Privacy Policy

Introduction

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

The terms used are not gender-specific.

As of June 18, 2021

Responsible party

Fabian Gmeindl / Drip Trading GmbH
Kolpingstraße 32
83278 Traunstein

Email address: shess@dawyn.ai.

Overview of processing activities

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

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, application documents and the information contained therein, such as cover letters, CVs, certificates and other information relating to a specific position or voluntarily provided by applicants regarding their person or qualifications).
  • Content data (e.g., entries in online forms).
  • Contact details (e.g. email, phone numbers).
  • Metadata/communication data (e.g., device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Contract details (e.g. subject matter of the contract, term, customer category).
  • Payment details (e.g. bank details, invoices, payment history).

Categories of affected persons

  • Employees (e.g., staff, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Prospective customers.
  • Communication partners
  • Customers.
  • Users (e.g., website visitors, users of online services).

Purposes of processing

  • Provision of our online services and user-friendliness.
  • Application process (justification and any subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Office and organizational procedures.
  • Direct marketing (e.g., by email or post).
  • Feedback (e.g., collecting feedback via online form).
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creating user profiles).
  • Audience measurement (e.g., access statistics, recognition of returning visitors).
  • Security measures.
  • Provision of contractual services and customer service.
  • Management and response to inquiries

Relevant legal bases

Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection laws may apply in your or our country of residence or establishment. Furthermore, should more specific legal bases 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 consent to the processing of his or her personal data for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – The processing is necessary for the performance of a contract to which the data subject is a 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) – The 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.
  • Application process as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g., health data, such as severe disability or ethnic origin) are requested from applicants during the application process so that the controller or the data subject can exercise their rights and fulfill their obligations under employment law and social security and social protection law, their processing is carried out in accordance with Art. 9 para. 2 lit. b GDPR, in the case of protecting the vital interests of the applicants or other persons in accordance with Art. 9 para. 2 lit. c GDPR, or for purposes of preventive or occupational medicine, for assessing the 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 in accordance with Art. 9 para. 2 lit. h GDPR. In the case of the disclosure of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.
  • National Data Protection Regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation (GDPR), national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment-related purposes (§ 26 BDSG), especially with regard to the establishment, execution, or termination of employment relationships and the consent of employees. State data protection laws of the individual federal states may also apply.

Security Measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

SSL encryption (https): To protect the data you transmit via our online service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this will only be done in accordance with legal requirements.

Subject to explicit consent or where transfer is required by contract or law, we only process or have data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Use of Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie primarily serves to store information about a user during or after their visit to an online service. Stored information can include, for example, language settings on a website, login status, items in a shopping cart, or the point at which a video was paused. We also include other technologies that perform the same functions as cookies in the term "cookies" (e.g., when user data is stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their browser.
  • Persistent cookies: Persistent cookies remain stored even after the browser is closed. This allows, for example, login status to be saved or preferred content to be displayed directly when the user revisits a website. Similarly, user interests, which are used for audience measurement or marketing purposes, can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely required) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input, or for security reasons).
  • Statistics, marketing, and personalization cookies: Cookies are also typically used for audience measurement and when a user's interests or behavior (e.g., viewing specific content, using certain functions, etc.) on individual websites are stored in a user profile. Such profiles are used to show users content that matches their potential interests. This process is also known as "tracking," i.e., monitoring users' potential interests. If we use cookies or tracking technologies, we will inform you separately in our privacy policy or when obtaining your consent.

Information on the legal basis: The legal basis for processing your personal data using cookies depends on whether we ask for your consent. If so, and you consent to the use of cookies, the legal basis for processing your data is your explicit consent. Otherwise, data processed using cookies is processed based on our legitimate interests (e.g., in the efficient operation and improvement of our online services) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information on the storage period of persistent cookies (e.g., as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the right to revoke any consent you have given or to object to the processing of your data by cookie technologies at any time (collectively referred to as "opt-out"). You can initially declare your objection via your browser settings, e.g., by disabling the use of cookies (although this may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also find further information on how to object in the details provided about the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management process to obtain, manage, and revoke user consent for the use of cookies and the processing activities and providers mentioned within the cookie consent management process. The consent declaration is stored to avoid having to request it again and to be able to demonstrate consent in accordance with legal requirements. Storage can be server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to assign consent to a user or their device. Subject to individual information regarding the providers of cookie management services, the following applies: The storage period for consent can be up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers), and the browser, operating system, and device used.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Users (e.g., website visitors, users of online services).

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Business Services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners") within the framework of contractual and similar legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to safeguard our rights, and for the administrative tasks and business organization associated with this information. We only disclose the data of our contractual partners to third parties within the framework of applicable law to the extent necessary for the aforementioned purposes, to fulfill legal obligations, or with the consent of the data subjects (e.g., to participating telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Contractual partners will be informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colors) or symbols (e.g. stars or similar), or personally.

We delete data after the expiry of statutory warranty periods and similar obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons (e.g., for tax purposes, generally 10 years). Data disclosed to us by the contractual partner within the scope of a contract is deleted according to the contract specifications, generally after the contract has ended.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms apply to the relationship between users and the providers.

Agency services: We process our clients' data within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services.

Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject of contract, term, customer category).

Affected persons: prospective customers, business partners and contractual partners.

Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and answering of inquiries.

Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Provision of the Online Service and Web Hosting

In order to provide our online service securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers they manage) the online service can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed in connection with providing our hosting services may include all information relating to users of our online services that is generated during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online services to browsers, and all entries made within our online services or on websites.

Collection of access data and log files: We (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, typically, IP addresses and the requesting provider.

Server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server utilization and stability.

Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing: Provision of our online service and user-friendliness.

Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

GoDaddy: Domain registration and web hosting services; Service provider: Go Daddy Operating Company, LLC, 14455 N. Hayden Road, Scottsdale, Arizona 85254, USA; Website: https://de.godaddy.com; Privacy policy: https://de.godaddy.com/legal/agreements/privacy-policy.

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter referred to as "publication medium"). Reader data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. For further information, please refer to the information on the processing of visitors to our publication medium within the framework of this privacy policy.

Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves could be held liable for the comment or post and are therefore interested in the author's identity.

Furthermore, we reserve the right to process user data for spam detection purposes based on our legitimate interests.

On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting.

The personal information provided in the comments and posts, including contact details, website information, and content, will be stored by us permanently until the user objects.

Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing: Provision of contractual services and customer service, feedback (e.g. collecting feedback via online form), security measures, administration and answering of inquiries.

Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contact

When you contact us (e.g. via contact form, email, telephone or social media), the information provided by the requesting persons will be processed to the extent necessary to answer the contact requests and any requested measures.

Responding to contact requests within the framework of contractual or pre-contractual relationships is done to fulfill our contractual obligations or to answer (pre-)contractual inquiries, and otherwise on the basis of our legitimate interests in answering the inquiries.

Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms).

Affected persons: Communication partners.

Purposes of processing: Contact requests and communication.

Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Application Process

The application process requires applicants to provide us with the data necessary for their assessment and selection. The required information is specified in the job description or, in the case of online forms, in the information provided there.

Generally, the required information includes personal details such as name, address, contact information, and proof of qualifications necessary for the position. We will gladly provide further details upon request.

If available, applicants can submit their applications to us using an online form. The data is transmitted to us using state-of-the-art encryption. Applicants can also submit their applications via email. However, please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the security of the application during transmission between the sender and its receipt on our server.

For the purposes of candidate sourcing, application submission and candidate selection, we may, in compliance with legal requirements, use applicant management or recruitment software and platforms and services from third-party providers.

Applicants are welcome to contact us regarding the method of submitting their application or to send us their application by post.

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Article 9(1) GDPR (e.g., health data, such as information on severe disability or ethnic origin) are requested from applicants during the application process so that the controller or the data subject can exercise their rights and fulfill their obligations under employment law and social security and social protection law, this processing is carried out in accordance with Article 9(2)(b) GDPR, in the case of the protection of the vital interests of the applicants or other persons in accordance with Article 9(2)(c) GDPR, or for purposes of preventive or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnosis, for the provision of health or social care or treatment, or for the management of health or social care systems and services in accordance with Article 9(2)(h) GDPR. In the case of disclosure of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

Data Deletion: If an application is successful, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a legitimate objection from the applicant, deletion will take place no later than six months after the application date. This allows us to answer any follow-up questions regarding the application and to comply with our obligations under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursements will be archived in accordance with tax regulations.

Inclusion in a talent pool: Inclusion in a talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process, and that they can withdraw their consent at any time for the future.

Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, application documents and the information contained therein, such as cover letters, CVs, certificates and other information relating to a specific position or voluntarily provided by applicants regarding their person or qualifications).

Affected persons: Applicants.

Purposes of processing: Application process (establishment and any subsequent implementation as well as possible subsequent termination of the employment relationship).

Legal basis: Application process as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).

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 following purposes: document storage and management, calendar management, email sending, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

Within this framework, personal data may be processed and stored on the providers' servers, insofar as this data is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data relating to transactions, contracts, other processes, and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.

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

Legal basis: If we request consent for the use of cloud services, the legal basis for processing is that consent. Furthermore, their use may be part of our (pre-)contractual services, provided that the use of cloud services has been agreed upon within this framework. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient and secure administrative and collaborative processes).

Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Customers, employees (e.g., staff, applicants, former employees), interested parties, communication partners.

Purposes of processing: Office and organizational procedures.

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

Google Cloud Services: Cloud storage services; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/; Privacy policy: https://www.google.com/policies/privacy; Security information: https://cloud.google.com/security/privacy; Standard Contractual Clauses (guaranteeing a level of data protection when processing in third countries): https://cloud.google.com/terms/data-processing-terms.

Web Analytics, Monitoring, and Optimization

Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online services and can include pseudonymous data on visitor behavior, interests, or demographic information, such as age or gender. Reach analysis allows us, for example, to identify when our online services, their features, or content are most frequently used or encourage repeat visits. We can also determine which areas require optimization.

In addition to web analytics, we can also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles can be created and stored in a file (a so-called "cookie") or similar methods can be used for the same purpose. This information can include, for example, viewed content, visited websites and elements used there, and technical information such as the browser used, the computer system used, and usage times. Depending on the provider, if users have consented to the collection of their location data, this may also be processed.

User IP addresses are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored for web analytics, A/B testing, and optimization; instead, pseudonyms are used. 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 purposes of the respective procedures.

Information on the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is that consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in providing efficient, economical, and user-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.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing: Audience measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).

Security measures: IP masking (pseudonymization of the IP address).

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

Google Analytics: Audience measurement and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy.

Google Optimize: Use of Google Analytics data to improve areas of our online offering and to better target our marketing efforts to potential user interests; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Opt-out options: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad settings: https://adssettings.google.com/authenticated.

Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags via a single interface and thus integrate other services into our online offering (see further details in this privacy policy). The Tag Manager itself (which implements the tags) does not, for example, create user profiles or store cookies. Google only receives the user's IP address, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.

Online Marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on users' potential interests, as well as measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie") or similar methods are used to store user information relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical information such as the browser used, the computer system used, and usage times. If users have consented to the collection of their location data, this data may also be processed.

Users' IP addresses are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored as part of the online marketing process; only pseudonyms are used. This means that neither we nor the providers of the online marketing methods know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is generally stored in cookies or using similar methods. These cookies can later be read on other websites that use the same online marketing methods and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing provider.

In exceptional cases, personal data may be associated with profiles. This occurs, for example, when users are members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by giving their consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, through conversion tracking, we can examine which of our online marketing methods have led to a conversion, i.e., a contract signed with us. Conversion tracking is used solely to analyze the success of our marketing efforts.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Information on the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is that consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in providing efficient, economical, and user-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.

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing: Marketing, profiling with user-related information (creating user profiles).

Security measures: IP masking (pseudonymization of the IP address).

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Right to object (opt-out): We refer you to the privacy policies of the respective providers and the opt-out options provided by them. If no explicit opt-out option is provided, you can disable cookies in your browser settings. However, this may restrict the functionality of our website. We therefore also recommend the following opt-out options, which are offered for specific regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-region: https://optout.aboutads.info.

Services and service providers used:

Google Analytics: Online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Opt-out options: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad settings: https://adssettings.google.com/authenticated.

Rating Platforms

We participate in rating processes to evaluate, optimize, and promote our services. When users rate us or otherwise provide feedback via the participating rating platforms or processes, the providers' terms and conditions and privacy policies also apply. As a rule, rating also requires registration with the respective providers.

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

Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).

Affected persons: Customers, users (e.g. website visitors, users of online services).

Purposes of processing: Feedback (e.g. collecting feedback via online form).

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Social Media Presence

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

Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their 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 usage patterns and the resulting user interests. These user profiles can then be used to display advertisements both within and outside the networks that are presumably tailored to the users' interests. For these purposes, cookies are typically stored on users' computers, recording their usage patterns and interests. Additionally, user profiles can also store data independent of the devices used by the users (especially if the users are members of the respective platforms and are logged in).

For a detailed description of the respective processing methods and the options for objecting (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the providers have access to user data and can take appropriate action and provide information directly. However, should you require assistance, you can contact us.

Types of data processed: Contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing: Contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.

Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Deletion of Data

The data we process will be deleted in accordance with legal requirements as soon as the consents allowing its processing are withdrawn or other permissions cease to apply (e.g., if the purpose of processing this data no longer exists or it is no longer necessary for that purpose).

Unless the data is deleted because it is required for other legally permissible purposes, its processing will be restricted to those purposes. This means the data will be blocked and not processed for any other purpose. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person.

Within the framework of our privacy policy, we can provide users with further information on the deletion and storage of data, which applies specifically to the respective processing operations.

Changes and updates to the privacy policy

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object, 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) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive the personal data concerning you that 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.
  • Right to lodge a complaint with a supervisory authority: In accordance with legal requirements 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 where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are listed alphabetically.

  • IP masking: "IP masking" refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, particularly in online marketing.
  • 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 simply "profiles," encompasses any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Examples of such profiling include interests in specific content or products, click behavior on a website, or location. Cookies and web beacons are frequently used for profiling purposes.
  • Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience analysis, website owners can, for example, determine when visitors access their website and which content they are interested in. This allows them to better tailor the website content to their visitors' needs. Pseudonymous cookies and web beacons are frequently used for audience analysis to recognize returning visitors and thus obtain more accurate analyses of online service usage.
  • Controller: The term "controller" refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.