Privacy policy
Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender-specific.
Status: December 8, 2025
Table of contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of the data subjects
- Business services
- Provision of the online offer and web hosting
- Use of cookies
- Blogs and publication media
- Contact and request management
- Newsletter and electronic notifications
- Advertising communication via e-mail, post, fax or telephone
- Web analysis, monitoring and optimization
- Online marketing
- Customer reviews and evaluation process
- Presence in social networks (social media)
- Plug-ins and embedded functions and content
- Data protection information for whistleblowers
- Change and update
- Definitions of terms
Person responsible
Fatih Kömec - AGS Schulungsgesellschaft mbH - Welding Technology Academy
E-mail address: info@schweisser-akademie.de
Phone: 0621 953 426 80
Imprint: https://schweisser-akademie.de/impressum/
Overview of processing
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.
- Employee data.
- Payment data.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Protocol data.
Categories of affected persons
- Beneficiary and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Business and contractual partners.
- Third parties.
- Whistleblower.
Purposes of the processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Target group formation.
- Organizational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Information technology infrastructure.
- Whistleblower protection.
- Public relations.
- Sales promotion.
- Business processes and business management procedures.
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Contract fulfillment 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.
- 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.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data 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), 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. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
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 the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which can be recognized by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and define contractual obligations to protect 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, the standard contractual clauses act as a reliable fall-back option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.
For the individual service providers, we will inform you whether they are certified in accordance with 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 website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive. We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.
Retention and deletion of data: The following general time limits 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 required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. Para. 3 AO, § 14b Para. 1 UStG, § 257 Para. 1 No. 1 i.V.m. para. 4 HGB).
- 8 years - Accounting documents, such as invoices and expense receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. para. 4 HGB).
- 6 years - Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents, insofar as they are relevant for taxation, e.g. time sheets, company accounting sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting documents and cash register slips (Section 147 (1) nos. 2, 3, 5 in conjunction with (3) AO). Para. 3 AO, § 257 Para. 1 No. 2 and 3 in conjunction with Para. para. 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on past business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Period begins at the end of the year: If a period does not expressly 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. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the termination or other termination of the legal relationship takes effect.
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
- Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
- Right to data portability: You have the right to receive 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.
- Complaint to 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 provisions of the GDPR.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as „contractual partners"), in the context of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to inquiries.
We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Persons concerned: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of the processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Performance of a contract 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).
Further information on processing operations, procedures and services:
- Craft services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and delivery or execution or provision.
The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for delivery and invoicing as well as contact information in order to be able to hold any consultations; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online offer and web hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web host"); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Use of cookies
The term „cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user's consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage duration: A distinction is made between the following types of cookies with regard to the storage period:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that they may be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Legal basis: 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 operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a consent management solution in which the user's consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness; security measures. Organizational and administrative procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies in order to avoid multiple votes.
The personal information provided as part of the comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact and request management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Communication partner.
- Purposes of the processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter „newsletter") exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the users. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Contents:Information about us, our services, promotions and offers.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: The newsletters contain a so-called „web beacon", i.e. a pixel-sized file that is retrieved from our server or its server, if we use a mailing service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates and the storage of the measurement results in the user profiles - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke their consent at any time or to object to advertising communication at any time free of charge via the contact option mentioned above.
After revocation or objection, we store the data required to prove the previous authorization for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analysis, monitoring and optimization
Web analysis (also referred to as „reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used, or invite visitors to reuse them. It also enables us to understand which areas require optimization.
In addition to web analysis, we may also use test procedures, for example to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Safety 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).
Further information on processing operations, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users that refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Safety measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms); Possibility of objection (opt-out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).
Online marketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as „content") based on the potential interests of users and the measurement of its 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 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, this can also be processed.
The IP addresses of 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 user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are generally stored in cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if, for example, the users are members of a social network whose online marketing processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part 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 the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies are 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, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Information on revocation and objection:
We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are summarized for each area:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-territory: https://optout.aboutads.info.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioral profiling, use of cookies); target group formation; marketing. Profiles with user-related information (creation of user profiles).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Safety measures: IP masking (pseudonymization of the IP address).
Customer reviews and evaluation process
We participate in review and rating procedures in order to evaluate, optimize and advertise our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers' data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer's consent. This data is used solely to verify the authenticity of the user.
- Processed data types: Contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Service recipients and clients. Users (e.g. website visitors, users of online services).
- Purposes of the processing: Feedback (e.g. collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on the user's computer, in which the user's usage behavior and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network, allows you to share photos and videos, comment on and favorite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
- Facebook pages: Profiles within the social network Facebook - The controller, together with Meta Platforms Ireland Limited, is responsible for the collection and transmission of data from visitors to our Facebook page („fan page"). This includes, in particular, information about user behavior (e.g. content viewed or interacted with, actions performed) and device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the „Page Insights" service, which provide information about how people interact with our page and its content. The basis for this is an agreement with Facebook („Information on Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subjects' rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore send requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transmission to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors„ data used to create the "page insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have entered into a special agreement with LinkedIn Ireland („Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of the data subjects (i.e. users can, for example, send requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - Pinterest: Social network, allows you to share photos, comment, favorite and curate posts, send messages, subscribe to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy policy: https://policy.pinterest.com/de/privacy-policy.
- X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/. Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
Plug-ins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as „content").
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons") for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, but may also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Location data (information on the geographical position of a device or person).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of our online services and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioral profiling, use of cookies); target group formation. Marketing.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offer, users„ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts "Analytics" page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to display targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and user location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Possibility of objection (opt-out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Data protection information for whistleblowers
In this section, you will find information on how we handle data from persons who provide information (whistleblowers) and from affected and involved parties as part of our whistleblower procedure. Our aim is to provide an uncomplicated and secure way to report possible misconduct by us, our employees or service providers, especially for actions that violate laws or regulations. - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Legal basis (Germany): Insofar as we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6 para. 1 sentence 1 lit. c) GDPR and, in the case of special categories of personal data, Article 9 para. 2 lit. g) GDPR, Section 22 BDSG, in each case in conjunction with Section 10 HinSchG. This relates to the obligation to set up and operate an internal whistleblower reporting office, the fulfillment of its statutory duties and, in the case of the use of the data collected in the reporting procedure, the taking of further investigations or steps under labor law against persons who have been convicted of a violation.
Insofar as we process data (in particular in the event of identified misconduct) in the context of or in preparation for legal defense, this is done on the basis of our legitimate interests in legally compliant and ethical action in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.
If you have given us your consent to process personal data for specific purposes, the processing is carried out on the basis of this consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR and, in the case of special cases, in accordance with Art. 6 para. 1 sentence 1 lit. b) GDPR. - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Legal basis (Austria): Insofar as we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HSchG), the legal basis for processing is Article 6 para. 1 sentence 1 lit. c) GDPR and, in the case of special categories of personal data, Article 9 para. 2 lit. g) GDPR, in each case in conjunction with Section 8 HSchG. This relates to the obligation to set up and operate an internal whistleblower reporting office, the fulfillment of its legal duties and, in the case of the use of the data collected in the reporting procedure, the taking of further investigations or labor law steps against persons who have been convicted of a violation.
Insofar as we process data (in particular in the event of identified misconduct) in the context of or in preparation for legal defense, this is done on the basis of our legitimate interests in legally compliant and ethical action in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.
If you have given us your consent to process personal data for specific purposes, the processing is carried out on the basis of this consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR and in the case of special categories - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Processed data types:
We may collect various data in the course of receiving and processing reports and in the subsequent whistleblower procedure. This includes, in particular, the data provided by a whistleblower, such as
- Name, contact details and location of the person providing the information,
- Names and details of possible witnesses or persons affected by the tip-off,
- Names and details of the persons against whom the notice is directed,
- Data on the alleged misconduct,
- Further relevant details, if provided by the whistleblower.
We also process the following personal data for the purposes of investigating the facts and further proceedings:
- Clear identification of the message,
- Contact details of the person providing the information, if specified,
- Personal data of persons named in the notice, if provided,
- Personal data of persons indirectly affected by the - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Special categories of personal data:
In the course of our activities, we may collect special types of personal data, especially if these are provided by a whistleblower. This includes
- Health-related data of a person,
- Data on the racial or ethnic origin of persons,
- Information about a person's religious or philosophical beliefs,
- Information on a person's sexual orientation.
This data is only processed if it - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Use of our online forms: Please note that it is possible to submit comments anonymously. To ensure the security of your data when using our online forms, we recommend that you access them in the so-called 'incognito mode' of your browser. You can open an incognito window as follows: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.
When you access our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your end device. This data is temporarily stored in a log file and automatically deleted after 30 days at the latest.
The IP address is processed for technical and administrative purposes to establish a connection to our website. It ensures the security, stability and functionality of the whistleblower form and is an important part of our measures to ensure confidentiality. - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Indication of names: You have the option of submitting comments anonymously. However, unless prohibited by national legislation, we recommend that you provide your name and contact details. This enables us to investigate the report more effectively and contact you directly if necessary.
If you provide your name and contact details, your identity will be kept strictly confidential. Exceptions to this confidentiality only exist if we are legally obliged to disclose your identity. This may be necessary to protect our rights or the rights of our employees, customers, suppliers or business partners. - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Provision of data to third parties: Data relating to the information provided will only be passed on by us to third parties under certain circumstances. This happens either a) if you have given us your express consent to do so, or b) if there is a legal obligation to pass on the data. Possible third parties include public authorities, government, regulatory or tax authorities if the disclosure is necessary to fulfill a legal or regulatory obligation. We may also engage lawyers and other professional advisors as permitted by law. They are authorized to investigate suspected misconduct and take necessary action following an investigation, such as initiating disciplinary or legal proceedings. In addition, service providers carefully selected and monitored by us may receive data for these purposes (e.g. operators of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection regulations as part of commissioned data processing.
Data retention and deletion: Personal data is only processed for as long as is necessary to fulfill the processing purposes described above. If this data is no longer necessary for the purposes mentioned, it will be deleted. In certain situations, however, the data may be retained for longer in order to comply with legal requirements, as long as this is necessary and proportionate. In such cases - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
Technical and organizational measures: We have implemented the necessary contractual, technical and organizational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. Incoming reports are processed by authorized persons who are given access to the respective reports and carry out the subsequent review of the facts. Our employees are specially - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ); employee data (information on employees and other persons in a company) - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ); contact details (e.g. postal and e-mail addresses or - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ); content data (e.g. textual or visual messages and contributions and the information relating to them, such as information on authorship - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ). Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ).
- Persons concerned: Employees (e.g. salaried employees, applicants, temporary staff and other - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ); Third parties. Whistleblower.
- Purposes of the processing: Whistleblower protection.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Change and update
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (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 us.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- Employees: Employees are defined as persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is defined by an employment contract or agreement. It involves the employer's obligation to pay remuneration to the employee while the employee performs work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee performs his or her work activities, and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance appraisals.
- Inventory data: Inventory data includes essential information that is 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, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
- Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
- Contact details: Contact data is essential information that enables communication with people or organizations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Meta, communication and process data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information on 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 e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
- Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they take to navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Protocol data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of their websites to the needs of their visitors, for example. For the purposes 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 offer.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: The term "tracking" is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Responsible person: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
- 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 category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
- Payment data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorizations and fees.
- Target group formation: Custom audiences are defined as target groups for advertising purposes, e.g. the 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 store in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
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