Schlossstrasse 85
77815 Bühl
GERMANY
Contact
eMail: cornelia@cornelialichtner.de
phone: +49 179 5386 180
Office address
Kloster-Oase
Josef-Bäder-Weg 2
77815 Bühl-Neusatzeck
GERMANY
VAT Identification Number
VAT identification number according to §27a German Value Added Tax Act: DE36170/38813
Therapeutic services are exempt from VAT in accordance with §4 No. 14 of the German Value Added Tax Act (UStG). Therefore, no VAT is charged or shown for these services.
Professional Title and Regulatory Information
Professional title: Heilpraktikerin für Psychotherapie (licensed under the German Heilpraktiker Act)
The license pursuant to §1 para. 1 of the German Heilpraktiker Act was granted on 27 November 2024 by the Public Health Authority of the City of Karlsruhe, Germany.
Legal regulations: German Heilpraktiker Act and Implementing Regulation
Available at:
http://www.gesetze-im-internet.de/heilprg/index.html
https://www.gesetze-im-internet.de/heilprgdv_1/index.html
Supervisory Authority
Public Health Authority Karlsruhe
Kriegsstraße 100
76133 Karlsruhe
Germany
Professional Associations
Member of the Verband Freier Psychotherapeuten, Heilpraktiker für Psychotherapie und Psychologischer Berater e.V. (VFP) – Professional Association of Independent Psychotherapists, Practitioners for Psychotherapy and Psychological Counselors
https://www.vfp.de
Professional Code of Conduct (Berufsordnung) of the VFP: https://vfp.de/verband/berufsordnung

Member of the MBSR-MBSR-Verband (German MBSR-MBCT Teachers Professional Association): https://www.mbsr-verband.de

Professional Liability Insurance
Continentale Versicherungsgesellschaft
Territorial coverage: Federal Republic of Germany
Dispute Resolution
We are neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board.
Data Protection Policy
The following Privacy Policy provides information about the processing of personal data when using this website. This English version is provided for convenience and informational purposes only. It is a translation of the original German Privacy Policy. In case of discrepancies or inconsistencies between the English and German versions, the German version shall prevail and shall be legally binding.
Preamble
With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) ) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering” ).
As of January 28, 2026
Table of contents
- Preamble
- Responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transfer of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Payment procedures
- Provision of the online offering and web hosting
- Use of cookies
- Registration, login, and user account
- Single sign-on login
- Blogs and publication media
- Contact and inquiry management
- Newsletters and electronic notifications
- Surveys and questionnaires
- Web analysis, monitoring, and optimization
- Online marketing
- Customer reviews and rating procedures
- Presence on social networks (social media)
- Plug-ins and embedded functions and content
- Management, organization, and support tools
- Changes and updates
- Definition of terms
Responsible party
Cornelia Lichtner
Schlossstrasse 85
77815 Bühl
Germany
Email address: kontakt@cornelialichtner.de
Phone: +49 179 5386180
Legal notice: https://cornelialichtner.de/impressum/
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.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of data subjects
- Service recipients and clients.
- Prospective customers.
- Communication partners.
- Users.
- Business and contractual partners.
- Education and course participants.
- Participants.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target group formation.
- Organizational and administrative procedures.
- Feedback.
- Surveys and questionnaires.
- Marketing.
- Profiles with user-related information.
- Registration procedures.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Business processes and business management procedures.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find 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 provisions of the GDPR, national data protection regulations may apply in your or our country of residence or country of residence. If more specific legal bases are applicable in individual cases, we will inform you of this in the privacy policy.
- Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 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 prior to entering into a contract which are carried out at the request of the data subject.
- Legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject requiring the protection of personal data do not override those interests.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, the scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, transfer, availability, and separation of data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and responses to data breaches. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Securing online connections using TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transmission of personal data
In the course of our processing of personal data, it may happen that this data is transmitted to other bodies, 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.
Use of SOMBA.io
Subdomains of our website and our CRM are operated using SOMBA.io software, which is based on the HighLevel platform. Personal data may be processed by HighLevel Inc., United States of America. The platform is used to provide contact forms, appointment bookings, courses, email communication (e.g., newsletters), and payment processing. SOMBA.io is used as a technical platform.
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 using third-party services or disclosing or transferring data to other persons, agencies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this is always done in accordance with legal requirements.
For data transfers to the USA, the transfer mechanisms provided for by law are used, in particular the EU-U.S. Data Privacy Framework and
– where necessary – the EU Commission’s standard contractual clauses.
We will inform you whether the individual service providers 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 US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consent, or transfers required by law. 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=en.
General information on data storage and deletion
We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer . Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the 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 data protection information contains additional information on the storage and deletion of data that apply specifically to certain processing operations.
If there are several specifications regarding the storage period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.
Storage and deletion of data: The following general periods apply to storage and archiving under German law:
- 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) 3 AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB).
- 8 years – Accounting documents, such as invoices and expense receipts (Section 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).
- 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant to taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting documents, and cash register receipts (§ 147 (1) No. 2, 3, 5 in conjunction with (3) AO, § 257 (1) No. 2 and 3 in conjunction with ( 4 HGB).
- 3 years – Data that is necessary 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 customary industry practices, is stored for the duration of the regular statutory limitation period of three years
- (Sections 195, 199 BGB).
Start of the period at the end of the year: If a period does not expressly begin on a specific date and lasts at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If 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 insofar as it is connected with such direct marketing .
- Right of revocation of consent: You have the right to revoke your consent at any time.
- Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about 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 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 to request that data concerning you be deleted immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
- Right to data portability: You have the right to receive data concerning you you have provided to us in a structured, commonly used, and machine-readable format or to request that it be transferred to another controller.
- Complaint to 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, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the provisions of the GDPR.
Business services
We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”), within the framework of contractual and comparable legal relationships and associated measures and with regard to communication with contractual partners (or pre-contractual), for example, to respond to inquiries.
We use this data to fulfill our contractual obligations.
This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies for warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of administrative tasks associated with these obligations and company organization. We also process the data on the basis of our legitimate interests in both proper and business-oriented management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g. e.g., for the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, within the framework of this privacy policy.
We inform contractual partners of the data required for the aforementioned purposes before or during data collection, e.g., in online forms, by means of special markings (e.g., colors) or symbols (e.g., asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for archiving purposes for legal reasons (e.g. for tax purposes, usually ten years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; interested parties; Business and contractual partners. Education and course participants.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); legal obligation (Art. 6 (1) (c) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Payment procedures
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the persons concerned efficient and secure payment options and use banks, credit institutions and other service providers (collectively referred to as “payment service providers”) for this purpose. In accordance with the state of the art, payment transactions are carried out exclusively via encrypted connections, so that the data entered is protected against unauthorized access during transmission .
Payment processing is carried out via our subdomains, which are operated with SOMBA.io.
The data processed by the payment service providers includes inventory data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract and sum and recipient-related information. This information is required in order to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or denying the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transfer is to verify identity and creditworthiness. For more information, please refer to the terms and conditions and privacy policy of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which can be found on their websites or in their transaction applications. We also refer to these for further information and the assertion of rights of revocation, information, and other rights of data subjects.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); 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., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved). Contact details (e.g., postal and email addresses or telephone numbers).
- Data subjects: Service recipients and clients; business and contractual partners. Prospective customers.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing operations, procedures, and services:
- 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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (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 basis: Contract performance and pre-contractual inquiries (Art. 6 (1) (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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de. Privacy policy:https://www.paypal.com/de/legalhub/paypal/privacy-full.
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 (1) (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, GB; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
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 end device.
- Types of data processed: Usage data (e.g., page views and length of stay, 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 stamps, identification numbers, persons involved). Log data (e.g., log files relating to 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 offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods, and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a server provider (also known as a “web host”) or otherwise obtain; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” The server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the event of malicious attacks), and are usually stored for a period of 30 days.
- page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server utilization and stability. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR) . Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider:STRATO AG, Pascalstraße 10,10587 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.strato.de; Privacy policy:https://www.strato.de/datenschutz/ . Data processing agreement: Provided by the service provider.
- Our main domain is operated on servers belonging to STRATO AG, Germany. Here we primarily provide information and content pages (e.g., texts, blog posts). Certain functions of our online offering are provided via subdomains that are operated with the SOMBA.io software. These subdomains are technically separate from the main domain.
Use of cookies
The term “cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes , such as for the functionality, security, and convenience of online offerings, as well as for the creation of visitor flow analyses. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of consent and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
- Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device has been closed. For example, the log
- status can be stored and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years .
General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including by using the privacy settings of their browser.
- Types of data processed: Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Users (e.g., website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR). Consent (Art. 6 (1) (1) (a) GDPR).
Further information on processing procedures, processes, and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users’ consent to the use of cookies or to the procedures and providers specified in the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and similar technologies that are used to store, read and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers specified in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the 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. If no specific information on the providers of consent management services, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used; Legal basis:
- consent (Art. 6 (1) (a) GDPR).
- BorlabsCookie: storage and management of consent (consent to cookies and data processing), logging of user decisions, display of notices on data protection and cookies, enabling users to revoke or adjust their consent; Service provider: Execution on servers and/or computers under our own data protection responsibility; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language, types of consent, and the time of consent are stored on the server and in a cookie on the user’s device.
Registration, login, and user account
Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The data processed includes, in particular, login information (user name, password, and email address).
When using our registration and login functions and the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests and those of the users in protection against misuse and other unauthorized use. This data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users can be informed by email about processes that are relevant to their user account, such as technical changes.
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., text or image messages and posts, as well as information relating to them, such as details of 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). Log data (e.g., log files relating to 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 contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online offering and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Deletion after termination.Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, processes, and services:
- User profiles are not public: User profiles are not publicly visible or accessible.
- Deletion of data after termination: When users terminate their user accounts, their data relating to the user account will be deleted, subject to legal permission, obligation, or consent of the users; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- No obligation to retain data: It is the responsibility of users to back up their data before the end of the contract upon termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Single sign-on
“Single sign-on” or “single sign-on authentication” refers to procedures that allow users to log in to our online offering using a user account with a single sign-on provider (e.g., a social network). The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already logged in with the single sign-on provider and confirm the single sign-on login via a button.
Authentication takes place directly with the respective single sign-on provider. As part of this authentication process, we receive a user ID with the information that the user is logged in with this user ID at the respective single sign-on provider and an ID that cannot be used by us for other purposes (known as a “user handle”). Whether additional data is transmitted to us depends solely on the single sign-on procedure, the data sharing options selected during authentication, and the data that users have shared in the privacy or other settings of their user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, this may be different data, but it is usually the email address and the user name. We cannot see the password entered during the single sign-on process with the single sign-on provider, nor do we store it.
Users are asked to note that the information we store about them can be automatically synchronized with their user account with the single sign-on provider, but that this is not always possible or actually done. If, for example, users’ email addresses change,
they must change it manually in their user account with us.
We may use single sign-on registration, if agreed with users, within the scope of or prior to the fulfillment of the contract, insofar as users have been asked to process it within the scope of consent, and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure login system.
If users decide that they no longer want to use the link to their user account with the single sign-on provider for the single sign-on procedure, they must remove this link within their user account with the single sign-on If users wish to delete their data from our system, they must cancel their registration with us.
- 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); 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 stamps, identification numbers, persons involved) .
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; registration procedures. Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Deletion after termination.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing, procedures, and services:
- Google Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information, and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.google.de; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Option to object (opt-out): Settings for the display of advertisements: https://myadcenter.google.com/.
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter referred to as “publication medium”). Reader data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication medium in this privacy policy.
- 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 contributions as well as information relating to them, such as details of authorship or time of creation); usage data (e.g., page views and length of stay, 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 stamps, identification numbers, persons involved).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures. Organizational and administrative procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR).
Further information on processing procedures, processes, and services:
- Comments and posts: If users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests. On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to prevent multiple votes. The Personal information provided in comments and posts, any contact and website information, as well as content information, will be stored by us permanently until the user objects; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR) .
- Akismet anti-spam check: Akismet anti-spam check – Based on our legitimate interests, we use the “Akismet” service based on our legitimate interests. Akismet helps distinguish comments made by real people from spam comments. To do this, all comment information is sent to a server in the USA, where it is analyzed and stored for four days for comparison purposes. If a comment is classified as spam, the data is stored beyond this period. This information includes the name entered, email address, IP address, comment content, referrer, information about the browser and computer system used, and the time of entry. Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a shame, but unfortunately we do not see any alternatives that work as effectively; Service provider:
Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).
Profile pictures from Gravatar: Profile pictures – We use the Gravatar service within our online offering and in particular in our blog. Gravatar is a service where users can register and store profile pictures and their email addresses. When users leave posts or comments on other online presences (especially in blogs) using the respective email address, their profile pictures may be displayed next to the posts or comments. For this purpose, the email address provided by the user is transmitted to Gravatar in encrypted form to check whether a profile is stored for that address. This is the sole purpose of transmitting the email address. It is not used for any other purpose and is deleted afterwards. The use of Gravatar is based on our legitimate interests, as Gravatar enables us to offer post and comment authors to personalize their posts with a profile picture. By displaying the pictures, Gravatar obtains the IP address of the users, as this is necessary for communication between a browser and an online service. If users do not want a user picture linked to their email address at Gravatar to appear in the comments, they should use an email address for commenting that that is not stored with Gravatar. We would also like to point out that it is also possible to use an anonymous or no email address if users do not want their own email address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Data processing agreement: Provided by the service provider. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).
UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd., 11, Barringer Way, St. Neots, Cambs. , PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://updraftplus.com/. Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.
Contact and inquiry management
When contacting us (e.g., by mail, contact form, email, telephone, or social media) and within the scope of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to contact requests and any requested measures.
- Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation). Meta, communication, and process data (e.g., IP addresses, time stamps, 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 offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (1) (b) GDPR).
Further information on processing procedures, methods, and services:
- Contact form: When you contact us via our contact form, by email, or other means of communication, we process the personal data you provide to respond to and process your request. This usually includes information such as your name, contact details, and, if applicable, other information that you provide to us and that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; Legal basis : Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (1) (f) GDPR).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potential defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called “block list”) for this purpose only.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions, and offers.
- 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); meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g., by email or post).
- Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
- Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter at the end of each newsletter, or you can use one of the contact options listed above, preferably email.
Further information on processing, procedures, and services:
- GetResponse: Email delivery and automation services; Service provider: GetResponse Sp. z o.o., Arkonska 6, A3, Gdansk (80-387), Poland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.getresponse.de/ ; Privacy policy:https://www.getresponse.de/email-marketing/legal/datenschutz.html. Basis for third-country transfers:Standard contractual clauses (https://www.getresponse.com/de/legal/standardvertragsklauseln).
Surveys and questionnaires
We conduct surveys and questionnaires to collect information for the purpose communicated in each survey or questionnaire. The surveys and questionnaires we conduct (hereinafter referred to as “questionnaires”) are evaluated anonymously. Personal data is only processed to the extent necessary for the provision and technical implementation of the surveys (e.g., processing the IP address to display the survey in the user’s browser or using a cookie to enable the survey to be resumed) .
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., text or image messages and posts, as well as information relating to them, such as details of 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: Participants.
Purposes of processing: Feedback (e.g., collecting feedback via online form). Surveys and questionnaires (e.g., surveys with input options, multiple-choice questions).
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods, and services:
- Google Form: Creation and evaluation of online forms, surveys, feedback forms, etc.; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website:https://www.google.de/intl/de/forms; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://cloud.google.com/terms/eu-model-contract-clause) .
Web analysis, monitoring, and optimization
Web analysis (also known as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about 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 offering or its functions or content are used most frequently, or invite reuse. It also enables us to understand which areas require optimization.
In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offering or its components.
Unless otherwise specified below, profiles, i.e., data summarized for a usage process, can be created for these purposes and information can be stored in a browser or on a device and then read. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed 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 IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users is stored in the context of web analysis, A/B testing, and optimization (such as email addresses or names) is stored in web analytics, A/B testing, and optimization, but rather 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.
Information 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 like to
also 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 length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions) . Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
- 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 (creation of user profiles). Provision of our online offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering 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 a terminal device in order to identify which content users have accessed within one or more usage processes, which search terms they have used, which they have accessed again, or how they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their terminal devices and browsers.
- In doing so, pseudonymous anonymous user profiles 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 geographic 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, IP address data is used solely for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed 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 basis: Consent (Art. 6(1)(a) GDPR);
- Website:https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization 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), standard contractual clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information:https://business.safety.google/adsservices/ (types of processing and data processed).
- Google Tag Manager: We use Google Tag Manager, a Google software that allows us to centrally manage website tags via a user interface. Tags are small code elements on our website that are used to record and analyze visitor activity. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, does not store cookies with user profiles, and does not perform any independent analyses. Its function is limited to simplifying and streamlining the integration and management of tools and services that we use on our website. Nevertheless, when using Google Tag Manager, the IP address of the user is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via Tag Manager. For more detailed information on these services and their data processing, please refer to the following sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR) ; Website: https://marketingplatform.google.com; Privacy policy:https://policies.google.com/privacy; Data processing agreement:
- https://business.safety.google/adsprocessorterms. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms).
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 advertising and other content (collectively referred to as “content”) based on 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 (the so-called “cookie”) or similar procedures are used,
which are used to store information about the user that is relevant for the display of the aforementioned content. 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 about usage times and functions used. If users have consented to the collection of their location data, this may also be processed .
In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or using similar methods. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if if, for example, users are members of a social network whose online marketing method we use and the network links the user profiles with the aforementioned information. Please note that users can enter into additional agreements with the providers, for example by giving their consent during registration.
We generally only have access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that the cookies used will be stored for a period of two years.
Information 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.
Information on revocation and objection:
We refer to the data protection information of the respective providers and the options for objection (so-called “opt-out”) specified for the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings.
However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective regions:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-regional: https://optout.aboutads.info.
- 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 stamps, identification numbers, persons involved).
- 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/behavior-based profiling, use of cookies); target group formation; marketing; profiles with user-related information (creation of user profiles). Conversion measurement (measurement of the effectiveness of marketing measures).
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods, and services:
- Google Ads and conversion measurement: Online marketing method for placing content and ads 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 are likely to be interested in the ads. In addition, we measure the conversion of the ads, i.e., whether users have taken the opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (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 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.
Customer reviews and rating procedures
We participate in review and rating procedures in order to evaluate, optimize, and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the providers’ general terms and conditions or terms of use and privacy policies also apply. As a rule, the rating also requires registration with the respective providers.
To ensure that the persons giving the ratings have actually used our services, we transmit the necessary data regarding the customer and the service used to the respective rating platform (including name, email address, and order number or item number) with the customer’s consent. . This data is used solely to verify the authenticity of the user.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Service recipients and clients. Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR).
Further information on processing procedures, processes, and services:
- Review widget: We integrate so-called “review widgets” into our online offering . A widget is a functional and content element integrated into our online offering that displays variable information. It can be displayed, for example, in the form of a seal or similar element, sometimes also referred to as a “badge.” The corresponding content of the widget is displayed within our online offering, but at that moment it is retrieved from the servers of the respective widget . This is the only way to ensure that the current content is always displayed, especially the current rating. To do this, a data connection must be established from the website accessed within our online offering to the widget provider’s server, and the widget provider receives certain technical data (access data, including IP address) that is necessary to deliver the content of the widget to the user’s browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to recognize which online offerings participating in the rating process have been visited by the user. The information can be stored in a user profile and used for advertising or market research ; Legal basis: Legitimate interests (Art. 6 (1) (f)
- GDPR).
Presence on social networks (social media)
We maintain an online presence on social networks and process user data in this context in order to communicate with users who are active there or to provide information about us.
We would like to point out that user data may be processed outside the European Union. This may pose risks for users, because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users’ computers in which the usage behavior and interests of users are stored. In addition, data can also be stored in the usage profiles independently of the devices used by users (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 options for objection (opt-out) , please refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and posts, as well as information relating to them, such as details of 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.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, procedures, and services:
Instagram: Social network that allows users to share photos and videos, comment on and favorite posts, send messages, and subscribe to profiles and pages; Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy policy:https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).Facebook pages: Profiles within the Facebook social network – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page (“fan page”). This includes, in particular, information about user behavior (e.g., content viewed or interacted with, actions performed) and device information (e.g., IP address, operating system, browser type, language settings, cookie data). For more information, please refer to the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical analyses via the “Page Insights” service, which provide information about how people interact with our page and its content. This is based on an agreement with Facebook (“Information about Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transfer to Meta Platforms Inc. in the USA, Meta Platforms Ireland Limited is solely responsible; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR) ; website:https://www.facebook.com; privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum) .LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to generate “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size, and employment status. Information about LinkedIn’s processing of user data can be found in LinkedIn’s privacy policy: https://www. linkedin.com/legal/privacy-policy.We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint
- responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/ dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Pinterest: Social network that allows users to share photos, comment on, favorite, and curate posts, send messages, and subscribe to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.pinterest.com. Privacy policy:https://policy.pinterest.com/de/privacy-policy.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option:https://myadcenter.google.com/personalizationoff.
Plug-ins and embedded functions and content
We integrate functional and content elements into our online offering 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 referred to uniformly as “content”).
The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavor 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 known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can 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, and other information about the use of our online offering, but can also be linked to such information from other sources.
Information 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 length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions) . Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest/behavior-based profiling, use of cookies); target group formation. Marketing.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion .” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 (1) (f) GDPR).
Further information on processing, procedures, and services:
- Google Fonts (hosted on our own server): Provision of font files for the purpose of user-friendly presentation of our online offering; Service provider: Google Fonts are hosted on our server; no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website:https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Management, organization, and auxiliary tools
We use services, platforms, and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organization, administration, planning, and provision of our services. We comply with legal requirements when selecting third-party providers and their services.
Within this framework, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes, and their content.
If users are referred to third-party providers or their software or platforms in the context of communication, business, or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to observe the privacy policies of the respective third-party providers.
- Types of data processed: Content data (
- e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation) ; usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
- Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR).
Changes and updates
We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.
If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and check the information before contacting them.
Definition of terms
This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.
- Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unique assignment and communication.
- Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata
- that provide information about the content itself, such as tags, descriptions, author information, and publication dates
- Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a process that can be used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user’s device within the websites where the marketing measures are carried out and then retrieved again on the target website. For example, this allows us to track whether the ads we place on other websites were successful.
- Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include information about file size, creation date, the author of a document, and change histories. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission routes. Process data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
- Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Profiles with user-related information: The processing of “profiles with user-related information,” or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data
- to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes. Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as time, date, subject, sender, recipient, content, and location. Cookies and web beacons are often used for profiling.
- Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, monitor security, or generate performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them, for example, to better tailor the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
- Tracking: “Tracking” refers to the tracking of user behavior across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it involves the collection, evaluation, storage, transmission, or deletion of data.
- Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged, or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
- Payment data:
Target group formation: Target group formation (known as “custom audiences”) refers to the process of determining target groups for advertising purposes, e.g., displaying advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online store where they viewed the products. . “Lookalike audiences” (or similar target groups) refer to situations where content deemed suitable is displayed to users whose profiles or interests are presumed to correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
