Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: March 3, 2025
Person responsible:
Moritz Kumpfmüller
Vectopay GmbH
Friedrichstrasse 33
80801 Munich
Authorized representative: Moritz Kumpfmüller
Email: info@vectopay.com
Imprint: www.vectopay.com
Contact Data Protection Officer:
info@vectopay.com
Representative in the European Union
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, Location data, Contact data, Content data, Contract data, Usage data Meta, communication and process data, Protocol data
Categories of affected persons:
Beneficiaries and clients, interested parties, communication partner, user, business and contractual partners, customers
Purposes of the processing:
Provision of contractual services and fulfillment of contractual obligations, communication, security measures, direct marketing, reach measurement, office and organizational procedures, organizational and administrative procedures, feedback, marketing, profiles with user-related information, provision of our online offering and user-friendliness Information technology infrastructure, public relations,
sales promotion, 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 domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)
The data subject has given their consent to the processing of their personal data for one or more specific purposes.
Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 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 at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR)
Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany:
In addition to the data protection regulations of the GDPR, national data protection regulations 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). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.
Reference to validity of GDPR and Swiss FADP:
This data protection notice serves to provide information in accordance with both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data”, “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, securing availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is truncated (also known as “IP masking”). The last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or make it much more difficult to identify a person by their IP address.
Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. 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 stored 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 retention and deletion of data that applies specifically to certain processing operations.
If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive.
If a period does not expressly begin on a specific date and is at least one year, it shall automatically start at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the termination or other termination of the legal relationship takes effect.
We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.
Further information on processing operations, procedures and services:
Storage and deletion of data:
The following general time limits apply to storage and archiving in accordance with German law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet and the work instructions and other organizational documents required to understand them (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. Para. 3 AO, § 14b Para. 1 UStG, § 257 Para. 1 No. 1 i.V.m. para. 4 HGB).
- 8 years - Accounting documents, such as invoices and expense receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. para. 4 HGB).
- 6 years - Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents, insofar as they are relevant for taxation, e.g. time sheets, company accounting sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting documents and cash register slips (Section 147 (1) nos. 2, 3, 5 in conjunction with (3) AO). Para. 3 AO, § 257 Para. 1 No. 2 and 3 in conjunction with Para. para. 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on past business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Rights of the data subjects
Rights of data subjects under the GDPR:
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent:
You have the right to withdraw your consent at any time.
- Right of access:
You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data and further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the statutory provisions, 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 statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability:
You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to the supervisory authority:
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the 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”), in the context of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to inquiries.
We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. to involve 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 pass on the data of contractual partners to third parties to the extent that this is 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, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (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 legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
Processed data types:
- Inventory data (e.g. full name, residential address, contact information, customer number, etc.)
- payment data (e.g. bank details, invoices, payment history)
- Contact details (e.g. postal and e-mail addresses or telephone numbers)
- Contract data (e.g. subject matter of the contract, term, customer category)
Persons concerned:
- Beneficiaries and clients
- Interested parties
- Business and contractual partners
Purposes of the 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:
Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Business processes and procedures
Personal data of service recipients and clients - including customers, clients or, in special cases, clients, patients or business partners as well as other third parties - are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.
The data collected is used to fulfill contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organization of the company.
Personal data may be passed on to third parties if this is necessary to fulfill the stated purposes or legal obligations.
Processed data types:
- Inventory data (e.g. full name, home address, contact information, customer number)
- Payment data (e.g. bank details, invoices, payment history)
- Contact details (e.g. postal and e-mail addresses)
- Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship)
- 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, device types and operating systems used)
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers)
Persons concerned:
- Beneficiaries and clients
- Interested parties
- Communication partner
- Business and contractual partners
- Customers
Purposes of the processing:
- Provision of contractual services and fulfillment of contractual obligations
- Office and organizational procedures
- Business processes and business management procedures
- Security measures
- Provision of our online offer and user-friendliness
Storage and deletion:
Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases:
Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
Customer account:
Customers can create an account within our online offering (e.g. customer or user account, “customer account” for short). If the registration of a customer account is required, customers will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is stored for purposes other than provision in the customer account or must be stored for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer's responsibility to back up their data when the customer account is terminated.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms that are operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms to measure reach and for interest-based marketing.
Processed data types:
- Inventory data (e.g. full name, residential address, contact information, customer number, etc.)
- Payment data (e.g. bank details, invoices, payment history)
- Contact details (e.g. postal and e-mail addresses or telephone numbers)
- 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, device types and operating systems used, interactions with content and functions)
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved)
Persons concerned:
- Beneficiaries and clients
- Business and contractual partners
Purposes of the processing:
- Provision of contractual services and fulfillment of contractual obligations
- Marketing
- 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 bases:
Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Provision of the online offer and web hosting
We process users' 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.
Processed data types:
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions)
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved)
- Log data (e.g. log files relating to logins or the retrieval of data or access times)
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation)
Persons concerned: Users (e.g. website visitors, users of online services)
Purposes of the processing:
- Provision of our online offer and user-friendliness
- Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.))
- Security measures
- Provision of contractual services and fulfillment of contractual obligation
Storage and deletion:
Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Deletion of data:
Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Webflow, Inc.
Service provider: Webflow, Inc. 208 Utah, Suite 210, San Francisco, CA 94103, USA
Website: hhtps://webflow.com
Privacy policy: https://webflow.com/legal/eu-privacy-policy
For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Use of cookies
The term “cookies” refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user's consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving 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 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 duration:
A distinction is made between the following types of cookies with regard to the storage period:
- Temporary cookies (also: session cookies):
Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application). - Permanent cookies:
Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved 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. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that they may be stored for up to two years.
General information on revocation and objection (opt-out):
Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, including by means of their browser's privacy settings.
Processed data types:
Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons concerned: Users (e.g. website visitors, users of online services)
Legal bases:
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
Processing of cookie data on the basis of consent:
We use a consent management solution in which the user's consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned 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 queries and to be able to provide proof of consent in accordance with legal requirements. The 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 is available, 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 on the browser, system and end device used.
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)
Registration, login and user account
Users can create a user account. As part of the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular the login information (user name, password and an e-mail address).
As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as 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.
Processed data types:
- Inventory data (e.g. full name, residential address, contact information, customer number, etc.)
- Contact details (e.g. postal and e-mail addresses or telephone numbers)
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation)
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, 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)
Persons concerned: Users (e.g. website visitors, users of online services)
Purposes of the processing:
- provision of contractual services and fulfilment of contractual obligations
- security measures
- organizational and administrative 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 bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)
Further information on processing operations, procedures and services:
Two-factor authentication:
Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, you must perform another authentication measure in addition to your password (e.g. enter a code sent to a mobile device). We will inform you about the procedure we use.
Legal bases: Contract fulfillment and pre-contractual request (Art. 6 para. 1 sentence 1 lit. b) GDPR)
Deletion of data after termination:
If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation or consent of the users.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)
Contact and request management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.
Processed data types:
- Inventory data (e.g. full name, residential address, contact information, customer number, etc.)
- Contact details (e.g. postal and e-mail addresses or telephone numbers)
- Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation)
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions)
- Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved)
Persons concerned: Communication partner
Purposes of processing:
- communication
- organizational and administrative procedures
- feedback (e.g. collecting feedback via online form)
- 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”.
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
Contact form:
When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your options to object.
You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and process technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).
Notes on legal bases:
If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to Messenger for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time
Processed data types:
- Contact details (e.g. postal and e-mail addresses)
- Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship)
Persons concerned: Communication partner
Purposes of processing: Communication
Storage and deletion:
Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases:
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Chatbots und Chatfunktionen
We offer online chats and chatbot functions (collectively referred to as “chat services”) as a means of communication. A chat is an online conversation conducted with a certain degree of timeliness. A chatbot is software that answers users' questions or informs them about messages. If you use our chat functions, we may process your personal data.
If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.
We would like to point out to users that the respective platform provider may find out that and when users communicate with our chat services and may collect technical information about the user's device and, depending on the settings of their device, location information (so-called metadata) for the purpose of optimizing the respective services and for security purposes. The metadata of communication via chat services (i.e. e.g. information on who has communicated with whom) may also be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their provisions, to which we refer for further information.
If users declare their willingness to a chatbot to activate information with regular messages, they have the option to unsubscribe from the information for the future at any time. The chatbot informs users how and with which terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, user data is deleted from the list of message recipients.
We use the aforementioned information to operate our chat services, e.g. to address users personally, to answer their inquiries, to transmit any requested content and also to improve our chat services (e.g. to “teach” chatbots answers to frequently asked questions).
Processed data types:
- Contact data (e.g. postal and e-mail addresses)
- Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used)
- Data subject data (e.g. name, address, telephone number, e-mail address)
Persons concerned: Communication partner
Purposes of processing: Communication
Storage and deletion:
Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases:
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Push messages
With the user's consent, we can send users so-called “push notifications”. These are messages that are displayed on users' screens, end devices or browsers, even if our online service is not currently being actively used.
To register for the push messages, users must confirm the request from their browser or end device to receive the push messages. This consent process is documented and saved. The storage is necessary to recognize whether users have agreed to receive the push messages and to be able to prove their consent. For these purposes, a pseudonymous identifier of the browser (so-called “push token”) or the device ID of an end device is stored.
The push messages may be necessary for the fulfilment of contractual obligations (e.g. technical and organizational information relevant to the use of our online offer).
Processed data types:
- usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used)
- meta, communication and process data (e.g. IP addresses, time data, identification numbers, etc.)
Persons concerned: Communication partner
Purposes of processing: Communication. Provision of our online offer 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 bases:
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the users. To subscribe to our newsletter, it is normally sufficient to provide your e-mail 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 e-mail 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 a potential defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Contents: Information about us, our services, promotions and offers.
Processed data types:
- inventory data (e.g. full name, residential address, contact information, customer number, etc.)
- contact data (e.g. postal and e-mail addresses or telephone numbers)
- meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions)
Affected persons:
- communication partners
- users (e.g. website visitors, users of online services)
Purposes of processing: Direct marketing (e.g. by email or post). Provision of contractual services and fulfillment of contractual obligations.
Legal bases:
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Option to object (opt-out):
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Further information on processing operations, procedures and services:
Measurement of opening and click rates:
The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or its server, if we use a mailing service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates and the storage of the measurement results in the user profiles
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)
Prerequisite for the use of free services: Consent to the sending of mailings may be made a condition for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.
Sending via SMS: The electronic notifications can also be sent as SMS text messages (or are only sent via SMS if the sending authorization, e.g. consent, only includes sending via SMS).
Legal bases:
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Mailchimp: Email marketing, automation of marketing processes, collection. Storage and management of contact data, measurement of campaign performance, recording and analysis of recipients' interaction with content, personalization of content
Service provider:
Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Website: https://mailchimp.com
Privacy policy: https://mailchimp.com/legal
Basis for third country transfers: Data Privacy Framework (DPF)
Further information: Special safety measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to marketing communication at any time.
After revocation or objection, we store the data required to prove the previous authorization to contact or send up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
Processed data types:
- inventory data (e.g. full name, residential address, contact information, customer number, etc.)
- contact data (e.g. postal and e-mail addresses or telephone numbers)
- content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation)
Affected persons: Communication partner
Purposes of Processing:
- Direct marketing (e.g. by e-mail or postal)
- Marketing
- Sales promotion
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors 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, recognize at what time our online offer or its functions or content are most frequently used, or invite visitors to reuse them. It also enables us to understand which areas require optimization.
In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.
Unless otherwise stated 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 in a terminal device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.
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 user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, 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 services 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 stated, 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 bases: 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 operations, procedures 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 e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can 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 city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. 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, Irland
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. 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
Order processing contract: https://business.safety.google/adsprocessorterms/
Basis for third country transfers: Data Privacy Framework (DPF)
Possibility of objection (opt-out):
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)
Customer reviews and evaluation process
We participate in review and rating procedures in order to evaluate, optimize and advertise our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers' data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers
In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer's consent. This data is used solely to verify the authenticity of the user.
Processed data types:
- 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, device types and operating systems used, interactions with content and functions)
- meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved)
Persons affected: 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 bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Further information on processing operations, procedures and services:
Trustpilot: Rating platform Service provider: Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR
Website: https://de.trustpilot.com
Privacy policy: https://de.legal.trustpilot.com/for-reviewers/end-user-privacy-terms
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on the user's computer, in which the user's usage behavior and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the 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 opt-out options, 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 asserted most effectively 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.
Processed data types:
- contact data (e.g. postal and e-mail addresses or telephone numbers)
- content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation)
- usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, 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 work.
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 para. 1 sentence 1 lit. f) GDPR)
Further information on processing operations, procedures and services:
Facebook pages:
Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy:
https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: www.facebook.com/privacy/policy/) As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights”, to Page owners to help them understand how people interact with their Pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights”( https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA.
Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR
Website: https://www.facebook.com
Privacy policy: https://www.facebook.com/privacy/policy/
Basis for third country transfers: Data Privacy Framework (DPF)
LinkedIn:
Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors' data used to create the “page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn 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 regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of the data subjects (i.e. users can, for example, send 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. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The 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, Irland
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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)
Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
X: Social network
Service provider: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Website: https://x.com
Privacy policy: https://x.com/de/privacy
Plug-ins and embedded functions and content
We incorporate 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 uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, but may also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. 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 draw your attention to the information on the use of cookies in this privacy policy.
Processed data types:
- usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions)
- meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved)
- location data (information on the geographical position of a device or person)
Persons affected: Users (e.g. website visitors, users of online services)
Purposes of processing: Provision of our online offer 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 stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
Google Maps:
We integrate the maps of the “Google Maps” service provided by Google. The processed data may include, in particular, IP addresses and user location data.
Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Irland
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)
Website: https://mapsplatform.google.com/
Privacy policy: https://policies.google.com/privacy
Basis for third country transfers: Data Privacy Framework (DPF)