Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to simply as "data") we process, for which 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 the "online offering").

The terms used are not gender-specific.

Last updated: April 20, 2024

Table of Contents

Controller

Samuel Schwarze
P.O. Box 94 02 04
12442 Berlin

Email address: Click here

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 concerned.

Types of Data Processed

  • Contact data.
  • Content data.
  • Usage data.
  • Metadata, communication data, and procedural data.

Categories of Data Subjects

  • Communication partners.
  • Users.

Purposes of Processing

  • Contact requests and communication.
  • Security measures.
  • Management and response to inquiries.
  • Feedback.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Applicable Legal Bases

Applicable legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or establishment. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of them in this privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) - The data subject has given consent to the processing of personal data concerning them for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • 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, provided that the interests, fundamental rights, and freedoms of the data subject requiring the protection of personal data do not override those interests.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG). The BDSG contains, in particular, special provisions on 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 transmission, as well as automated decision-making in individual cases, including profiling. In addition, the data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss FADP: These privacy notices serve both to provide information under the Swiss Federal Act on Data Protection (Swiss FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader territorial scope and easier comprehensibility, the terminology of the GDPR is used. In particular, instead of the terms used in the Swiss FADP, namely "Bearbeitung" (processing) of "Personendaten" (personal data), "überwiegendes Interesse" (overriding interest), and "besonders schützenswerte Personendaten" (particularly sensitive personal data), the GDPR terms "Verarbeitung" (processing) of "personenbezogenen Daten" (personal data), "berechtigtes Interesse" (legitimate interest), and "besondere Kategorien von Daten" (special categories of data) are used. However, within the scope of the Swiss FADP, the legal meaning of these terms continues to be determined in accordance with the Swiss FADP.

Security Measures

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

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, safeguarding of availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data breaches. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through privacy-friendly default settings.

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

Transfer of Personal Data

As part of our processing of personal data, it may happen that such data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content integrated into a website. In such cases, we comply with the statutory requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or the disclosure or transfer of data to other persons, bodies, or companies, this only takes place in accordance with the statutory requirements. If the level of data protection in the third country has been recognized by an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c GDPR), explicit consent, or in the case of contractually or legally required transfer (Art. 49 para. 1 GDPR). In all other respects, we inform you of the basis for third-country transfers in connection with the respective providers from the third country, whereby adequacy decisions take priority as the basis. 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.

EU-US Trans-Atlantic Data Privacy Framework: Under the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection as adequate for certain companies in the USA under the adequacy decision of July 10, 2023. The list of certified companies and further information about the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English). Within these privacy notices, we inform you which service providers used by us are certified under the Data Privacy Framework.

Retention and Deletion of Data

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or no other legal bases for the processing exist. 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 where legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities. If several retention periods or deletion deadlines are specified for a particular item of data, the longest period always applies. If a period does not explicitly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred.

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

Further information on processing activities, procedures, and services:

  • Retention and deletion of data (Germany): The following general periods apply to retention and archiving under German law:

    10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet, as well as work instructions and other organizational documents required for their understanding, accounting records, and invoices (§ 147 para. 3 in conjunction with para. 1 nos. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 nos. 1 and 4, para. 4 HGB).

    6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting records, and cash register tapes (§ 147 para. 3 in conjunction with para. 1 nos. 2, 3, 5 AO, § 257 para. 1 nos. 2 and 3, para. 4 HGB).

    3 years - Data required to assert potential warranty and damages claims.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, arising in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you that is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether the relevant data is being processed and to obtain information about that data, as well as further information and a copy of the data, in accordance with the statutory provisions.
  • 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 request that data concerning you be deleted without undue delay or, alternatively, to request restriction of the processing of the data in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with the statutory provisions, or to request its transfer to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Provision of the Online Offering and Web Hosting

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

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Further information on processing activities, procedures, and services:

  • Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent from or otherwise obtain from a corresponding server provider (also referred to as a "web host"); Legal bases: 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 retrieved web pages and files, the date and time of retrieval, transferred data volumes, notification of successful retrieval, 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. On the one hand, the server log files may be used for security purposes, e.g. to avoid server overload (especially in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Use of Cookies

Cookies are small text files or other storage notes that store information on end devices and read information from them. For example, to store the login status in a user account, the contents of a shopping cart in an online shop, the content accessed, or the functions used in an online offering. Cookies may also be used for various other purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users unless it is not required by law. Permission is not necessary in particular if the storage and reading of information, including cookies, is strictly necessary in order to provide users with a telemedia service expressly requested by them (i.e. our online offering). The revocable consent is clearly communicated to users and contains information about the respective use of cookies.

Notes on data protection legal bases: The data protection legal basis on which we process users' personal data using cookies depends on whether we ask for their consent. If users accept, the legal basis for the use of their data is the consent they have given. Otherwise, the data processed using cookies is 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 takes place within the framework of the performance of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which cookies are used by us throughout this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to storage duration, the following types of cookies are distinguished:

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

General notes on withdrawal and objection (opt-out): Users may withdraw any consent they have given at any time and may also object to the processing in accordance with the statutory provisions, including by means of their browser's privacy settings.

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

Further information on processing activities, procedures, and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers named within the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consents, particularly with regard to the use of cookies and comparable technologies used to store, read, and process information on users' devices. Within the scope of this procedure, users' consent is obtained for the use of cookies and the related processing of information, including the specific processing activities and providers named in the consent management procedure. Users also have the option to manage and revoke 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. Storage takes place on the server and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to assign the consent to a specific user or their device. Unless specific information about the providers of consent management services is available, the following general information applies: the consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers), and information about the browser, the system, and the device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

Contact and Inquiry Management

When contacting us (e.g. by post, contact form, email, telephone, or via social media), as well as within the scope of existing user and business relationships, the information provided by the inquiring persons is processed insofar as this is necessary to respond to the contact inquiries and any requested measures.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and posts as well as information relating to them, such as details on authorship or the time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; management and response to inquiries; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).

Further information on processing activities, procedures, and services:

  • Contact form: When users contact us via our contact form, email, or other communication channels, we process the data communicated to us in this context in order to handle the communicated matter; Legal bases: 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).

Changes and Updates

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

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we ask you to verify the details before making contact.

Definitions

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

  • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Metadata, communication data, and procedural data: Metadata, communication data, and procedural data are categories that contain information about the way data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include details about file size, creation date, the author of a document, and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used to trace and verify processes.
  • Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which functions they prefer, how long they remain on certain pages, and which paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and possible problem areas within digital offerings
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Controller: "Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • 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 covers practically any handling of data, whether collection, evaluation, storage, transmission, or deletion.

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