Privacy Policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration 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 offer”).
The terms used are not gender-specific. Status: 11 November 2022

Table of contents

• Introduction
• Responsible
• Contact Data Protection Officer
• Overview of the processing
• Relevant legal bases
• Security measures
• Transmission of personal data
• Data processing in third countries
• Data deletion
• Use of cookies
• Business services
• Provision of the online offer and web hosting
• Blogs and publication media
• Contact and enquiry management
• Video conferencing, online meetings, webinars and screen sharing
• Application procedure
• Cloud services
• Newsletter and electronic notifications
• Promotional communication via e-mail, post, fax or telephone
• Web analysis, monitoring and optimisation
• Online marketing
• Presence in social networks (social media)
• Plugins and embedded functions and content
• Management, organisation and auxiliary tools
• Amendment and update of the privacy policy
• Rights of the data subjects
• Definitions of terms

Responsible

Setlog GmbH Alleestrasse 80
44793 Bochum GERMANY
T: +49 234 720 285 00
F: +49 234 720 285 99
Authorised representatives:
Ralf Düster, Guido Brackelsberg, Dmitry Chaykin E-mail address: info@setlog.com
Imprint: https://www.setlog.com/impressum

Contact Data Protection Officer

We have appointed a data protection officer Markus van der Bijl
eMail: datenschutz@setlog.com

Overview of the processing

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

• Inventory data.
• Payment details.
• Contact details.
• Content data.
• Contract data.
• Usage data.
• Meta/communication data.
• Applicant data.
• Event data (Facebook).

Categories of persons concerned

• Customers.
• Employees.
• Interested parties.
• Communication partner.
• Users.
• Applicants.
• Business and contractual partners.
• Persons depicted.

Purposes of the processing

• Provision of contractual services and customer service.
• Contact requests and communication.
• Safety measures.
• Direct marketing.
• Reach measurement.
• Tracking.
• Office and organisational procedures.
• Conversion measurement.
• Target group formation.
• Managing and responding to enquiries.
• Application procedure.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Target group formation.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal basis 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 be relevant in individual cases, we will inform you of these in the data protection declaration.

• Consent (Art. 6 para. 1 sent. 1 lit. a) DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
• Contract performance and pre-contractual enquiries (Art. 6 (1) p. 1 lit.
b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
• Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
• Application procedure as a pre-contractual or contractual relationship (Art. 6(1)(b) law and fulfil his or her obligations in this regard. If the data protection officer or the data subject requests data from job applicants (e.g. health data, such as severely disabled persons or ethnic origin) so that the data protection officer or the data subject can exercise his or her rights under labour law and social security law and fulfil his or her obligations in this respect, the data is processed in accordance with Article 9(2)(b) of the GDPR. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. DSGVO.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on 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, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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. The 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, entry into, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): In order to protect your data transmitted via our online offer, we use TLS encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. 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 that serve to protect your data with the recipients of your data.

Data processing in third countries

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

Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data- protection_de).

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
As part of our privacy notices, we may provide users with further information on the deletion and retention of data specific to the processing operation.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process the cookies in the course of this data protection declaration or as part of our consent and processing procedures.

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

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile app).
• Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further guidance on processing operations, procedures and services: The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.

• Cookiebot: Cookie consent management; Service provider: Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/de; Privacy policy: https://www.cookiebot.com/de/privacy-policy/; Other information: Data stored (on the service provider’s server): The user’s IP number in anonymised form (the last three digits are set to 0), Date and time of consent, Browser details, The URL from which the consent was sent, An anonymous, random and encrypted key value; The user’s consent status.

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 as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries. We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and

rights (e.g. for the involvement of 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 disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall begin at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual accounts or the management report was drawn up, the commercial or business letter was received or sent or the accounting document was created, furthermore the recording was made or the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
• Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category).
• Affected persons: Interested parties; business and contractual partners.
• Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organisational procedures; administration and response to requests.
• Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

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 terminal device.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of 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.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• anonymised.

Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
• E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Hostserver GmbH: Services in the field of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); service provider: Hostserver GmbH Biegenstr. 2035037 Marburg Tel.: +49(0)64 21 / 175 175-0Fax: +49(0)64 21 / 175 175-9Email:
info@hostserver.de
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO; Website: https://www.hostserver.de;
Privacy policy:
https://www.hostserver.de/unternehmen/agb/datenschutzerklaerung/.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Contact and enquiry management

When contacting us (e.g. by contact form, e-mail, 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 answer the contact enquiries and any requested measures.
• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Affected persons: Communication partner.
• Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.
Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends on the one hand on which data is requested in the context of a specific conference (e.g. provision of access data or clear names) and on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The contents of the communications are encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent – if necessary.
Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms and select the optimal security and data protection settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g. by notifying fellow participants, locking doors and using the function to make the background unrecognisable, if technically possible). Links to the conference rooms as well as access data, may not be passed on to unauthorised third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in participant lists, in the case of processing of conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners; Users (e.g. website visitors, users of online services); Persons depicted.
• Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organisational procedures.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Microsoft Teams: messenger and conferencing software; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services- Data-Protection-Addendum-DPA.
• Zoom: Video conferences, web conferences and webinars; Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://zoom.us; Privacy policy: https://zoom.us/docs/de- de/privacy-and-legal.html; Order processing agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA); Standard contractual clauses (ensuring level of data protection for processing in third countries): https://zoom.us/docs/de-de/privacy-and- legal.html (referred to as Global DPA).
• GoToMeeting: Conference software; Service provider: LogMeIn Ireland Limited, Bloodstone Building Block C 70, Sir John Rogerson’s Quay Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.gotomeeting.com/de-de; Privacy policy: https://www.logmeininc.com/de/legal/privacy; Order processing agreement: https://www.logmein.com/de/legal#other-agreements (data processing addendum); Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.logmein.com/de/legal#other-agreements (data processing addendum).

Application procedure

The application procedure requires that applicants provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.
In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.
If provided, applicants can submit their applications to us using an online form. The data will be transmitted to us in encrypted form in accordance with the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e- mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services from third party providers in compliance with legal requirements.
Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.
Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 (1) of the GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure in order for the controller or the data subject to exercise the rights accruing to him or her under labour law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) (b) of the GDPR. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of the special categories of data based on voluntary consent, their processing is based on Art. 9 (2) lit. a. DSGVO.
Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application.
Otherwise, if the application for a vacancy is unsuccessful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified withdrawal by the applicants, at the latest after the expiry of a period of six months to enable us to answer any follow-up questions about the application and to comply with our obligations to provide evidence under the Equal Treatment of Applicants Regulations. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
• Persons concerned: Applicants.
• Purposes of the processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
• Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 lit. b) DSGVO).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.
If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g. in the case of media control).
• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online

forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Affected persons: Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners.
• Purposes of processing: office and organisational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
• Microsoft Cloud Services: cloud storage, cloud infrastructure services and cloud-based application software; Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://microsoft.com/de- de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter; Order processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services- Data-Protection-Addendum-DPA; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services- Data-Protection-Addendum-DPA.

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further details if these are required for the purposes of the newsletter. Double opt-in procedure: Registration for our newsletter is always carried out in a so- called double opt-in process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.
The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been 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.
• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
• Affected persons: Communication partner.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

• 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 cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail, for this purpose.
Further guidance on processing operations, procedures and services:
• Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve us to recognise 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 the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are based on the consent of the users. Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
• HubSpot: Email marketing platform; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.hubspot.com/dpa.

Promotional communication via e-mail, post, fax or telephone

We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we store the data required to prove the previous entitlement to contact or send 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 defence against claims. Based on the legitimate interest of permanently observing the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
• Affected persons: Communication partner.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Web analysis, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.
In addition to web analysis, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and 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 agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles); tracking (e.g. interest/behaviour-related profiling, use of cookies); provision of our online offer and user-friendliness.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
• Google Analytics: web analysis, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-Out- Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).
• No collection of detailed location and device data (Google Analytics function): No detailed location and device data is collected (further information: https://support.google.com/analytics/answer/12017362).
• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user’s IP address, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).

Online marketing

We process personal data for online marketing purposes, which may include, but are not limited to, marketing advertising space or displaying promotional and other content (collectively, “Content”) based on users’ potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (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, this may also be processed. The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not 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 and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
• Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Event data (Facebook) (“Event data” is data that can be transmitted, e.g. via Facebook Pixel (via apps or in other ways) by us to Facebook and relates to persons or their actions; The data includes e.g.. Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data are deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
• 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/behaviour-related profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiling with user-related information (creation of user profiles); target group formation (determination of target groups relevant for marketing purposes or other output of content); provision of our online offer and user friendliness.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
• Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the opt-out options given for the providers. If no explicit opt-out option has been specified, you have the option of switching off 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 offered in summary for the respective regions: 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.
Further guidance on processing operations, procedures and services:
• Facebook pixel and target group formation (Custom Audiences): With the help of the Facebook pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so- called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook Pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Further information: Event data of users, i.e. behavioural and interest data, are processed for the purposes of targeted advertising and audience building on the basis of the Joint Responsibility Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Shared responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

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 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 the users because, for example, it may be more difficult to enforce the rights of the users.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can 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 behaviour and the 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 to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we 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 providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
• Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
• Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data)
; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the US (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
• LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
• YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Opt-out: https://adssettings.google.com/authenticated.
• Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plugins and embedded functions and content

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

device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of the processing: Provision of our online offer and user- friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
• Google Fonts (provided on own server): Fonts (“Google Fonts”) for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Management, organisation and auxiliary tools

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

privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.
If users are referred to third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
• Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services).
• Purposes of processing: provision of contractual services and customer service; office and organisational procedures; range measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
• HubSpot: Social media publishing, reporting (e.g. traffic sources, access figures, web analysis), contact management (e.g. contact forms, direct communication and user segmentation), landing pages; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy:
https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.hubspot.com/dpa.

Amendment and update of the privacy policy

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.
Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

Rights of the data subjects

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 at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right of revocation for consents: You have the right to revoke any consent you have given at any time.
• Right of access: You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.

• Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another controller.
• Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

• Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s 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 ads we have placed on other websites have been successful.
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

• 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 these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can see, for example, 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 purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
• Tracking: We speak of “tracking” when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information with regard to the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
• Controller: 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 upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
• Target group formation: We speak of target group formation (or “custom audiences”) when target groups are determined 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 in which he or she viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) 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 to create custom audiences and lookalike audiences