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Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process for which purposes and to what extent in the context of providing our application.

The terms used are not gender-specific.

Status: December 22, 2025

Table of Contents

Controller

Elena Gundyreva
Habichergasse 45, 1160 Wien, Austria

Authorized representative: Elena Gundyreva

E-mail address: GEMgundyreva@gmx.at

Imprint: gem-humanenergetik.at/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.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Image and/or video recordings.
  • Audio recordings.
  • Protocol data.

Categories of data subjects

  • Service recipients and clients.
  • Communication partners.
  • Users.
  • Depicted persons.
  • Third parties.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Public relations.
  • Artificial intelligence (AI).

Relevant Legal Bases

Relevant legal bases according to GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be applicable in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of personal data relating to him or her for one or more specific purposes.
  • Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, 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 Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. This includes in particular the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains special regulations regarding the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases.

Note on the application of GDPR and Swiss DPA: These privacy notices serve to provide information under both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA "processing" of "personal data", "overriding interest" and "particularly sensitive personal data", the terms used in the GDPR "processing" of "personal data" as well as "legitimate interest" and "special categories of data" are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of the application of the Swiss DPA.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of security 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 access to, input of, disclosure of, ensuring availability of and segregation of data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data and response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect users' 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), thereby protecting the data from unauthorized access. TLS, as the evolved and more secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and encrypted.

Transmission of Personal Data

In the context of our processing of personal data, the data may be transmitted to or disclosed to other entities, companies, legally independent organizational 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 comply with legal requirements and conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transmission within the corporate group: We may transmit personal data to other companies within our corporate group or grant them access to it. This data sharing takes place on the basis of our legitimate business and economic interests. This includes, for example, the improvement of business processes, ensuring efficient and effective internal communication, optimal use of our human and technological resources and the ability to make informed business decisions. In certain cases, data sharing may also be necessary to fulfill our contractual obligations, or it may be based on the consent of the data subjects or a legal permission.

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, entities or companies (which becomes apparent from the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. This ensures that your data always remains adequately protected even in the event of any political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, express consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information offer of 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 legal provisions as soon as the underlying consent is revoked or there are no other legal bases for processing. This applies to cases in which the original processing purpose ceases to apply or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy notices contain additional information on the retention and deletion of data that specifically applies to certain processing processes.

If several indications are given regarding the retention period or deletion deadlines of a date, the longest period is always decisive. Data that is no longer retained for the originally intended purpose, but due to legal requirements or other reasons, we process exclusively for the reasons that justify their retention.

Retention and deletion of data: The following general periods apply according to Austrian law for retention and archiving:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Federal Fiscal Code (BAO §132), Commercial Code (UGB §§190-212)).
  • 6 years - Other business documents: Received commercial or business letters, copies of sent commercial or business letters and other documents, provided they are relevant for tax purposes. This includes, for example, hourly wage slips, operating accounting sheets, calculation documents, price labeling and wage accounting documents, provided they are not already accounting documents and cash register receipts (Federal Fiscal Code (BAO §132), Commercial Code (UGB §§190-212)).
  • 3 years - Data that is required to consider potential warranty and damage compensation claims or similar contractual claims and rights as well as to process associated inquiries, based on previous business experience and usual industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).

Period commencing 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 starts at the end of the calendar year in which the period-triggering event occurred. In the case of ongoing contractual relationships within which data is stored, the period-triggering event is the time at which the termination or other termination of the legal relationship becomes effective.

Rights of Data Subjects

Rights of data subjects under GDPR: As data subjects under GDPR, you have various rights, 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 processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right of access: You have the right to request confirmation as to whether relevant data is being processed and to information about this data as well as to further information and a copy of the data in accordance with legal provisions.
  • Right to rectification: In accordance with legal provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal provisions, you have the right to demand that data concerning you be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with legal provisions.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to supervisory authority: In accordance with legal provisions 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 in which you habitually reside, the supervisory authority of your workplace or the place of the alleged infringement, if you are of the opinion that the processing of personal data relating to you infringes the GDPR.

Provision of Online Offering and Web Hosting

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

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Protocol data (e.g. log files concerning logins or retrieval of data or access times). Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • 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 on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

Use of Cookies

Cookies are small text files or other data records that store information on end devices and read information from the end devices. For example, to store the login status in a user account, shopping cart content in an e-shop, content accessed or functions used in an online offering. Cookies can also be used for different purposes, e.g. for purposes of functionality, security and convenience of online offerings as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal provisions. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide an information society service (i.e. our online offering) explicitly requested by the user. Essential cookies usually include cookies with functions related to the display, performance and functionality of the online offering, load balancing, security, storage of users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offering requested by users. 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 use of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or in the context 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 offering 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 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 for reach measurement. 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 the storage period can be up to two years.

General notes on revocation and objection (so-called "opt-out"): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with legal requirements. Users can also restrict the use of cookies via their browser settings (whereby this may also restrict the functionality of our online offering). 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/.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Contact and Inquiry Management

When contacting us (e.g. by mail, contact form, e-mail, telephone or via social media) and in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

  • Types of data processed: Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: 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 procedures, methods 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 to process the communicated request; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on functionality, encryption, use of metadata of communication and your objection options.

You can also contact us in alternative ways, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options specified in our online offering.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messengers with activated encryption so that the encryption of the message content is ensured.

However, we also point out to our communication partners that although the messenger providers cannot see the content, they can find out that and when communication partners communicate with us and process technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).

Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us of their own accord, for example, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messengers. Furthermore, we point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke consent given at any time and object to communication with us via messenger at any time. In the case of communication via messengers, we delete the messages in accordance with our general deletion guidelines (i.e. e.g. as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.

Reservation of reference to other communication channels: Finally, we reserve the right to refuse to answer inquiries via messenger for reasons of security. This is the case if, for example, internal contractual matters require special confidentiality or an answer via messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Types of data processed: Contact data (e.g. postal and e-mail addresses or telephone numbers); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; Direct marketing (e.g. by e-mail or postal mail).
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

  • Telegram: Messenger with end-to-end encryption; Service provider: Telegram Messenger Inc., 5527 Sonora St, Plano, TX 75074, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://telegram.org/; Privacy policy: https://telegram.org/privacy.
  • WhatsApp: Messenger with end-to-end encryption. The metadata (i.e. who communicated with whom and when) are also encrypted; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal/privacy-policy. Data Privacy Framework (DPF): WhatsApp Ireland Limited is certified under the Data Privacy Framework (DPF), ensuring compliance with EU data protection standards when processing data in the USA (https://www.dataprivacyframework.gov/participant/5778).

Artificial Intelligence (KI)

We use artificial intelligence (AI) technologies as part of our service offerings. AI enables the automation, personalization and improvement of various processes. The use of AI is based on the processing of data that we receive from users or that is otherwise processed by us for the purposes mentioned in this privacy policy. This includes data such as usage data, content data and communication data. Through AI-supported analyses and processing, we can, for example, better respond to user needs or optimize our services. The legal basis for the use of AI is determined according to the respective purpose of use. As a rule, AI is used as part of our contractual services or based on our legitimate interests in efficient and improved service provision, provided that no other legal basis applies, such as user consent.

  • Types of data processed: Inventory data (e.g. the 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 posts as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Image and/or video recordings (e.g. photographs or video recordings of a person). Audio recordings (e.g. recordings of conversations or other audio content).
  • Data subjects: Communication partners; Users (e.g. website visitors, users of online services); Depicted persons. Service recipients and clients.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Contact requests and communication; Direct marketing (e.g. by e-mail or postal mail). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Video Conferencing, Online Meetings, Webinars and Screen Sharing

We use platforms and applications from 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 "conferences"). When selecting conference platforms and configuring their services, we observe legal requirements.

Data processed by conference platforms: In the context of participation in conferences, conference platforms process the personal data of participants listed below. The scope of processing depends on which data is required as part of a specific conference, which access authorizations are granted to participants and which data processing takes place on the conference platform itself. In addition to the actual execution of conferences, data can also be processed before and after conferences as well as in the context of registrations and participant administration.

The processed data includes personal data on users: First name, last name, telephone number (optional), e-mail address, password (if registration on the platform is necessary), profile pictures (optional), department/company (optional).
Data on conferences: Subject, description (optional), participant IP addresses, device/hardware information, operating system.

Recordings (optional): If conference platforms offer a recording function, users are informed about this in advance and must give their consent, if necessary, so that audio, video or screen content is recorded (e.g. chat entries, shared screen content, presentations and similar data as well as information related to user interactions, such as clicks on buttons, etc.).

If texts are entered, for example to ask questions, these can be stored in order to document conference sessions. However, this usually requires consent or at least information to the participants.

Purpose and legal bases: The data is processed in order to provide conference functions to users.

We are interested in effective and secure conferences and have therefore chosen conference platforms whose operators we trust to provide reliable and secure conference services. On this basis, we process data based on our legitimate interests.

If consent is required for certain processing (e.g. recording of conferences), we obtain it beforehand; the legal basis in this case is the consent.

The content of conferences can be encrypted, as far as technically possible on the user side. The responsibility for ensuring that the technical requirements for encryption are met on the user side lies with the users and their conference platform providers.

Recipient and data transfer: When users use other services in connection with the conference platform or, for example, integrate third-party applications or plugins (e.g. calendar synchronizations or appointment booking services), personal data is also made accessible to these services. The data processing by these services is governed by the respective provider's data protection information.

  • Types of data processed: Inventory data (e.g. the 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 posts as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Image and/or video recordings (e.g. photographs or video recordings of a person). Audio recordings (e.g. recordings of conversations or other audio content).
  • Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Web Analytics, Monitoring and Optimization

Web analytics (also referred to as "reach measurement") is used to evaluate visitor traffic on our online offering and can include the behavior, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or content are most frequently used or encourage reuse. Likewise, we can understand which areas need optimization.

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

Unless otherwise stated below, profiles can be created for these purposes, i.e. data summarized for a usage process, and information can be stored in a browser or end 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 consented 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 users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, in the context of web analytics, A/B testing and optimization, no user data (such as e-mail addresses or names) is stored, 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 purposes of the respective processes.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Protocol data (e.g. log files concerning logins or retrieval of data or access times). Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles); Tracking (e.g. interest/behavioral profiling, use of cookies). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with 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 up to two years).
  • Security measures: IP masking (pseudonymization of IP address).
  • Legal bases: 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 procedures, methods and services:

  • Google Analytics 4: 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 unique data, such as names or e-mail addresses. It is used to assign analytics information to an end device in order to recognize which content users have accessed within one or more usage sessions, which search terms they have used, have accessed again or have interacted with our online offering. The times of use and their duration are also saved, as well as the sources of users who 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 may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geo-location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), 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, accessible or used for further use. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Standard contractual clauses (ensuring level of data protection when processing in third countries): https://business.safety.google/intl/de/adsprocessorterms; Opt-Out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed). Data Privacy Framework (DPF): Google Ireland Limited is certified under the Data Privacy Framework (DPF), ensuring compliance with EU data protection standards when processing data in the USA (https://www.dataprivacyframework.gov/participant/5780).

Customer Reviews and Rating Procedures

We participate in review and rating procedures in order to evaluate, optimize and promote our services. If users rate us via the review or rating platforms or procedures used by us or send us feedback, the General Terms and Conditions or Terms of Use and the privacy notices of the providers also apply. As a rule, the rating also requires registration with the respective providers.

In order to ensure that the evaluating persons have actually used our services, we transmit the data necessary for this purpose to the respective review or rating platform (including name and e-mail address) with the consent of the users. This data is used solely to verify the authenticity of the user.

  • Types of data processed: Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved). Contact data (e.g. postal and e-mail addresses or telephone numbers).
  • Data subjects: Service recipients and clients.
  • Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: 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 procedures, methods and services:

Presences 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 point out that user data may be processed outside the European Union. This can result in risks for users because, for example, the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests of 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 behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (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 objection options (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

Also in the case of information requests and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • 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. Public relations.
  • Retention and deletion: Deletion in accordance with information in the section "General information on data storage and deletion".
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Facebook pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Standard contractual clauses (ensuring level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum. Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/page_controller_addendum. The shared responsibility is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the 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. Data Privacy Framework (DPF): Meta Platforms Ireland Limited is certified under the Data Privacy Framework (DPF), ensuring compliance with EU data protection standards when processing data in the USA (https://www.dataprivacyframework.gov/participant/4452).
  • Instagram profiles: Profiles within the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Data Privacy Framework (DPF): Meta Platforms Ireland Limited is certified under the Data Privacy Framework (DPF), ensuring compliance with EU data protection standards when processing data in the USA (https://www.dataprivacyframework.gov/participant/4452).

Plugins and Embedded Functions and Content

We integrate 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 can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").

The integration always presupposes that the third-party providers of this content process the IP address of users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the presentation of this content or functions. We strive to use only such content whose respective providers use the IP address only to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate 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 may contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, as well as be linked to such information from other sources.

  • Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Protocol data (e.g. log files concerning logins or retrieval of data or access times). Contact data (e.g. postal and e-mail addresses or telephone numbers).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness. Profiles with user-related information (creating user profiles).
  • Retention and deletion: Deletion in accordance with 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 up to two years).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Changes and Updates

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require 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 verify 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 legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Artificial Intelligence (AI): Artificial intelligence (AI) refers to technologies and systems capable of performing tasks that require human-like intelligence. These include learning, reasoning, problem solving, perception and language understanding. AI can be divided into different categories, such as narrow AI, which is specialized for specific tasks, and general AI, which is capable of performing a variety of tasks. The use of AI ranges from automated decision-making systems to machine learning, natural language processing and robotics.
  • Audio recordings: Audio recordings are recordings of conversations or other sounds that are recorded for a variety of purposes. They can be created as part of communication, for example in meetings, telephone calls or online conferences, as well as for the creation of audio content such as podcasts, radio programs or music productions. Audio recordings can be transmitted in analog or digital form and stored on various media, such as magnetic tapes, CDs or digital storage devices. The creation and use of audio recordings can also be subject to legal regulations, particularly with regard to data protection, consent requirements of the persons recorded and copyrights. In a professional context, audio recordings are often used to document conversations, create protocols or enable the later review of content.
  • Contract data: Contract data is special information relating to the conclusion, execution, modification or termination of contracts or business relationships. It includes data that is necessary for initiating, processing and managing contractual relationships. Contract data can include contract numbers, contract periods, customer categories, special features or priorities of contracts and other information relevant to contract management. It is part of inventory data because it refers to the basic data and details needed to identify and manage business partners and their contractual obligations.
  • Content data: Content data includes information created, edited or shared as part of creating, editing and publishing content. This category of data may include text, images, videos, audio files and other multimedia elements embedded or created within online offerings, applications or other platforms. Content data also includes metadata, which contains information about the content itself, such as authorship, creation date, location and interaction (such as likes, shares and comments). They are central to the user experience because they determine the content that is displayed to users.
  • Controller: "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • 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, for example, personal and demographic data such as names, contact details (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities or systems, by enabling the assignment and communication between these and the respective persons.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, communicated and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. This may include information such as timestamps of creation or modification, authorship and changes made to documents. Communication data includes information that arises in the context of exchanges between users via various channels, such as e-mail, telephone, instant messaging or social media. This includes metadata such as connection data, IP addresses and timestamps, as well as content-related information included in the communication exchanges. Procedural data refers to information generated in the context of business or technical processes. This includes process logs, transaction histories, error reports and other protocol data that is used to track the sequence of operations in systems and applications.
  • 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.
  • Image and/or video recordings: Image and video recordings refer to visual captures of persons or events. Such recordings can be made in various forms, such as photographs, video clips, live streams and other visual media. In the digital context, this includes both images and videos that are uploaded or shared via websites, apps, social media and other online platforms. These recordings often serve purposes such as communication, content creation, security monitoring, personalized advertising or public presentation and can be stored and processed in various formats and via various devices. The creation and use of image and video recordings is subject to strict legal frameworks, especially regarding data protection and personal rights, as they affect individual privacy and personality rights. It is therefore important to obtain the consent of the persons depicted when creating and disseminating image and video recordings, unless a legal exception applies.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • 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 involves using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (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: Protocol data, also known as log files or log data, are electronic records of events and activities that occur within a computer system, network, application or other IT environment. These data contain information about access, actions, errors, warnings and other relevant events that are recorded for a certain period of time. Protocol data serves various purposes, including security monitoring, system and network analysis, troubleshooting, performance evaluation and compliance with legal or regulatory requirements. Typically, protocol data includes timestamps that indicate when a specific event occurred, as well as details about the users, processes or systems involved in that event. In the context of data protection and data security, protocol data is important for understanding data flows, identifying security incidents and enabling the necessary responses and investigations to such events.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic 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, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better optimize the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Tracking: "Tracking" is used when the behavior of users can be tracked across multiple websites. As a rule, behavioral and interest information is stored in cookies or on servers of the tracking technology providers with regard to the websites used (so-called profiling). This information can then be used, for example, to display advertisements to users that presumably correspond to their interests.
  • 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 provides insight into usage patterns, preferences and behavior of users. Usage data includes, for example, page views, time spent on different pages, click paths (the sequence of pages visited by users), search queries, actions performed (such as purchases or form submissions), device types and operating systems used, as well as information about interactions with app functionalities or website content. It is used to analyze, optimize and personalize user experience, improve security, develop products and services, and support effective marketing strategies. The collection and processing of usage data is subject to strict data protection regulations to protect user privacy.