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 as part 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 offering").
The terms used are not gender-specific.
Last updated: June 18, 2025
Table of Contents
Controller
Christian Hollatz
Brandoberndorfer Straße 4
35647 Waldsolms
Email address:
christian-hollatz@web.de
Overview of Processing Operations
The following overview summarizes the types of data processed and the purposes
of their processing and refers to the affected data subjects.
Types of Data Processed
- Inventory data.
- Payment data.
- Image data (exclusively for QR code recognition).
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Communication partners.
- Users.
- Business and contractual partners.
Purposes of Processing
-
Provision of contractual services and fulfillment of contractual
obligations.
- Communication.
- Security measures.
- Reach measurement.
- Tracking.
- Conversion measurement.
- Target group formation.
- Organizational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online service and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Business processes and business management procedures.
Applicable Legal Bases
Relevant 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 regulations may apply in your or our country of residence or
establishment. Should more specific legal bases be relevant in individual
cases, we will inform you of these in the privacy policy.
-
Consent (Art. 6(1)(a) GDPR) - The data subject has given
consent to the processing of their personal data for one or more specific
purposes.
-
Performance of a contract and pre-contractual inquiries (Art. 6(1)(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(1)(f) GDPR) - Processing is
necessary for the purposes of the legitimate interests pursued by the
controller or by a third party, except where such interests are overridden
by the interests or fundamental rights and freedoms of the data subject
which require protection of personal data.
National data protection regulations in Germany: In addition
to the data protection regulations of the GDPR, national regulations on data
protection apply in Germany. These include, in particular, the German Federal
Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains
special provisions on the right to access, the right to erasure, the right to
object, the processing of special categories of personal data, the processing
for other purposes, and transmission, as well as automated decision-making in
individual cases, including profiling. Furthermore, state data protection laws
of the individual German states may apply.
Note on the applicability of the GDPR and Swiss DPA: This
privacy notice serves to provide information in accordance with both the Swiss
Federal Act on Data Protection (DPA) and the General Data Protection
Regulation (GDPR). Please note that due to the broader territorial application
and for better understanding, the terminology of the GDPR is used. In
particular, instead of the terms "processing" of "personal data", "overriding
interest" and "particularly sensitive personal data" used in the Swiss DPA,
the terms "processing" of "personal data" as well as "legitimate interest" and
"special categories of data" used in the GDPR are used. However, the legal
meaning of the terms continues to be determined according to the Swiss DPA
within the scope of application of the Swiss DPA.
Security Measures
We take appropriate technical and organizational measures in accordance with
legal requirements, taking into account the state of the art, the
implementation costs, and the nature, scope, context, and purposes of
processing, as well as the risk of varying likelihood and severity to the
rights and freedoms of natural persons.
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, disclosure of, assurance
of availability of, and segregation of the data. We have also established
procedures to ensure the exercise of data subjects' rights, the deletion of
data, and responses to data compromise. Furthermore, we take the protection of
personal data into account as early as the development or selection of
hardware, software, and procedures, in accordance with the principle of data
protection by design and by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To
protect the data of users transmitted via our online services from
unauthorized access, we 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
comply with 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 for users that their data is being transmitted
securely and encrypted.
International Data Transfers
Data processing in third countries: If we transfer data to a third country
(i.e., outside the European Union (EU) or the European Economic Area (EEA)) or
if this occurs in the context of using third-party services or disclosure or
transfer of data to other persons, entities, or companies (which is evident
from the postal address of the respective provider or if explicitly indicated
in the privacy policy regarding data transfer to third countries), this is
always done in accordance with legal requirements.
For data transfers to the US, we primarily rely on the Data Privacy Framework
(DPF), which was recognized as a secure legal framework by an adequacy
decision of the EU Commission on July 10, 2023. Additionally, we have
concluded Standard Contractual Clauses with the respective providers that
comply with the requirements of the EU Commission and establish contractual
obligations for the protection of your data.
This dual protection ensures comprehensive protection of your data: The DPF
forms the primary layer of protection, while the Standard Contractual Clauses
serve as additional security. Should there be any changes to the DPF
framework, the Standard Contractual Clauses act as a reliable fallback option.
This ensures that your data remains adequately protected even in the event of
political or legal changes.
For individual service providers, we will inform you whether they are
certified under the DPF and whether Standard Contractual Clauses are in place.
Further information on the DPF and a list of certified companies can be found
on the US Department of Commerce website at
https://www.dataprivacyframework.gov/
(in English).
For data transfers to other third countries, appropriate safeguards apply, in
particular Standard Contractual Clauses, explicit consent, or legally required
transfers. Information on third-country transfers and applicable adequacy
decisions can be found on the EU Commission's information page:
https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with legal provisions as
soon as the underlying consents are withdrawn or there are no further legal
grounds for processing. This applies to cases where the original processing
purpose ceases to exist or the data is no longer needed. Exceptions to this
rule exist if 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 enforcement or to protect 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 specifically apply to certain processing operations.
If multiple retention periods or deletion deadlines are specified for a piece
of data, the longest period always applies.
If a period does not explicitly start on a specific date and lasts at least
one year, it automatically starts at the end of the calendar year in which the
triggering event occurred. In the case of ongoing contractual relationships
under which data is stored, the triggering event is the effective date of
termination or other ending of the legal relationship.
Data that is no longer needed for the originally intended purpose but is
retained due to legal requirements or other reasons is processed exclusively
for the purposes that justify its retention.
Further information on processing operations, procedures, and
services:
-
Data retention and deletion: 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 the work instructions and other organizational documents
necessary for their understanding (Section 147(1) No. 1 in conjunction
with paragraph 3 of the German Fiscal Code (AO), Section 14b(1) of the
German Value Added Tax Act (UStG), Section 257(1) No. 1 in conjunction
with paragraph 4 of the German Commercial Code (HGB)).
-
8 years - Accounting documents, such as invoices and expense receipts
(Section 147(1) No. 4 and 4a in conjunction with paragraph 3 sentence 1
AO and Section 257(1) No. 4 in conjunction with paragraph 4 HGB).
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6 years - Other business documents: received commercial or business
letters, reproductions of sent commercial or business letters, other
documents insofar as they are of significance for taxation, e.g. hourly
wage sheets, operational accounting sheets, calculation documents, price
marking, but also payroll accounting documents, insofar as they are not
already accounting documents (Section 147(1) No. 2, 3, 5 in conjunction
with paragraph 3 AO, Section 257(1) No. 2 and 3 in conjunction with
paragraph 4 HGB).
-
3 years - Data necessary to take into account potential warranty and
compensation claims or similar contractual claims and rights, as well as
to process related inquiries, based on previous business experience and
common industry practices, are stored for the duration of the regular
statutory limitation period of three years (Sections 195, 199 of the
German Civil Code (BGB)).
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject under the GDPR, you
have various rights, 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 the processing of personal data
concerning you which is based on Article 6(1)(e) or (f) GDPR, including
profiling based on those provisions. Where personal data are processed for
direct marketing purposes, you have the right to object at any time to
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
given consent at any time.
-
Right of access: You have the right to obtain confirmation
as to whether personal data concerning you are being processed and to obtain
information about these data as well as further information and a copy of
the data in accordance with legal requirements.
-
Right to rectification: You have the right to have the data
concerning you completed or inaccurate data concerning you rectified in
accordance with legal requirements.
-
Right to erasure and restriction of processing: You have
the right, in accordance with legal requirements, to request the erasure of
data concerning you without undue delay or, alternatively, to request the
restriction of the processing of the data in accordance with legal
requirements.
-
Right to data portability: You have the right to receive
data concerning you, which you have provided to us, in a structured,
commonly used and machine-readable format or to request their transmission
to another controller in accordance with legal requirements.
-
Lodge a complaint with a supervisory authority: Without
prejudice to any other administrative or judicial remedy, you have the right
to lodge a complaint with a supervisory authority, in particular in the
Member State of your habitual residence, place of work or place of the
alleged infringement, if you consider that the processing of personal data
relating to you infringes the GDPR.
Payment Methods
As part of contractual and other legal relationships, due to legal obligations
or otherwise based on our legitimate interests, we offer data subjects
efficient and secure payment options and use other payment service providers
in addition to banks and credit institutions (collectively "payment service
providers").
The data processed by the payment service providers includes inventory data,
such as name and address, bank details, such as account numbers or credit card
numbers, passwords, TANs and checksums, as well as contract, summary and
recipient-related information. The information is required to complete the
transactions. However, the entered data is only processed and stored by the
payment service providers. This means that we do not receive any account or
credit card-related information, but only information with confirmation or
negative notification of the payment. Under certain circumstances, the data
may be transmitted by payment service providers to credit agencies. The
purpose of this transmission is to check identity and creditworthiness. We
refer to the terms and conditions and data protection notices of the payment
service providers.
The terms and conditions and data protection notices of the respective payment
service providers apply to payment transactions, which can be accessed within
the respective websites or transaction applications. We also refer to these
for the purpose of further information and asserting rights of withdrawal,
information, and other data subject rights.
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Types of data processed: Inventory data (e.g., full name,
home address, contact information, customer number, etc.); payment data
(e.g., bank details, invoices, payment history); contract data (e.g.,
subject matter of contract, term, customer category); 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 procedural data (e.g., IP addresses, timestamps,
identification numbers, involved persons). Contact details (e.g., postal and
email addresses or phone numbers).
-
Data subjects: Service recipients and clients. Business and
contractual partners.
-
Purposes of processing: Provision of contractual services
and fulfillment of contractual obligations. Business processes and business
management procedures.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
-
Legal bases: Performance of a contract and pre-contractual
inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and
services:
-
Apple Pay: Payment services (technical connection of online
payment methods); Service provider: Apple Inc., Infinite
Loop, Cupertino, CA 95014, USA;
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR); Website:
https://www.apple.com/apple-pay/. Privacy Policy:
https://www.apple.com/legal/privacy/.
-
Google Pay: Payment services (technical connection of
online payment methods); Service provider: Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR); Website:
https://pay.google.com/about/. Privacy Policy:
https://policies.google.com/privacy.
Provision of the Online Service 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
device.
-
Types of data processed: 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 procedural data (e.g., IP addresses, timestamps,
identification numbers, involved persons). Log data (e.g., log files
regarding logins or data retrieval or access times).
-
Data subjects: Users (e.g., website visitors, users of
online services).
-
Purposes of processing: Provision of our online service and
user-friendliness; information technology infrastructure (operation and
provision of information systems and technical devices (computers, servers,
etc.)). Security measures.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
-
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and
services:
-
Provision of online service on rented server space: For the
provision of our online service, we use server space, computing capacity,
and software that we rent or otherwise obtain from a corresponding server
provider (also called "web host");
Legal bases: Legitimate interests (Art. 6(1)(f)
GDPR).
-
Collection of access data and log files: Access to our
online service is logged in the form of so-called "server log files". Server
log files may include the address and name of the 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 case of
abusive attacks, so-called DDoS attacks) and to ensure the utilization of
the servers and their stability;
Legal bases: Legitimate interests (Art. 6(1)(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 necessary for evidentiary purposes is exempt from deletion
until the respective incident is finally clarified.
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Hetzner: Services in the field of providing information
technology infrastructure and related services (e.g., storage space and/or
computing capacities); Service provider: Hetzner Online
GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany;
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website:
https://www.hetzner.com; Privacy Policy:
https://www.hetzner.com/legal/privacy-policy. Data Processing Agreement:
https://docs.hetzner.com/general/general-terms-and-conditions/data-privacy-faq/.
Registration, Login, and User Account
Users can create a user account. As part of the registration, users are
informed of the required mandatory information and this information is
processed for the purpose of providing the user account on the basis of
contractual obligation fulfillment. The processed data includes, in
particular, login information (username, password, and an email address).
In the context of using our registration and login functions as well as the
use of the user account, we store the IP address and the time of the
respective user action. The storage is based on our legitimate interests as
well as those of the users in protection against misuse and other unauthorized
use. This data is generally not passed on to third parties, unless it is
necessary for the pursuit of our claims or there is a legal obligation to do
so.
Users may be informed about events relevant to their user account, such as
technical changes, by email.
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Types of data processed: Inventory data (e.g., full name,
home address, contact information, customer number, etc.); contact details
(e.g., postal and email addresses or phone numbers); content data (e.g.,
textual or visual messages and posts as well as information concerning them,
such as authorship information 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).
Log data (e.g., log files regarding logins or data retrieval or access
times).
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Data subjects: Users (e.g., website visitors, users of
online services).
-
Purposes of processing: Provision of contractual services
and fulfillment of contractual obligations; security measures;
organizational and administrative procedures. Provision of our online
service and user-friendliness.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
Deletion after termination.
-
Legal bases: Performance of a contract and pre-contractual
inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and
services:
-
Registration with pseudonyms: Users may use pseudonyms as
usernames instead of real names;
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR).
-
User profiles are not public: Users' profiles are not
publicly visible or accessible.
-
Deletion of data after termination: When users have
terminated their user account, their data relating to the user account will
be deleted, subject to legal permission, obligation, or consent of the
users;
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR).
-
No obligation to retain data: It is the responsibility of
users to secure their data before the end of the contract in the event of
termination. We are entitled to irretrievably delete all user data stored
during the term of the contract;
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR).
Community Features
The community features provided by us allow users to engage in conversations
or otherwise interact with each other. Please note that the use of community
features is only permitted in compliance with applicable law, our terms and
guidelines, and the rights of other users and third parties.
Use of Camera Permission
Our app uses the camera function of your mobile device
(android.permission.CAMERA) exclusively for a specific functional purpose:
scanning QR codes to enable you to join a multiplayer lobby.
-
Type of processing: When scanning a QR code, access to the
camera is temporarily activated. The app processes the video stream locally
on your device to read a 6-digit lobby code contained within it.
-
No storage or transmission: The image data captured by the
camera is never stored, archived, or transmitted to our servers or third
parties. Only the extracted string (the lobby code) is processed.
-
Voluntariness: The use of the camera only takes place after
your explicit consent within the app. Without this permission, the QR code
scan function cannot be used; however, the lobby code can be entered
manually in this case.
-
Legal basis: Contract performance and pre-contractual
inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
-
Types of data processed: Inventory data (e.g., full name,
home address, contact information, customer number, etc.). 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: Provision of contractual services
and fulfillment of contractual obligations; security measures. Provision of
our online service and user-friendliness.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
-
Legal bases: Performance of a contract and pre-contractual
inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and
services:
-
Protection of own data: Users decide for themselves which
data they disclose about themselves within our online service. For example,
when users provide information about themselves or participate in
conversations. We ask users to protect their data and to disclose personal
data only with caution and only to the extent necessary. In particular, we
ask users to note that they must protect their access data particularly well
and use secure passwords (i.e., especially long and random character
combinations);
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR).
Contact and Inquiry Management
When contacting us (e.g., by mail, contact form, email, telephone, or via
social media) as well as in the context of existing user and business
relationships, the information of the inquiring persons is processed insofar
as this is necessary to respond to the contact inquiries and any requested
measures.
-
Types of data processed: Inventory data (e.g., full name,
home address, contact information, customer number, etc.); contact details
(e.g., postal and email addresses or phone numbers); content data (e.g.,
textual or visual messages and posts as well as information concerning them,
such as authorship information 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).
Meta, communication and procedural data (e.g., IP addresses, timestamps,
identification numbers, involved persons).
- Data subjects: Communication partners.
-
Purposes of processing: Communication; organizational and
administrative procedures; feedback (e.g., collecting feedback via online
forms). Provision of our online service and user-friendliness.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
-
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Further information on processing operations, procedures, and
services:
-
Contact form: When contacting us via our contact form, by
email, or other communication channels, we process the personal data
provided to us to respond to and process the respective request. This
usually includes details such as name, contact information, and any other
information communicated to us that is necessary for adequate processing. We
use this data exclusively for the stated purpose of contact and
communication;
Legal bases: Performance of a contract and
pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art.
6(1)(f) GDPR).
Push Notifications
With the consent of users, we may send them so-called "push notifications".
These are messages that are displayed on the screens, devices, or browsers of
users, even when our online service is not actively being used.
To sign up for push notifications, users must confirm the prompt of their
browser or device to receive push notifications. This consent process is
documented and stored. The storage is necessary to recognize that users have
consented to receiving push notifications and to be able to prove the consent.
For these purposes, a pseudonymous identifier of the browser (so-called "push
token") or the device ID of a device is stored.
Push notifications may, on the one hand, be necessary for the fulfillment of
contractual obligations (e.g., technical and organizational information
relevant to the use of our online service) and, on the other hand, serve to
inform users about new features, products, or services.
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Types of data processed: 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 procedural data (e.g., IP addresses, timestamps,
identification numbers, involved persons).
- Data subjects: Communication partners.
-
Purposes of processing: Communication. Provision of our
online service and user-friendliness.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
Deletion after termination.
-
Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate
interests (Art. 6(1)(f) GDPR).
Online Marketing
We process personal data for online marketing purposes, which may include, in
particular, marketing advertising space or presenting advertising and other
content (collectively "content") based on potential user interests and
measuring their effectiveness.
For these purposes, so-called user profiles are created and stored in a file
(the so-called "cookie") or similar procedures are used, by means of which the
information about the user relevant for the presentation of the aforementioned
content is stored. This information may include, for example, content viewed,
websites visited, online networks used, but also communication partners and
technical information such as the browser used, the computer system used, and
information on usage times and functions used. If users have consented to the
collection of their location data, these may also be processed.
The IP addresses of the users are also stored. However, we use available IP
masking procedures (i.e., pseudonymization by shortening the IP address) for
user protection. In general, no clear data of the users (such as email
addresses or names) is stored within the online marketing procedure, but
pseudonyms. This means that neither we nor the providers of the online
marketing procedures know the actual identity of the users, but only the
information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means
of similar procedures. These cookies can later generally also be read on other
websites that use the same online marketing procedure, analyzed for the
purpose of content presentation, and supplemented with additional data and
stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles, primarily when
users are members of a social network whose online marketing procedure we use
and the network links user profiles with the aforementioned information. We
ask to note that users may make additional arrangements with the providers,
for example by consent during registration.
We generally only receive access to summarized information about the success
of our advertisements. However, in the context of so-called conversion
measurements, we can check which of our online marketing procedures have led
to a so-called conversion, i.e., for example, to a contract conclusion with
us. Conversion measurement is used solely to analyze the success of our
marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a
period of two years.
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, users' data is processed on the basis of our legitimate
interests (i.e., interest in efficient, economic, 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.
Notes on withdrawal and objection:
We refer to the privacy notices of the respective providers and the objection
options given to the providers (so-called "opt-out"). If no explicit opt-out
option has been specified, there is the option to disable cookies in your
browser settings. However, this may restrict functions of our online service.
We therefore recommend the following opt-out options, which are offered
collectively for the respective areas:
a) Europe:
https://www.youronlinechoices.eu.
b) Canada:
https://www.youradchoices.ca/choices.
c) USA:
https://www.aboutads.info/choices.
d) Cross-territory:
https://optout.aboutads.info.
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Types of data processed: 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 procedural data (e.g., IP addresses, timestamps,
identification numbers, involved persons).
-
Data subjects: Users (e.g., website visitors, users of
online services).
-
Purposes of processing: Reach measurement (e.g., access
statistics, recognition of returning visitors); tracking (e.g.,
interest/behavior-based profiling, use of cookies); target group formation;
marketing; profiles with user-related information (creation of user
profiles). Conversion measurement (measurement of the effectiveness of
marketing measures).
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Retention and deletion: Deletion according to information
provided 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).
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Security measures: IP masking (pseudonymization of the IP
address).
-
Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate
interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and
services:
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Google Ads and Conversion Measurement: Online marketing
procedure for the purpose of placing content and advertisements within the
advertising network of the service provider (e.g., in search results, in
videos, on websites, etc.), so that they are displayed to users who have a
presumed interest in the advertisements. We also measure the conversion of
the advertisements, i.e., whether users have used them as an opportunity to
interact with the advertisements and use the advertised offers (so-called
conversions). However, we only receive anonymous information and no personal
information about individual users;
Service provider: Google Ireland Limited, Gordon House,
Barrow Street, Dublin 4, Ireland;
Legal bases: Consent (Art. 6(1)(a) GDPR), Legitimate
interests (Art. 6(1)(f) GDPR); Website:
https://marketingplatform.google.com; Privacy Policy:
https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy
Framework (DPF), Data Privacy Framework (DPF);
Further information: Types of processing and data
processed:
https://business.safety.google/adsservices/. Data processing terms between controllers and Standard Contractual
Clauses for third-country transfers of data:
https://business.safety.google/adscontrollerterms.
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Google Adsense with personalized ads: We integrate the
Google Adsense service, which allows us to place personalized ads within our
online service. Google Adsense analyzes user behavior and uses this data to
display targeted advertising that is tailored to the interests of our
visitors. For each ad impression or other uses of these ads, we receive
financial compensation; Service provider: Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal bases: Consent (Art. 6(1)(a) GDPR); Website:
https://marketingplatform.google.com; Privacy Policy:
https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy
Framework (DPF), Data Privacy Framework (DPF);
Further information: Types of processing and data
processed:
https://business.safety.google/adsservices/. Data processing terms 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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Google Adsense with non-personalized ads: We use the Google
Adsense service to display non-personalized ads in our online offering.
These ads are not based on individual user behavior but are selected based
on general characteristics such as the content of the page or your
approximate geographic location. We receive compensation for the display or
other use of these ads; Service provider: Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal bases: Consent (Art. 6(1)(a) GDPR); Website:
https://marketingplatform.google.com; Privacy Policy:
https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy
Framework (DPF), Data Privacy Framework (DPF);
Further information: Types of processing and data
processed:
https://business.safety.google/adsservices/. Data processing terms 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.
Social Media Presences
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 point out that user data may be processed outside the European Union. This
may entail risks for users, as it could, for example, make it more difficult
to enforce user rights.
Furthermore, user data within social networks is usually processed for market
research and advertising purposes. Thus, for example, usage profiles can be
created based on the usage behavior and resulting interests of the users.
These usage profiles may in turn be used, for example, to place advertisements
within and outside the networks that presumably correspond to the interests of
the users. For these purposes, cookies are usually stored on the users'
computers, in which the usage behavior and interests of the users are stored.
Furthermore, data independent of the devices used by the users may also be
stored in the usage profiles (especially if the users 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, we refer to the privacy policies and information provided by
the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject
rights, we point out that these can be most effectively asserted with the
providers. Only the providers have access to the user data and can directly
take appropriate measures and provide information. Should you nevertheless
need assistance, you may contact us.
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Types of data processed: Contact details (e.g., postal and
email addresses or phone numbers); content data (e.g., textual or visual
messages and posts as well as information concerning them, such as
authorship information 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).
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Data subjects: Users (e.g., website visitors, users of
online services).
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Purposes of processing: Communication; feedback (e.g.,
collecting feedback via online forms). Public relations.
-
Retention and deletion: Deletion according to information
provided in the section "General information on data storage and deletion".
-
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and
services:
-
Instagram: Social network, enables sharing of photos and
videos, commenting and favoriting posts, message sending, subscribing to
profiles and pages; Service provider: Meta Platforms
Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland;
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website:
https://www.instagram.com; Privacy Policy:
https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy
Framework (DPF), Data Privacy Framework (DPF).
-
X: Social network;
Service provider: Twitter International Company, One
Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland;
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website:
https://x.com.
Privacy Policy:
https://x.com/privacy.
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YouTube: Social network and video platform;
Service provider: Google Ireland Limited, Gordon House,
Barrow Street, Dublin 4, Ireland;
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Privacy Policy:
https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy
Framework (DPF), Data Privacy Framework (DPF).
Opt-out option:
https://myadcenter.google.com/personalizationoff.
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy
policy. We adjust the privacy policy as soon as changes in 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 organizations
in this privacy policy, please note that the addresses may change over time
and please check the information before contacting them.
Definitions
This section provides you with an overview of the terms used in this privacy
policy. Insofar as the terms are legally defined, their legal definitions
apply. The following explanations, on the other hand, are primarily intended
to aid understanding.
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Inventory data: Inventory data encompasses essential
information necessary for the identification and management of contractual
partners, user accounts, profiles, and similar assignments. This data may
include personal and demographic information such as names, contact
information (addresses, phone numbers, email addresses), birth dates, and
specific identifiers (user IDs). Inventory data forms the basis for any
formal interaction between individuals and services, institutions, or
systems by enabling unique assignment and communication.
-
Content data: Content data includes information generated
in the course of creating, editing, and publishing content of all types.
This category of data may include texts, images, videos, audio files, and
other multimedia content published 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 details are essential information
that enables communication with individuals or organizations. They include
phone numbers, postal addresses, and email addresses, as well as
communication tools such as social media handles and instant messaging
identifiers.
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Conversion measurement: Conversion measurement (also
referred to as "visit action evaluation") is a procedure used to determine
the effectiveness of marketing measures. For this purpose, a cookie is
usually stored on the users' devices within the websites on which the
marketing measures take place, and then retrieved again on the target
website. For example, this allows us to track whether the advertisements we
have placed on other websites have been successful.
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Meta, communication, and procedural data: Meta,
communication, and procedural data are categories that contain information
about how 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 can include details about file size,
creation date, document author, and change histories. Communication data
captures the exchange of information between users across various channels,
such as email traffic, call records, messages in social networks, and chat
histories, including the persons involved, timestamps, and transmission
paths. Procedural data describes the processes and procedures within systems
or organizations, including workflow documentation, transaction and activity
logs, and audit logs used for tracking and verifying operations.
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Usage data: Usage data refers to information that captures
how users interact with digital products, services, or platforms. This data
encompasses a wide range of information that shows how users use
applications, which features they prefer, how long they stay on certain
pages, and which paths they navigate through an application. Usage data may
also include frequency of use, activity timestamps, 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. Additionally, usage data plays a crucial
role in identifying trends, preferences, and potential problem areas within
digital offerings.
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Personal data: "Personal data" means any information
relating to an identified or identifiable natural person ("data subject");
an identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier (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.
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Profiles with user-related information: The processing of
"profiles with user-related information", or "profiles" for short, includes
any kind of automated processing of personal data that consists of using
this personal data to analyze, evaluate, or predict certain personal aspects
relating to a natural person (depending on the type of profiling, different
information concerning demographics, behavior, and interests, such as
interaction with websites and their content, etc.). For the purposes of
profiling, cookies and web beacons are often used.
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Log data: Log data is information about events or
activities that have been logged in a system or network. This data typically
includes 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 analyze system issues, monitor security, or create
performance reports.
-
Reach measurement: Reach measurement (also referred to as
web analytics) is used to evaluate the visitor flows of an online offering
and can include the behavior or interests of visitors in certain
information, such as the content of web pages. With the help of reach
analysis, website operators can, for example, recognize at what time
visitors visit their website and what content they are interested in. This
enables them, for example, to better adapt the content of the website to the
needs of their visitors. For the purpose of reach analysis, pseudonymous
cookies and web beacons are often used to recognize returning visitors and
thus obtain more precise analyses of the use of an online offering.
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Tracking: Tracking is when user behavior can be traced
across multiple online offerings. In general, in terms of the online
offerings used, behavioral and interest information is stored in cookies or
on servers of the tracking technology providers (so-called profiling). This
information can then be used, for example, to display advertisements to
users that are likely to match their interests.
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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 or on sets of personal data,
whether or not by automated means. The term is broad and includes virtually
any handling of data, be it collection, evaluation, storage, transmission,
or erasure.
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Contract data: Contract data is specific information that
relates to the formalization of an agreement between two or more parties. It
documents the conditions under which services or products are provided,
exchanged, or sold. This data category is essential for managing and
fulfilling contractual obligations and includes both the identification of
the contractual parties and the specific terms and conditions of the
agreement. Contract data may include start and end dates of the contract,
the type of agreed services or products, price agreements, payment terms,
termination rights, renewal options, and special conditions or clauses. It
serves as the legal basis for the relationship between the parties and is
crucial for clarifying rights and obligations, enforcing claims, and
resolving disputes.
-
Payment data: Payment data includes all information needed
to process payment transactions between buyers and sellers. This data is
crucial for electronic 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 may also include information about payment
status, chargebacks, authorizations, and fees.
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Target group formation: Target group formation (English
"Custom Audiences") is the determination of target groups for advertising
purposes, e.g., display of advertisements. For example, based on a user's
interest in certain products or topics on the internet, it can be concluded
that this user is interested in advertisements for similar products or the
online shop where they viewed the products. "Lookalike Audiences" (or
similar target groups) are, in turn, when the content deemed suitable is
shown to users whose profiles or interests presumably match those of the
users for whom the profiles were created. For the purposes of creating
Custom Audiences and Lookalike Audiences, cookies and web beacons are
typically used.
Created with the free Privacy Generator from Dr. Thomas Schwenke