Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

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The terms used are not gender-specific.

Status: 02 December 2024

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Table of contents

• Preamble
• Person responsible
• Overview of processing
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• General information on data storage and deletion
• Rights of the data subjects
• Business services
• Business processes and procedures
• Providers and services used in the course of business     activities
• Credit assessment
• Provision of the online offer and web hosting
• Use of cookies
• Special notes on applications (apps)
• Blogs and publication media
• Contact and enquiry management
• Video conferences, online meetings, webinars and screen sharing
• Cloud services
• Web analysis, monitoring and optimisation
• Customer reviews and evaluation process
• Presence in social networks (social media)
• Plug-ins and embedded functions and content
• Management, organisation and support tools
• Processing of data in the context of employment relationships
• Change and update
• Definitions of terms

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Person responsible

Caplign Wealth GmbH

Freiligrathstraße 16

65812 Bad Soden am Taunus

Persons authorised to represent the company: Christian Hille

E-mail address: info@caplign-wealth.com

Imprint: https://www.caplign-wealth.com/de/legal/impressum

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Overview of processing

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

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Types of data processed

• Inventory data
• Employee data
• Payment data
• Location data
• Contact details
• Content data
• Contract data
• Usage data
• Meta, communication and process data
• Social data
• Image and/or video recordings
• Protocol data
• Performance and behaviour data
• Creditworthiness data
• Salary data

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Categories of affected persons

• Beneficiary and client
• Employees
• Interested parties
• Communication partner
• Users
• Business and contractual partners
• People depicted
• Third parties
• Customers

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Purposes of the processing

• Provision of contractual services and fulfilment of contractual     obligations
• Communication
• Safety measures
• Reach measurement
• Office and organisational procedures
• Organisational and administrative procedures
• Feedback
• Marketing
• Profiles with user-related information
• Provision of our online services and user-friendliness
• Assessment of creditworthiness and credit standing
• Establishment and implementation of employment relationships
• Information technology infrastructure
• Financial and payment management
• Public relations
• Sales promotion
• Business processes and business management procedures

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Automated decisions in individual cases

• Credit report

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Relevant legal bases

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Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of     their personal data for one or more specific purposes.
• Contract fulfilment and pre-contractual enquiries (Art. 6 para.   1 sentence 1 lit. b) GDPR) - Processing is   necessary for the performance of a contract to which the data subject is     party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal   obligation to which the controller is subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate  interests pursued by the controller or by a third party, except where such  interests are overridden by the interests or fundamental rights and  freedoms of the data subject which require protection of personal data.
• Processing of special categories of personal data relating to  health care, employment and social security (Art. 9 para. 2 lit. h) GDPR) - Processing is necessary for the purposes of preventive or   occupational medicine, for the assessment of an employee's fitness for work, for medical diagnosis, the provision of health or social care or  treatment, or for the management of health or social care systems and services on the basis of Union or Member State law or on the basis of a  contract with a health professional.

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National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany.These include, in particular, the Act on the Protection against Misuse ofPersonal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.
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Relevant legal bases according to the Swiss Data Protection Act: If you are located inSwitzerland, we process your data on the basis of the Federal Act on DataProtection ("Swiss FADP" for short). Unlike the GDPR, for example, the Swiss FADP does not generally require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully and proportionately (Art. 6 para. 1 and 2of the Swiss FADP). In addition, personal data is only obtained by us for a specific purpose recognisable to the data subject and only processed in a way that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).
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Note on the applicability of the GDPRand Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss FADP and the GeneralData Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing"of "personal data", "overriding interest" and"sensitive personal data" used in the Swiss DPA, the terms"processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

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Security measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

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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 the access, input, disclosure, safeguarding of availability and its separation.Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats.Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. SecureSockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signal led by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

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Transmission of personal data

As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

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Data transfer within the organisation: We may transfer personal data to other departments or units within our organisation or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual obligations or if the consent of the data subjects or a legal permission exists.

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International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), theEuropean Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred ifthe level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent orin the case of contractual or legally required transfer (Art. 49 para. 1 GDPR).In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.As part of the so-called "Data Privacy Framework" (DPF), the EUCommission has also recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10 July2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

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Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list:  //www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and InformationCommissioner (FDPIC) or internal company data protection regulations recognised in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss DPA, exceptions for the disclosure of data abroad may be authorised if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements. As part of the so-called "Data PrivacyFramework" (DPF), the Swiss have recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 7 June 2024. The list of certified companies and further information on theDPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

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General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

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

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Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive.

If a period does not expressly begin on a specific date and is at least one year, it shall automatically start at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the cancellation or other termination of the legal relationship takes effect.

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We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.

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Further information on processing operations, procedures and services:

• Retention and deletion of data: The  following general time limits apply to storage and archiving in accordance  with German law:
   
  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organisational   documents, accounting documents and invoices required for their understanding (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a   AO, § 14b para. 1 UStG, § 257  para. 1 no. 1 and 4, para. 4 HGB).
   
  • 6 years - Other business documents: commercial or business      letters received, reproductions of commercial or business letters sent,   other documents insofar as they are of significance for taxation, e.g.   Hourly wage slips, company accounting sheets, calculation documents, price labelling, but also payroll accounting documents, insofar as they   are not already accounting documents and cash register slips (§ 147 para.      3 in conjunction with para. 1 no. 2, 3, 5 AO, § 257 para. 1 no. 2 and 3, para. 4 HGB).
   
  • 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to  process related enquiries based on past business experience and standard  industry practice will be stored for the duration of the regular      statutory limitation period of three years (Sections 195, 199 BGB).

• Retention and deletion of data: The  following general time limits apply to storage and archiving in accordance with Swiss law:
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  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance  sheets, accounting vouchers and invoices as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
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  • 10 years - Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as   for the processing of related requests based on past business experience and standard 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 (Art. 127, 130 CO). Claims for rent, lease and capital interest as well as other periodic services,  from the supply of food, for catering and for debts to landlords, as well  as from handicraft work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries and from the employment relationship of employees expire after five years (Art. 128  CO).

Rights of the data subjects

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

• Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data and further     information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right     to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
• Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
• Complaint to a supervisory authority: In accordance with the statutory provisions and without     prejudice to any other administrative or judicial remedy, you also have     the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place     of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR

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Rights of data subjects under the SwissDPA:

As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:

• Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to     assert your rights under this law and to ensure transparent data processing.
• Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
• Right to rectification: You have the right to request the rectification of inaccurate personal data     concerning you.
• Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

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Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships and related measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to enquiries.

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

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

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
• Persons affected: Service recipients and clients; interested parties. Business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and     administrative procedures. Business processes and business management     procedures.
• Storage and deletion: Deletion in     accordance with the information in the section "General information     on data storage and deletion".
• Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Further information on processing operations, procedures and services:

• Consulting: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly 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, collecting and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials,  billing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
     
  If it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client's data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Financial services: We process the  data of our customers in order to provide them with advice, brokerage and  the conclusion of financial transactions and related services. The required information is labelled as such in the context of the advisory, brokerage or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from customers or other persons, we process this in accordance with the legal and contractual requirements; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 Para.   1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR),  Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
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Business processes and procedures

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

The data collected is used to fulfil contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organisation of the company.

Personal data may be passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); log data (e.g. log files relating to logins or retrieval of data or access times); creditworthiness data (e.g. credit score received, estimated probability of default, risk rating based on this, access times). log files relating to logins or the retrieval of data or access times); creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behaviour); employee data (information on employees and other persons in an employment relationship); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties. Customers.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and business management procedures; communication; assessment of creditworthiness and credit     standing; financial and payment management; marketing. Sales promotion.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR);     Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

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Further information on processing operations, procedures and services:

• Customermanagement and customer relationship management, Client onboarding (CRM):
  Procedures required in the context of customer management and     customer relationship management (CRM) (e.g. Customer acquisition in     compliance with data protection regulations, measures to promote customer     loyalty and retention, effective customer communication, complaint     management and customer service with consideration of data protection,     data management and analysis to support the customer relationship,     administration of CRM systems, secure account management, customer     segmentation and target group formation); Legal bases: Contract     fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit.     b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

• Contact management and maintenance: Procedures required to organise, maintain and secure contact     information (e.g. setting up and maintaining a central contact database,     regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly reviewing     communication history and adapting contact strategies); Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Bookkeeping, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. Creation and checking of incoming and outgoing invoices,     monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art.     6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Sales: Procedures required for the planning, implementation and control of measures for the marketing and sale of products or services (e.g. customer acquisition, preparation and     tracking of offers, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Providers and services used in the course of business activities

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

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on     authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
• Persons concerned: Service recipients and clients; interested parties; business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other     employees).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures. Business processes and business management procedures.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Further information on processing operations, procedures and services:

• DATEV: Software for accounting, communication with tax advisors and authorities and with document storage; Service provider: DATEV eG, Paumgartnerstr. 6 - 14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/ ; Privacy Policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/ ; Data processing agreement: Provided by the service provider. Basis for third country transfers: Switzerland - adequacy decision (Germany).

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Credit assessment

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialised service companies (credit agencies) in order to safeguard our legitimate interests.  

We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

In accordance with the legal requirements, the decision as to whether we make advance payments is made solely on the basis of an automated decision in the individual case, which our software makes on the basis of the information provided by the credit agency.

If we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer's data to the credit agencies is consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the security of our payment claims.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of contract, term, customer category). Creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behaviour).
• Persons affected: Service recipients and clients; interested parties. Business and contractual     partners.
• Purposes of processing: Assessment of creditworthiness and credit standing.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Automated decisions in individual cases: Credit information (decision based on a credit check).

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Further information on processing operations, procedures and services:

• BN & Partners Capital AG: Takeover of customer onboarding as part of the liability umbrella; Service provider: BN & Partners Capital AG
      Steinstraße 33
      50374 Erftstadt; Website: https://bnpartner.com/ . Privacy Policy: https://bnpartner.com/informationen-zum-datenschutz/ .

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Provision of the online offer and web hosting

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

• Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content     and functions); metadata, communication data and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
• Data subjects: Users (e.g. website visitors, users of online services). Business and contractual partners.
• Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures. Office and organisational procedures.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Further information on processing operations, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a     corresponding server provider (also called "web host"); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of     so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the     previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilisation of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.
• E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and     senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are     generally not sent in encrypted form. As a rule, emails are encrypted in transit,     but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore assume no responsibility for the transmission path of the emails between the sender and receipt on our server; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Content delivery network: We use a content delivery network (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as     graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Webflow: Creation, management and hosting of websites, online forms and other web elements; Service     provider: Webflow, Inc., 398 11th St., Floor 2, 94103 San Francisco, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://webflow.com ; Privacy Policy: https://webflow.com/legal/eu-privacy-policy ; Data processing agreement: https://webflow.com/legal/dpa . Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
• Amazon CloudFront: Content Delivery Network (CDN) - Service that enables the content of an online offering, in particular large media files such as graphics or programme scripts, to be     delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://aws.amazon.com/de/cloudfront/ ; Privacy Policy: https://aws.amazon.com/privacy/ ; Data processing agreement: https://aws.amazon.com/de/compliance/gdpr-center/ . Basis for third country transfers: EU/EEA - standard contractual clauses (provided by the service provider), Switzerland - adequacy decision (Luxembourg).
• JSDelivr: Content Delivery Network (CDN), which helps to deliver media and files quickly and efficiently, especially under high load; Service provider: ProspectOne, Królewska 65A/1, 30-081, Kraków, Poland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.jsdelivr.com ; Privacy Policy: https://www.jsdelivr.com/terms/privacy-policy . Basis for third country transfers: Switzerland - adequacy decision (Poland).

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Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
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Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law.In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to you and contains the information on the respective use of cookies.
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Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask for their consent. If users accept, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g.in the commercial operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.
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Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile     application).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are     permanent and that the storage duration can be up to two years.
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General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

• Processed data types: Meta, communication and process data (e.g. IP addresses, time data,     identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence     1 lit. a) GDPR).
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Further information on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers     mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated     processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A     pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Cookiebot: Consent management: Process for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and their processing; Service provider: Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/de ; Privacy Policy: https://www.cookiebot.com/de/privacy-policy/ ; Data processing agreement: Provided by the service provider; Additional     information: Stored data (on the server of the service provider): The user's IP number in anonymised form (the last three digits are set to 0), the date and time of consent, browser details, the URL from which the consent was sent, An anonymous, random and encrypted key value. the user's consent status.
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Special notes on applications (apps)

We process the data of users of our application insofar as this is necessary to provide users with the application and its functionalities, to monitor its security and to develop it further. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administration or use of the application.Otherwise, we refer to the data protection information in this privacy policy with regard to the processing of user data.
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Legal basis: The processing of data required to provide 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 asked to consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

• Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); usage data (e.g. page views and length of stay, click     paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures. Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium").Readers' data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone     numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers,     persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit.     f) GDPR).

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Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone     numbers); Content data (e.g. text or image messages and contributions as     well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Affected persons: Communication partner.
• Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and     pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
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Further information on processing operations, procedures and services:

• Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the     respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Video conferences, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as"conference"). When selecting the conference platforms and their services, we observe the legal requirements.
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Data processed by conference platforms: As part of participation in a conference, the conference platforms process the participants' personal data listed below. The scope of the processing depends on which data is required in the context of a specific conference (e.g. specification of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, the conference platforms may also process participants' data for security purposes or service optimisation. The processed data includes personal data (first name, surname), 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 language settings, information on the content of the communication processes, i.e.entries in chats as well as 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 the participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
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Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be communicated transparently to the participants in advance and - if necessary - they will be asked for their consent.
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Data protection measures for participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the optimum security and data protection settings for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g. by informing roommates, locking doors and using the function to make the background unrecognisable if technically possible). Links to the conference rooms and access data must not be passed on to unauthorised third parties.
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Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, 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 (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone     numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services). Depicted persons.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication. Office and organisational procedures.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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Further information on processing operations, procedures and services:

• Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365     applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/ ; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement , Security information: https://www.microsoft.com/de-de/trustcenter . Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
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Cloud services

We use software services accessible via the internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") 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).

In this context, personal data may be processed and stored on the provider's servers if they are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. The cloud service providers also process usage data and meta data that they use for security purposes and to optimise their services.

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

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone     numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Affected persons: Interested parties; communication partners. Business and contractual partners.
• Purposes of processing: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment     (computers, servers, etc.)).
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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Further information on processing operations, procedures and services:

• Microsoft cloud services: cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-de ; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement , Security information: https://www.microsoft.com/de-de/trustcenter ; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: EU/EEA - Data Privacy     Framework (DPF), Switzerland - Adequacy Decision (Ireland).

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Web analysis, monitoring and optimisation

Web analysis (also referred to as"reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. It also enables us to understand which areas require optimisation.

In addition to web analysis, we may also use test procedures, for example to test and optimise different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.

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

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

• Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Further information on processing operations, procedures and services:

• Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification     number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time     of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers.
  Pseudonymised user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP     addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before     the traffic is forwarded to Analytics servers for processing; service     provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Security measures: IP masking (pseudonymisation of the IP address) ; Privacy Policy: https://policies.google.com/privacy ; Data processing agreement: https://business.safety.google/adsprocessorterms/ ; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - adequacy decision (Ireland); Opt-Out: Opt-out     plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of adverts: https://myadcenter.google.com/personalizationoff . Further information: https://business.safety.google/adsservices/ (types of processing and processed data).

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Customer reviews and evaluation process

We participate in review and rating procedures in order to evaluate, optimise and advertise our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers' data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer's consent.This data is used solely to verify the authenticity of the user.

• Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
• Persons affected: Service recipients and clients. Users (e.g. website visitors, users of online     services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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Further information on processing operations, procedures and services:

• Google Customer Reviews: Service for obtaining and/or presenting customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/ ; Privacy Policy: https://policies.google.com/privacy ; Third country transfer basis: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Further information: As part of the collection of customer reviews, an identification number and time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer's e-mail address and their country of residence as well as the review details themselves are processed; Further information on the types of processing and the data processed: https://business.safety.google/adsservices/ . Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms .

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Presence in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce user rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes.For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on users' computers, in which the user behaviour and interests of the users are stored.In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

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

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

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

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Further information on processing operations, procedures and services:

• LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors' data generated for the purpose of creating the "page insights" (statistics) of our LinkedIn profiles.
  This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as job function, country,  industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's data protection information: https://www.linkedin.com/legal/privacy-policy      
  We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum) , which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to     information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The     further processing of the data is the sole responsibility of Ireland Unlimited Company, which in particular concerns the transmission of the  data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2,     Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy     ; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .

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Plug-ins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "webbeacons") for statistical or marketing purposes. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, but may also be linked to such information from other sources.
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Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest inefficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

• Processed data types: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). 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: Provision of our online services and user-friendliness; marketing. Profiles with user-related information (creation of user profiles).
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Further information on processing operations, procedures and services:

• Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and user location data; Service     provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/ ; Privacy Policy: https://policies.google.com/privacy     . Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
• LinkedIn plugins and content: LinkedIn plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from     this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com ; Privacy Policy: https://www.linkedin.com/legal/privacy-policy ; Data processing agreement: https://legal.linkedin.com/dpa ; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.    

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Management, organisation and support tools

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

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

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 providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

• Processed data types: Content data (e.g. text or image messages and posts and the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved). Contact data (e.g. postal and email addresses or telephone numbers).
• Affected persons: Communication partners. Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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Processing of data in the context of employment relationships

In the context of employment relationships, personal data is processed with the aim of effectively organising the establishment, implementation and termination of such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relations.

Data processing covers various aspects ranging from contract initiation to contract cancellation. This includes the organisation and administration of daily working hours, the administration of access rights and authorisations as well as the handling of personnel development measures and employee appraisals. The processing is also used for payroll accounting and the administration of wage and salary payments, which are critical aspects of contract fulfilment.

Data processing also takes into account the legitimate interests of the employer responsible, such as ensuring safety in the workplace or collecting performance data to evaluate and optimise operational processes. Data processing also includes the disclosure of employee data as part of external communication and publication processes, where this is necessary for operational or legal purposes.

This data is always processed in compliance with the applicable legal framework, whereby the aim is always to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymisation or deletion of data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.

• Processed data types: Employee data (information on employees and other persons in an employment relationship); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); social data (data subject to social confidentiality and processed, for example, by social insurance institutions, social welfare institutions or pension authorities); log data (e.g. log files relating to logins or the retrieval of data or access times); performance and behaviour data (e.g. performance and behaviour aspects such as performance evaluations, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behaviour evaluations). Salary data (e.g. base salary, bonus payments,     premiums, tax class information, night work/overtime allowances, tax deductions, social security contributions, net amount paid).
• Persons affected: Employees (e.g. salaried employees, applicants, temporary staff and other employees).
• Purposes of processing: Establishment and implementation of employment relationships (processing of employee data in the context of the establishment and implementation of employment relationships); business processes and business management procedures. Provision of contractual services and fulfilment of contractual obligations.
• Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).

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Further information on processing operations, procedures and services:

• Purposes of data processing: Employees' personal data is primarily processed to establish, implement and terminate the employment relationship. In addition, the processing of this data is necessary to fulfil legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfil regulatory and supervisory requirements, to optimise electronic data processing processes and to compile internal or     cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the assertion of legal claims and for defence in legal disputes; legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal     obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Payroll accounting and payroll accounting: Procedures required for the calculation, payment and     documentation of wages, salaries and other remuneration of employees (e.g.     Recording of working hours, calculation of deductions and supplements, payment of taxes and social security contributions, preparation of wage and salary statements, management of payroll accounts, reporting to the tax office and social security institutions); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
• Personnel file management: Procedures required for the organisation, updating and management of employee data and documents (e.g. recording of personnel master data, storage of employment contracts, references and certificates, updating of data in the event of changes, compilation of documents for employee appraisals,  archiving of personnel files, compliance with data protection regulations); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art.     6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).

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Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us 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 organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

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Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined bylaw, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Employees: Employees are defined as persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal     relationship between an employer and an employee that is defined by an employment contract or agreement. It involves the employer's obligation to pay remuneration to the employee while the employee performs work. The employment relationship comprises various phases, including the establishment phase, in which the employment contract is concluded, the performance phase, in which the employee carries out their work activities, and the termination phase, when the employment relationship ends, whether by termination, cancellation agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal     identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
• Inventory data: Inventory data includes essential information that is necessary for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
• Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if the data subject consents, if they are necessary for the fulfilment of a contract or if national laws permit these decisions.
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
• Contact details: Contact data is essential information that enables communication with individuals or organisations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant     messaging identifiers.
• Performance and behavioural data: Performance and behavioural data refers to information related to how people perform tasks or behave in a particular context, such as an     educational, work or social environment. This data can include metrics such as productivity, efficiency, quality of work, attendance and compliance with policies or procedures. Behavioural data could include interactions with colleagues, communication styles, decision-making processes and reactions to different situations. These types of data are     often used for performance appraisals, training and development and decision making within organisations.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that     contain information about the way in which data is processed, transmitted     and managed. Meta data, also known as data about data, includes     information that describes the context, origin and structure of other data. It can include information about the file size, the creation date, the author of a document and the change histories. Communication data     records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat     histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and procedures within systems  or organisations, including workflow documentation, logs of transactions  and activities, and audit logs used to track and review processes.
• Usage data: Usage data refers to  information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that     shows how users use applications, which functions they favour, how long they stay on certain pages and which paths they take to navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is  particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In  addition, usage data plays a crucial role in recognising trends, preferences and potential problem areas within digital offerings
• Personal data: "Personal  data" means any information relating to an identified or identifiable     natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an  identification number, location data, an online identifier (e.g. a cookie)     or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of "profiles with user-related     information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal     data to analyse, evaluate or predict certain personal aspects relating to  a natural person (depending on the type of profiling, this may include     various information relating to 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.
• Log data: Log data is information about events or activities that have been logged on a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation     of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests  of visitors in certain information, such as website content. With the help of reach analysis, operators of online services can, for example,  recognise at what time users visit their websites and what content they are interested in. This enables them to better customise the content of     their websites to the needs of their visitors, for example. Pseudonymous cookies  and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
• Location data: Location data is  generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN     or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
• Controller: The  "controller" is the natural or legal person, public authority,  agency or other body which, alone or jointly with others, determines the  purposes and means of the processing of personal data.
• Processing: "Processing"  means any operation or set of operations which is performed on personal  data, whether or not by automated means. The term is broad and encompasses     practically every handling of data, whether it is collecting, analysing,  storing, transmitting or deleting.
• Contract data: Contract data is specific information that relates to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of  data is essential for the management and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract     data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, cancellation rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
• Payment data: Payment data includes  all information required to process payment transactions between buyers  and sellers. This data is crucial for e-commerce, online banking and any  other form of financial transaction. It includes details such as credit  card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorisations and fees.