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Privacy Policy ​

Preamble ​

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement 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 services").

The terms used are not gender-specific.

Last Update: 22. October 2026

Legal text by Dr. Schwenke - please click for further information.

Table of contents ​

Controller ​

Fully Factory GmbH
Alexey Ozerov
Von-Witzleben-Str. 12
41540 Dormagen
Germany

Authorised Representatives: Alexey Ozerov, Rattana Nuon

E-mail address: info@fully-kiosk.com

Legal Notice: https://www.fully-kiosk.com/docs/en/legal/about

Overview of processing operations ​

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data ​

  • Inventory data.
  • Payment Data.
  • Location data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Images and/ or video recordings.
  • Audio recordings.
  • Log data.

Categories of Data Subjects ​

  • Service recipients and clients.
  • Prospective customers.
  • Communication partner.
  • Users.
  • Members.
  • Business and contractual partners.
  • Participants.
  • Persons depicted.
  • Third parties.
  • Customers.

Purposes of Processing ​

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Web Analytics.
  • Office and organisational procedures.
  • Remarketing.
  • Affiliate Tracking.
  • Organisational and Administrative Procedures.
  • Content Delivery Network (CDN).
  • Feedback.
  • Polls and Questionnaires.
  • Marketing.
  • Profiles with user-related information.
  • Authentication processes.
  • Provision of our online services and usability.
  • Information technology infrastructure.
  • Financial and Payment Management.
  • Public relations.
  • Sales promotion.
  • Business processes and management procedures.
  • Artificial Intelligence (AI).

Relevant legal bases ​

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - 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.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) - the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.

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

Relevant legal basis according to the Swiss Data Protection Act: We process your personal data in accordance with the Swiss Federal Act on Data Protection (“Swiss DPA”). Personal data must be processed lawfully, in good faith and proportionately (Art. 6 para. 1 and 2 Swiss DPA). It may only be collected for a specific purpose that is recognisable to the data subject and may only be processed in a manner compatible with that purpose (Art. 6 para. 3 FADP). Unlike the GDPR, the Swiss DPA does not generally require private controllers to base processing on a specific legal basis from a statutory list. Therefore, there is generally no obligation to state such a legal basis for each processing activity in the privacy policy.

Reference to the applicability of the GDPR and the Swiss DPA: This privacy policy is intended to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). Where references are made to concepts such as the processing of personal data, legitimate interests, or special categories of data, these references are to be understood in accordance with the applicable data protection laws. Within the scope of application of the Swiss FADP, the legal interpretation of these terms is determined exclusively by Swiss law.

Security Precautions ​

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

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information that is transferred between the website or app and the user's browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with 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 securely and encryptedly transmitted.

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 the disclosure or transfer of data to other individuals, entities, or companies (which becomes apparent either from the postal address of the respective provider or when explicitly mentioned in the privacy policy regarding data transfer to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by the EU Commission's adequacy decision of July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the EU Commission's requirements and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Contractual Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we will inform you whether they are certified under the DPF and if Standard Contractual Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce's website at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate safeguards apply, particularly Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.

Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss DPA). If the Federal Council has not determined an adequate level of protection (list of states: https://www.bj.admin.ch/de/schweizerische-anerkennung-von-staaten-die-einen-angemessenen-datenschutz-gewaehrleisten), we implement alternative security measures.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by Switzerland's adequacy decision of September 15, 2024. Additionally, we have concluded Standard Data Protection Clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Data Protection Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Data Protection Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we will inform you whether they are certified under the DPF and if Standard Data Protection Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce's website at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate safeguards apply, including international agreements, specific guarantees, FDPIC-approved Standard Data Protection Clauses, or internal company data protection regulations previously recognized by the FDPIC or a competent data protection authority of another country.

Under Art. 16 of the Swiss DPA, exceptions can be made for the disclosure of data abroad if certain conditions are met, including the consent of the affected person, contract execution, public interest, protection of life or physical integrity, publicly made data, or data from a legally provided register. Such disclosures always comply with the legal requirements.

We will inform you which of our service providers are certified under the Data Privacy Framework as part of our privacy notices.

General Information on Data Retention and Deletion ​

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or special interests require a longer retention 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 protection of the rights of other natural or legal persons, must be archived accordingly.

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

In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.

Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.

Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:

  • 10 Years - Fiscal Code/Commercial Code - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 8 years - Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB))
  • 6 Years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 3 Years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).

Data Retention and Deletion: The following general retention and archiving periods apply under Swiss law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
  • 10 years - Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries based on previous business experiences and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Articles 127, 130 OR). Claims for rent, lease, and interest on capital, as well as other periodic services, for the delivery of food, for board and lodging, for innkeeper debts, as well as for craftsmanship, small-scale sales of goods, medical care, professional services by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees, expire after five years (Article 128 OR).

Start of the period at the end of the year: If a period does not expressly start on a specific date and lasts at least one year, it automatically begins 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 time at which the termination or other termination of the legal relationship takes effect.

Rights of Data Subjects ​

Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data 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 data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. In particular, you may lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work or the place of the alleged infringement.

Rights of the data subjects under the Swiss DPA:

As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

  • Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.

Business services ​

We process personal data of our contractual and business partners, such as Customers, Clients, Prospective Customers, Suppliers and other cooperation partners (collectively referred to as "Contractual Partners"), for the initiation, execution and settlement of contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures carried out at the request of the parties and communication related to the respective contractual relationship.

Processing serves in particular to fulfil our primary and secondary contractual obligations. This includes providing the agreed services, any update and information obligations, handling warranty claims and other service disruptions, processing revocations, terminations of continuing obligations, reversals, refunds as well as handling other contract-related statements and enquiries. Both one-off contracts and ongoing contractual relationships are covered.

In particular, we process master data such as name, address and where applicable company name; contact details such as email address and telephone number; contract and service data such as subject matter of the contract, duration of the contract, order or transaction number; usage and performance data; payment and billing data; as well as communication content and histories. Where necessary, we also process data disclosed or transmitted to us in connection with carrying out an assignment.

Furthermore, we process the data to safeguard our rights and to comply with legal obligations. This particularly includes commercial law and tax law retention requirements, documentation obligations as well as possible duties of proof or accountability. Processing may also take place on the basis of our legitimate interests in proper business management, internal administration, risk control and IT security as well as in protecting our business operations and Contractual Partners against misuse or threats to data, secrets or other legal assets. This may include involving external Service Providers such as IT- and telecommunications providers, transport- or logistics companies, payment service providers, banks, tax advisors or legal advisors or other vicarious agents insofar as this is required for executing contracts or fulfilling legal obligations.

Personal data will only be passed on to third parties if this is necessary for fulfilling a contract or conducting pre-contractual measures; safeguarding legitimate interests; or complying with statutory obligations. We will inform you separately within this privacy policy about any further processing activities—particularly those undertaken for marketing purposes.

Which specific data is required in each case will be communicated to Contractual Partners during collection—for example by appropriate labelling in online forms or during personal contact.

Data will be deleted once it is no longer required for these purposes provided there are no statutory retention requirements preventing deletion. Statutory retention periods—particularly under commercial- or tax law—may require longer storage periods. Data transmitted in connection with a specific assignment will be deleted after completion of that assignment and expiration of any applicable retention period unless further statutory or contractual storage obligations exist.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Online shop, order forms, e-commerce and fulfilment of services: We process our customers' data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and provision, delivery, or execution. If necessary for the execution of an order, we employ service providers, particularly postal services, freight carriers, and shipping companies to carry out delivery or execution for our customers. For processing payment transactions, we use the services of banks and payment service providers. The necessary information is marked as such within the ordering or comparable acquisition process and includes the details required for delivery or provision and billing as well as contact information to facilitate any necessary consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

  • Provision of software and platforms: We process the data of our Customers and users (hereinafter collectively referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to develop it further. The required details are identified as such within the context of the conclusion of the agreement, order or comparable contract and include the details required for the provision of services and invoicing as well as contact information in order to be able to hold any further consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

  • Provision of mobile applications: We process the data of our Customers and users (hereinafter collectively referred to as "users") in order to provide them with our contractual services within the scope of the provision and operation of our mobile applications, as well as to ensure the security, availability, and further development of our online services. The required information is identified as such within the context of order placement, conclusion of a contract or similar agreements, and includes the details necessary for service provision and billing, as well as contact information in order to enable any necessary communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

  • Consulting: We process the data of our clients as well as prospects and other commissioning parties or contractual partners (collectively referred to as "clients") in order to be able to provide our services to them. The processes that are part of and for the purposes of consulting include: contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, capturing and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, invoicing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the nature, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship with the client.
    If it is necessary for our contract performance, for the protection of vital interests or legally required, or if there is consent from the clients, we disclose or transmit client data in compliance with professional legal requirements to third parties or agents such as authorities, subcontractors or in the field of IT, office or similar services; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

  • IT Services: We process the data of our clients as well as contractors to enable them to plan, implement, and support IT solutions and associated services. The required information is marked as such during the contract, project, or similar agreement phase and includes details necessary for service provision and billing, as well as contact information to facilitate any necessary consultations. Insofar as we gain access to information from end customers, employees, or other individuals, we process this in accordance with legal and contractual requirements.

    Processing processes include project management and documentation, which cover all phases from initial requirement analysis to project completion. This involves creating and managing project timelines, budgets, and resource allocations. Data processing also supports change management, where changes in the project flow are documented and tracked to ensure compliance and transparency.

    Another process is customer relationship management (CRM), which involves recording and analyzing customer interactions and feedback to improve service quality and efficiently address individual customer needs. Additionally, the processing process encompasses technical support and trouble-shooting, which includes capturing and handling support requests, error resolutions, and regular maintenance.

    Furthermore, reporting and performance analysis are conducted by capturing and evaluating performance metrics to assess the effectiveness of provided IT solutions continuously optimizing them. All these processes are aimed at ensuring high customer satisfaction and compliance with all relevant regulations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Business processes and operations ​

Personal data of service recipients and clients - including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties - are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Data subjects: Service recipients and clients; Customers; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Third parties. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Security measures; Provision of our online services and usability; Communication; Marketing; Sales promotion; Public relations; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Further information on processing methods, procedures and services used:

  • Customer Management and Customer Relationship Management (CRM): Processes required in the context of customer management and Customer Relationship Management (CRM) include customer acquisition in compliance with data protection regulations, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, management of CRM systems, secure account management, customer segmentation and targeting; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Customer Account: Customers can create an account within our online offer (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 as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent registration and use of the customer account, we store the IP addresses of the contractual partners along with the access times, in order to be able to prove the 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 retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the customers' responsibility to back up their data when terminating the customer Account; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Sales: Procedures required for the planning, implementation, and control of measures for marketing and selling products or services (e.g., customer acquisition, preparation and tracking of offers, order processing, customer consultation and support, sales promotion, product training, sales controlling and analysis, management of distribution channels); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Use of online platforms for listing and sales purposes ​

We offer our services on online platforms operated by other service providers. In addition to our privacy policy, the privacy policies of the respective platforms apply. This is particularly true with regard to the payment process and the methods used on the platforms for performance measuring and behaviour-related marketing.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Marketing. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Providers and services used in the course of business ​

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, "services") in compliance with legal requirements. Their use is based on our interests in the proper, legal and economic management of our business operations and internal organization.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Members.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Payment Procedure ​

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively referred to as "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, ensuring that the data entered is protected from unauthorized access during transmission.

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.

The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Contact data (e.g. postal and email addresses or phone numbers).
  • Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Business processes and management procedures. Office and organisational procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Pay: Payment services provider; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://pay.google.com/intl/en_uk/about/. Privacy Policy: https://business.safety.google/privacy/.
  • Mastercard: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.mastercard.co.uk. Privacy Policy: https://www.mastercard.co.uk/en-gb/vision/terms-of-use/commitment-to-privacy/privacy.html.
  • PayPal: Payment-Service-Provider (technical integration of online-payment-methods) (e.g. PayPal, PayPal Plus, Braintree, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.paypal.com. Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
  • Stripe: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://stripe.com/de; Privacy Policy: https://stripe.com/en-de/privacy. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
  • Visa: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Visa Europe Services Inc., Zweigniederlassung London, 1 Sheldon Square, London W2 6TT, UK; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.com/en-us/legal/global-privacy-notice.
  • Paddle: A sales and billing platform that acts as Merchant of Record (contractual partner and reseller of digital products to end customers) and assumes responsibility for sales, payment processing, subscriptions, as well as tax obligations. Contact data, payment information, device information, and usage data are processed for the purposes of order management, invoicing, fraud prevention, and customer support. Data processing also takes place in the United Kingdom, which has been recognised by the European Commission as a secure third country through an adequacy decision. In cases where data is transferred to non-adequate third countries, Standard Contractual Clauses (model contractual clauses approved by the European Commission) are used; Service provider: Paddle.com Market Limited, Judd House, 18-29 Mora Street, London EC1V 8BT, United Kingdom; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.paddle.com/; Privacy Policy: https://www.paddle.com/legal/privacy; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA - Standard Contractual Clauses (Provided by the service provider), Switzerland - Standard Contractual Clauses (Provided by the service provider).

Provision of online services and web hosting ​

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

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)); Security measures. Content Delivery Network (CDN).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

  • Provision of online services on own/ dedicated server hardware: For the provision of our online services, we use server hardware operated by us as well as, the storage space, computing capacity and software associated with it; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

  • Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically 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 abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

  • Content-Delivery-Network: We use a so-called "Content Delivery Network" (CDN). A CDN is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

  • Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://docs.hetzner.com/general/company-and-policy/data-protection-at-hetzner. Data Processing Agreement: https://docs.hetzner.com/general/company-and-policy/data-protection-at-hetzner.

  • Cloudflare CDN: A service for the provision and securing of web content, through which operators can deliver their content via a globally distributed network (Content Delivery Network). For this purpose, Customers redirect web requests to Cloudflare so that websites, web resources (e.g. files), and network functions are processed or provided on behalf of the operator. In this context, in particular IP addresses, timestamps of access, URL/resource information, device or browser information as well as log data and other technical metadata may be processed insofar as they are required for delivery, error diagnosis, security and abuse detection. Depending on the configuration, configuration and status data for security functions (e.g. access and protection rules) may also be included. Use typically takes place by configuring DNS or web server integrations of the operator so that Cloudflare acts as an intermediary between end users and origin server.

    Securing of web content, through which operators can deliver their content via a globally distributed network (Content Delivery Network). For this purpose, Customers redirect web requests to Cloudflare so that websites, web resources (e.g. files), and network functions are processed or provided on behalf of the operator. In this context, in particular IP addresses, timestamps of access, URL/resource information, device or browser information as well as log data and other technical metadata may be processed insofar as they are required for delivery, error diagnosis, security and abuse detection. Depending on the configuration, configuration and status data for security functions (e.g. access and protection rules) may also be included. Use typically takes place by configuring DNS or web server integrations of the operator so that Cloudflare acts as an intermediary between end users and origin server; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.cloudflare.com; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/).

  • INWX: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: INWX GmbH, Prinzessinnenstr. 30, 10969 Berlin, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.inwx.de/en. Privacy Policy: https://www.inwx.de/en/aboutus/dataprotection.

  • Serverprofis GmbH: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Serverprofis GmbH, Mondstr. 2-4, 85622 Feldkirchen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.serverprofis.de/; Privacy Policy: https://www.serverprofis.de/datenschutz/. Data Processing Agreement: Provided by the service provider.

Use of Cookies ​

The term "cookies" refers to functions that store information on users' devices and read it from them. Cookies can also be used for different purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users' consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.

Information on legal data protection bases: Whether we process personal data using cookies depends on users' consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as outlined in this section and in the context of the respective services and procedures.

Storage duration: The following types of cookies are distinguished based on their storage duration:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user revisits a website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that these are permanent and may have a storage duration of up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to the processing according to legal regulations, including through the privacy settings of their browser.

Cookie Settings/ Opt-Out:

Cookies

  • Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and usability.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users' consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users' devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • Cookie-Opt-Out: In the footer of our website you will find a link that allows you to change your cookie settings as well as revoke corresponding consents.

Processing of data in the context of applications (apps) ​

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

Information on the functions of the application:

All Fully Kiosk apps do not track users. No information about Fully Kiosk apps usage including their local Remote Admin web interface is transmitted to or stored on our servers or third party servers.

The Accessibility Service is used solely to maintain kiosk mode by restricting access to system UI elements such as the notification panel and certain system dialogs. The service does not collect, store, transmit, or analyze accessibility event data or personal information.

If you are using the PLUS features the app checks periodically the PLUS license validity if the Internet connection is available. The anonymous device ID will be sent via HTTPS to our licensing servers for this purpose.

If you order a PLUS License the device ID, the payment transaction details, your name, address and email will be stored in order to enable authentication in case of license relocation.

If you are using our Fully Cloud service your device will frequently send all information available on the Fully Remote Admin interface (including the device location if enabled) to Fully Cloud server via HTTPS. The latest information will be saved for the quick view in the Fully Cloud account. No history data (except Fully Log) will be saved on our cloud servers. Fully Cloud is hosted at Hetzner Online (ISO/IEC 27001 certified hosting) in Germany.

In case of application crash or ANR the anonymous information about your device type, Android version, Fully version, its major settings, logcat and exception stack will be sent to our servers via HTTPS in order to support investigation and fixing that bug.

If you save your configuration with Fully Exam Configurator the exam name, URL and encrypted configuration will be saved on our servers for 12 months in order to provide the permalinks.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings. Location data (Information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Commercial use: We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to develop it further. The required details are identified as such within the scope of the conclusion of a contract for the use of the application, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Storage of the universally unique identifier (UUID): The application stores a so-called Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality of the application and storing the user's settings. This identifier is generated when the application is installed (but is not connected to the device, so no device ID in this sense), remains stored between the start of the application and its updates and is deleted when users remove the application from their device.
  • Storage of an own unique identifier: In order to provide the application and ensure its functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no clear data such as names are used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated during the installation of the application, remains stored between the start of the application and its updates and is deleted when users remove the application from the device.
  • Device authorizations for access to functions and data: The use of certain functions of our application may require access to the camera and the stored recordings of the users. By default, these authorizations must be granted by the user and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorizations can affect the functionality of our application.
  • Accessing the camera and stored recordings: In the course of using our application, image and/or video recordings (whereby audio recordings are also included) of the users (and of other persons captured by the recordings) are processed by accessing the camera functions or stored recordings. Access to the camera functions or stored recordings requires an authorization by the user that can be withdrawn at any time. The processing of the image and/or video recordings serves only to provide the respective functionality of our application, according to its description to the users or the typical and expectable functionality of the application.
  • Use of the microphone functions: The use of certain functions of our application may require access to the camera and the stored recordings of the users. By default, these authorizations must be granted by the user and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorizations can affect the functionality of our application.
  • Processing of location data: Within the course of using our application, the location data collected by the device used or otherwise entered by the user are processed. The use of the location data requires an authorization of the users, which can be revoked at any time. The use of the location data serves only to provide the respective functionality of our application, according to its description to the users or its typical and expectable functionality.
  • Location history and movement profiles: The location data is only used selectively and is not processed to create a location history or a movement profile of the devices used or of their users.

Purchase of applications via Appstores ​

The purchase of our apps is done via special online platforms operated by other service providers (so-called "appstores"). In this context, the data protection notices of the respective appstores apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for webanalytics and for interest-related marketing as well as possible costs.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Registration, Login and User Account ​

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).

Within the scope of using our registration and login functions as well as 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 the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users may be informed by e-mail of information relevant to their user account, such as technical changes.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Users' profiles are public: The users' profiles are not publicly visible or accessible.
  • Two-factor Authentication: Two-factor authentication provides an extra 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, in addition to your password, you must perform another authentication measure (e.g. enter a code sent to a mobile device - we will inform you about the procedure we use); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (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 any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • No obligation to retain data: It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Single Sign-on Authentication ​

Single Sign-On" or "Single Sign-On Authentication or Logon" are procedures that allow users to log in to our online services using a user account with a provider of Single Sign-On services (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 the button.

Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in with the respective single sign-on provider under this user ID and an ID that cannot be used for other purposes (so-called "user handle"). Whether we receive further data depends solely on the single sign-on procedure used, the data releases selected as part of authentication and also which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, there can be different data, usually the e-mail address and the user name. The password entered by the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are requested to note that their data stored with us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actual. If, for example, the e-mail addresses of users change, users must change these manually in their user account with us.

We can use single sign-on authentication, provided that it has been agreed with users in the context of pre-fulfillment or fulfilment of the contract, in the context of consent processing and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure authentication system.

Should users decide to no longer want to use the link of 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 provider. If users wish to delete their data from us, they must cancel their registration with us.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Authentication processes. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Single-Sign-On: Authentication services for user logins, provision of single sign-on functionalities, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.google.com; Privacy Policy: https://business.safety.google/privacy/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF). Opt-Out: Settings for the Display of Advertisements: https://myadcenter.google.com/.

Contact and Inquiry Management ​

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

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Communication via Messenger ​

We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.

You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.

In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed.

However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner's device used and, depending on the settings of their device, also location information (so-called metadata).

Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process 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 for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.

Reservation of reference to other means of communication: For your security, we kindly ask for your understanding that we may not respond to enquiries via messenger for specific reasons. This applies in situations where contract details require heightened confidentiality or a response via messenger does not meet formal requirements. In such cases, we recommend using more appropriate communication channels.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Communication. Direct marketing (e.g. by e-mail or postal).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Telegram: A cloud-based messaging service that enables the sending and receiving of text messages, voice messages, images, videos, files, and voice calls. Telegram stores chats, media, and contacts encrypted on servers to allow cross-platform access. Individual chats can optionally be protected by end-to-end encryption; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://telegram.org/. Privacy Policy: https://telegram.org/privacy.
  • WhatsApp: A communication service that enables the sending and receiving of text messages, voice messages, images, videos, documents, as well as voice and video calls over the internet. Communication is conducted through end-to-end encryption, ensuring that content is accessible only to the involved communication partners. To provide the service, the platform processes metadata (e.g., phone numbers, timestamps, device information) and may use this data for functionality enhancement, security, and service optimisation; Service provider: WhatsApp Ireland Limited, Merrion Road 4, D04 X2K5 Dublin, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.whatsapp.com/. Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea.

Chatbots and chat functions ​

We provide online chats and chatbot functions as a means of communication (together referred to as "Chat Services"). A chat is an online conversation that is conducted with a certain degree of immediacy. 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 is also 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 inform users that the respective platform provider can find out that and when users communicate with our Chat Services and can collect technical information about the user's device used and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of communication via Chat Services (i.e., information about who has communicated with whom) could be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their regulations, to which we refer for further information.

If users agree to activate information with regular messages to a chatbot, they have the possibility to unsubscribe from the information for the future at any time. The chatbot points out to users how and with which terms they can unsubscribe the messages. By unsubscribing from the chatbot messages, Users' data is deleted from the directory 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 or to identify unanswered inquiries).

Information on Legal basis: We use the Chat Services on the basis of a consent if we first obtain the permission of the users to process their data by the Chat Services (this applies in cases where users are asked for consent, e.g. so that a chatbot regularly sends them messages). If we use Chat Services to answer user queries about our services or our company, this is done for contractual and pre-contractual communication. In addition, we use Chat Services based on our legitimate interests in optimizing the Chat Services, its operating efficiency and enhancing the positive user experience.

Withdrawal, objection and deletion: You can revoke a given consent at any time or contradict the processing of your data in the context of our chatbot use.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Communication.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Push notifications ​

With the consent of the users, we can send the users so-called "push notifications". These are messages that are displayed on users' screens, devices or browsers, even if our online services are not being actively used.

In order to sign up for push messages, users must confirm that their browser or device has requested to receive push messages. This approval process is documented and stored. The storage is necessary to recognize whether users have consented 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 a terminal device is stored.

The push messages may be necessary for the fulfilment of contractual obligations (e.g. technical and organisational information relevant for the use of our online offer) and will otherwise be sent, unless specifically mentioned below, on the basis of user consent. Users can change the receipt of push messages at any time using the notification settings of their respective browsers or end devices.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Communication. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Artificial Intelligence (AI) ​

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term "AI system" as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.

To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services). Third parties.
  • Purposes of processing and legitimate interests: Artificial Intelligence (AI).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Video Conferences, Online Meetings, Webinars and Screen-Sharing ​

We use platforms and applications of other providers (hereinafter referred to as "Conference Platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "Conference"). When using the Conference Platforms and their services, we comply with the legal requirements.

Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific Conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants' end devices, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the Conference Platforms, then further data may be processed in accordance with the agreement with the respective Conference Provider.

Logging and recording: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are recorded, this will be transparently communicated to the participants in advance and they will be asked - if necessary - for their consent.

Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.

Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users' data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Images and/ or video recordings (e.g. photographs or video recordings of a person); Audio recordings; Log data (e.g. log files concerning logins or data retrieval or access times.); Contract data (e.g. contract object, duration, customer category). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Persons depicted; Service recipients and clients; Prospective customers. Participants.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organisational procedures. Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Cloud Services ​

We use Internet-accessible software services (so-called "cloud services", also referred to as "Software as a Service") provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users' devices for web analysis or to remember user settings (e.g. in the case of media control).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Office and organisational procedures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Surveys and Questionnaires ​

We conduct surveys and interviews to gather information for the survey purpose communicated in each case. The surveys and questionnaires ("surveys") carried out by us are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address to display the survey in the user's browser or to enable a resumption of the survey with the aid of a cookie).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Participants.
  • Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Polls and Questionnaires (e.g. surveys with input options, multiple choice questions).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Web Analysis, Monitoring and Optimization ​

Web analytics (also referred to as "reach measurement") is used to evaluate the visitor flows of our online services and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age or gender. Through reach analysis, we can, for example, identify when our online services or their functions and content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas need optimization.

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

Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these purposes, and information can be stored in and later retrieved from a browser or device. The data collected includes, in particular, visited websites and elements used on them, as well as technical information such as the browser used, the computer system, and information about usage times. If users have given consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

Additionally, users' IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the respective procedures.

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

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Remarketing; Affiliate Tracking; Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention 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 Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Analytics: We use Google Analytics to perform measurement and analysis of the use of our online services by users based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers.
    In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses. Analytics does provide coarse geo-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-based traffic, IP-address data is used solely for geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers before forwarding traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP Masking (Pseudonymization of the IP address); Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms); Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, 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 Signals (Google Analytics function): Google signals are session data from sites and apps that Google associates with users who have signed in to their Google accounts, and who have turned on Ads Personalization. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion export to Ads. These are the areas where more information is gathered when Google Signals is activated (but only for users with Ads Personalization enabled): Cross Platform reporting - Connection of data about devices and activities from different sessions using your User-ID or Google-signals data providing an understanding of user behavior at each step of the conversion process, from initial contact to conversion and beyond; Remarketing with Google Analytics - Creation of remarketing audiences from Google Analytics data, and sharing of those audiences with linked advertising accounts; Demographics & Interests: Google Analytics collects additional information about demographics and interests from users who are signed in to their Google accounts and who have turned on Ads Personalization; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://support.google.com/analytics/answer/7532985?hl=en; Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms). Further Information: https://business.safety.google/adsservices/ (Types of processing and data processed).
  • Google Analytics Audiences: We use Google Analytics to specifically present ads, placed through Google's advertising services and those of its partners, to users who have already shown interest in our online offering or exhibit certain characteristics (e.g., interests in specific topics or products determined based on the websites they have visited). We transmit this data to Google as part of what is known as "Remarketing" or "Google Analytics Audiences". The purpose of using Remarketing Audiences is to ensure that our ads align as closely as possible with the potential interests of the users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Legal Basis: https://business.safety.google/adsprocessorterms/; Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF); Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Data Processing Conditions for Google Advertising Products and standard contractual clauses for data transfers to third countries: https://business.safety.google/adsprocessorterms .
  • Google Tag Manager: We use Google Tag Manager, a software provided by Google, which enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that serve to record and analyse visitor activities. This technology assists us in improving our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies with user profiles, or perform any independent analyses. Its function is limited to simplifying and making the integration and management of tools and services we use on our website more efficient. Nevertheless, when using Google Tag Manager, users' IP addresses are transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in this process. However, this data processing only occurs if services are integrated via the Tag Manager. For more detailed information about these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement: https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms).

Customer Reviews and Ratings ​

We participate in review and rating procedures to evaluate, optimise and advertise our performance. If users rate us via the participating rating platforms or methods or otherwise provide feedback, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective provider.

In order to ensure that the evaluators have actually made use of our services, we transmit, with the consent of the customer, the necessary data relating to the customer and the service or products used to the respective rating platform (this includes the name, e-mail address, order number or article number). This data is used solely to verify the authenticity of the user.

  • Processed data types: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online form). Marketing.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Rating Widget: We include so-called " rating widgets " in our online services. A widget is a functional and content element integrated within our online services that displays variable information (e.g. a widget can be displayed in the form of a seal or a badge). Although the corresponding content of the widget is displayed within our online services, it is retrieved from the servers of the respective widget provider at this moment. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online service to the widget provider's server and the widget provider receives certain technical data (access data, including the IP address) that is necessary for the content of the widget to be delivered to the user's browser.
    In addition, the widget provider receives information that users have visited our online services. This information may be stored in a cookie and used by the widget provider to identify 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 purposes; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Profiles 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 entail risks for users, e.g. by making it more difficult to enforce users' rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Facebook Pages: Profiles within the social network Facebook - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page ("Fanpage"). This includes, in particular, information about user behaviour (e.g., viewed or interacted content, actions taken) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations through the "Page Insights" service that give insights into how people interact with our page and its content. The basis for this is an agreement with Facebook ("Information about Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates security measures and the exercise of data subjects' 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 (particularly access, deletion, objection, complaint to a supervisory authority) remain unaffected by this. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited alone is responsible for further processing, including any possible transmission to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://business.safety.google/privacy/; Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF). Opt-Out: https://myadcenter.google.com/personalizationoff.

Plugins and embedded functions and content ​

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

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Location data (Information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and usability; Provision of contractual services and fulfillment of contractual obligations. Security measures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention 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 Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Integration of third-party software, scripts or frameworks: We incorporate into our online services software which we retrieve from servers of other providers (e.g. function libraries which we use for the purpose of displaying or user-friendliness of our online services). The respective providers collect the user's IP address and can process it for the purposes of transferring the software to the user's browser as well as for security purposes and for the evaluation and optimisation of their services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Google Fonts (Provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Font Awesome (Provision on own server): Display of fonts and symbols; Service provider: The Font Awesome icons are hosted on our server, no data is transmitted to the provider of Font Awesome; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Google Maps: We integrate the maps of the service "Google Maps" from the provider Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://business.safety.google/privacy/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
  • Google Maps APIs and SDKs: Interfaces to the map and location services provided by Google, which, for example, allow the addition of address entries, location determinations, distance calculations or the provision of supplementary information on locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://business.safety.google/privacy/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
  • reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically operating machines (so-called "bots"). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our legitimate interest to protect our online services from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://cloud.google.com/security/products/recaptcha; Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/sccs/eu-c2p), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/sccs/eu-c2p).
  • hCaptcha: CAPTCHA service that is used to verify whether the data entered within our online services (e.g., on a login page or contact form) was entered by a human or an automated program. To this end, the service analyzes the behavior of the users of our online services based on various characteristics. This analysis starts automatically as soon as a user uses our online services. Various pieces of information are evaluated for the analysis (IP address, the visitor's dwell time on the website or app, or mouse movements of the user, as well as technical information about the device and browser used by the user); Service provider: Intuition Machines, Inc. 350 Alabama St, San Francisco, CA 94110, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.hcaptcha.com/; Privacy Policy: https://www.hcaptcha.com/privacy; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA - Standard Contractual Clauses (Provided by the service provider), Switzerland - Standard Contractual Clauses (Provided by the service provider).

Management, Organization and Utilities ​

We use services, platforms and software from other providers (hereinafter referred to as " third-party providers") for the purposes of organizing, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.

Within this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). Business and contractual partners.
  • Purposes of processing and legitimate interests: Communication; Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Security measures; Provision of our online services and usability. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • AI software (on own server): Use of "artificial intelligence" in the applicable legal sense of the term, i.e., software that is primarily based on specific logic and is essentially autonomous in its ability to understand and produce natural language or other input, output, and data, analyze information, and make predictions; Service provider: Executed on servers and/or computers under our controllership; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • WeTransfer: Transferring files over the Internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://wetransfer.com. Privacy Policy: https://wetransfer.com/explore/legal/privacy.
  • GitLab: GitLab provides a comprehensive solution for software development with features such as repository management to centrally store and version code. Continuous Integration/Continuous Deployment (CI/CD) automates the processes of testing and deploying code. With code review and collaboration, teams can review changes and work efficiently on the source code. Issue tracking enables the management of tasks and bugs. Additionally, GitLab offers project management tools for planning and organising projects. Security and compliance features ensure the protection of the code, while monitoring and error tracking support supervision and rapid problem detection; Service provider: GitLab B.V., Eduard van Beinumstraat 28, 1077 CZ Amsterdam, Netherlands; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://about.gitlab.com/; Privacy Policy: https://about.gitlab.com/privacy/; Data Processing Agreement: https://handbook.gitlab.com/handbook/legal/data-processing-agreement/ Provided by the service provider. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://handbook.gitlab.com/handbook/legal/data-processing-agreement/), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://handbook.gitlab.com/handbook/legal/data-processing-agreement/).
  • GitHub: Platform for version control of software projects. Developers are enabled to upload their code to repositories and track changes, as well as use tools for project management in software development; Service provider: GitHub B.V., Netherlands, https://support.github.com/contact/privacy; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://github.com. Privacy Policy: https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement.

Changes and Updates ​

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices 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 of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Terminology and Definitions ​

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • Affiliate Tracking: Custom Audiences refers to the process of determining target groups for advertising purposes, e.g. the display of advertisements. For example, a user's interest in certain products or topics on the Internet may be used to conclude that the user is interested in advertisements for similar products or the online store in which the user viewed the products. "Lookalike Audiences" is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences, cookies and web beacons are typically used.
  • Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users' consent or based on legal authorisation grounds.
  • Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
  • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
  • Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
  • Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
  • Controller: "Controller" means 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.
  • Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
  • Location data: Location data is created when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
  • Meta, communication and process 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, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
  • Payment Data: Payment data comprise all information necessary for processing 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 account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
  • Personal Data: "personal data" means any information relating to an identified or identifiable natural person ("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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Remarketing: Remarketing" or "retargeting" is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors.