PRIVACY POLICY

With the following privacy policy, 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 in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “Online Offer”).

Status: August 15, 2022

Legal text by Dr. Schwenke - please click for more information. We have revised the generated privacy policy towards gender-appropriate wording.

Table of contents

Responsible

Roland Steinegger
Authorized representatives:
Nadine Bolch, Peter Bolch, Daniela Grammlich, Lukas Jung
E-mail address: datenschutz@edudea.de
Imprint: https://edudea.de/impressum

Contact data protection officer

datenschutzbeauftragt@edudea.de or by mail to association address

Processing overview

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.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.

Categories of persons concerned

  • Customers.
  • Interested parties.
  • Communication partners.
  • Users.
  • Members.
  • Business and contractual partners.
  • Pupils/ Students/ Participants.

Processing purposes

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Safety measures.
  • Direct marketing.
  • Office and organizational procedures.
  • Managing and responding to inquiries.
  • Feedback.
  • Marketing.
  • 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. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 (1) p. 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 requests (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller / organization is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller / organization 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.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes, 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 provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. 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, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organizational 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, input of, disclosure of, ensuring the availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

IP address shortening: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is shortened (also referred to as “IP masking”). The last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

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, entities or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: 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). Unless the data is deleted because it is required for other and legally permissible purposes, its processing will be 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 defense of legal claims or for the protection of the rights of another natural person or legal entity.

In the context of our privacy notices, we may provide users with further information on the deletion as well as the retention of data that is specific to the respective processing operations.

Cookies use

Cookies are small text files, or other memory tags, that store information on end devices and read information from the end devices. For example, to store the login status in an account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can further be used for various purposes, e.g. for the purposes 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. Therefore, we obtain prior consent from users, except where such consent 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 the user with a telemedia service (i.e., our online offering) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process the personal data of users with the aid of cookies depends on whether we ask users for their consent. If the user*s consent, the legal basis for the processing of your 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 management of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, 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 as part of our consent and processing procedures.

Storage duration: In terms of storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after the user has left an online offer and closed his end device (e.g. browser or mobile application).
  • 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 users visit 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 about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also 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:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be repeated and the consent can be proven 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. Here, a pseudonymous identifier is created for each person and stored with the time of consent, information about the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.

Performance of duties under the Articles of Association or the Rules of Procedure

We process the data of our members, supporters, interested parties, business partners or other persons (collectively “data subjects”) if we have a membership or other business relationship with them and perform our tasks and are recipients of services and benefits. In other respects, we process the data of data subjects on the basis of our legitimate interests, e.g. when administrative tasks or public relations work are involved.

The data processed in this context, the type, scope and purpose and the necessity of its processing, are determined by the underlying membership or contractual relationship, from which the necessity of any data disclosures also arise (in addition, we refer to required data).

We delete data that is no longer required to fulfill our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as they may be relevant for the processing of the business, as well as with regard to any warranty or liability obligations based on our legitimate interest in regulating them. The need to retain the data is reviewed regularly; in all other respects, the statutory retention obligations apply.

  • 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: Users (e.g. website visitors, users of online services); members; business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; administration and response to requests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

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 inquiries.

We process this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other performance disruptions. In addition, we process the data to safeguard our rights and for the purposes of the administrative tasks associated with these duties and the company organization. In addition, 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 scope 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 fulfill legal obligations. The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., basically after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons. The statutory retention period for documents relevant under tax law and for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins 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 financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting voucher 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 shall 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; pupils/ students/ participants; customers.
  • Purposes of processing: providing contractual services and customer service; contact requests and communication; office and organizational procedures; managing and responding to requests.
  • Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Education and Training Services: We process the data of participants in our education and training services (uniformly referred to as “trainees”) in order to provide our training services to them. The data processed in this context, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. In the course of our activities, we may also process special categories of data, in particular information on the health of students and trainees, as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. For this purpose, we obtain the explicit consent of the trainees, if required, and otherwise process the special categories of data only if it is necessary for the provision of the training services, for the purposes of preventive health care, social protection or the protection of vital interests of the trainees; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Business consulting: We process the data of our customers, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The processed data, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.If it is necessary for our contract performance or required by law, or if there is a consent of the customers, we disclose or transfer the data of customers in compliance with the professional requirements to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Payment method

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively, “payment service providers”).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is necessary to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the GTC and the data protection information of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, shall apply to the payment transactions. We also refer to these for further information and assertion of revocation, information and other data subject rights.

  • Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers; prospective customers; users (e.g., website visitors, users of online services); business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service; marketing; provision of our online offer and user experience.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • PayPal: payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service Provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.paypal.com/de; Privacy policy: https: //www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Steady: Internet platform for project financing via crowdfunding as well as the sale of subscriptions and memberships, billing and the provision of access and payment procedures, for the implementation of which cookies are used and the IP address, date, time and other technical data about the Internet browser used, the operating system as well as inventory, contract and payment data of the users are processed; Service provider: Steady Media GmbH, Schönhauser Allee 36, House 1 – Aufg. D, 10435 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://steadyhq.com/de/; Privacy policy: https: //steadyhq.com/de/privacy.
  • Patreon: Internet platform for project financing via crowdfunding as well as the sale of subscriptions and memberships, billing and the provision of access and payment procedures, for the implementation of which cookies are used and the IP address, date, time and other technical data about the Internet browser used, the operating system as well as inventory, contract and payment data of the users are processed; Service provider: Patreon Ireland Limited, German Branch Revaler Strasse 99, Hall 20, 2nd floor Rooms 3.19 and 3.25. 10245 Berlin-Friedrichshain, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.patreon.com/de-DE; Privacy policy: https: //privacy.patreon.com/policies.

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 equipment (computers, servers, etc.).); security measures; provision of contractual services and customer service.
  • 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).
  • Collection of access data and log files: Access to our online offer 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 retrieved, the date and time of the retrieval, data volumes transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
  • E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information concerning 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 SPAM detection purposes. We ask you to note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method 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).
  • Infomaniak: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Order processing contract: Provided by the service provider; Service provider: Infomaniak AG, 25 Eugène-Marziano, 1227 Les Acacias, GE, Switzerland; Website: https://www.infomaniak.com/de; Privacy Policy: https: //www.infomaniak.com/de/agb/datenschutzrichtlinien.
  • Friendly Captcha: Friendly Captcha is used to verify that data entered on our website (for example, on a login page or contact form) has been entered by a human or an automated program. For this purpose, Friendly Captcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with Friendly Captcha enabled. For the analysis Friendly Captcha evaluates various information (browser details, URL from which a user comes (referrer), information whether the user has solved a puzzle created by us, anonymized IP address with conversion to a numerical value, so-called hash value). This data cannot be assigned to specific websites or persons. Data processing is based on our legitimate interest in protecting our online offering from abusive automated crawling and spam; Service provider: Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hcaptcha.com/; Privacy Policy: https://friendlycaptcha.com/legal/; Order Processing Agreement: https://friendlycaptcha.com/legal/.

Contact and request 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 to the extent necessary to respond to the contact requests and any requested measures.

The answering of contact inquiries as well as the administration of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of legitimate interests in answering inquiries and maintaining user or business relationships.

  • 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 partners.
  • Purposes of processing: providing contractual services and customer service; contact requests and communication; managing and responding to requests; feedback (e.g., collecting feedback via online form); providing our online service and user experience.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) 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. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the requests and our statutory retention obligations; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Communication via messenger

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

You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not viewable, not even by the messenger providers themselves. You should always use an up-to-date version of messengers with encryption enabled to ensure that message content is encrypted.

However, we additionally point out to our communication partners that the providers of the messengers cannot view the content, but can learn that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

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, for example, on their own initiative, we use Messenger 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 in communication via Messenger. Furthermore, we would like to 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 a given consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, 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 provided by 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 would like to point out that, for reasons of your security, we reserve the right not to answer requests via Messenger. This is the case if, for example, contractual internals require special secrecy or a reply via Messenger does not meet formal requirements. In such cases, we refer you to more adequate communication channels.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Telegram Broadcasts: Telegram Broadcasts – Messenger with end-to-end encryption; Service provider: Telegram, Dubai; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //telegram.org/; Privacy policy: https: //telegram.org/privacy.

Promotional communication via e-mail, mail, 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, mail or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.

After revocation or objection, we store the data required to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest in permanently observing the user’s revocation or objection, we also store the data required to avoid contacting the user again (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 partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

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 in the process, user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, it could make it more difficult to enforce users’ rights.

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 behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within and outside the networks that presumably correspond to the users’ interests. 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 may also be stored in the usage profiles regardless 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 options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data in each case and can take appropriate measures and provide information directly. If you still need help, then 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.
  • 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 contract: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing the 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.
  • TikTok: Social network / video platform; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.tiktok.com; Privacy policy: https: //www.tiktok.com/de/privacy-policy.
  • 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, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; 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.

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the 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.

Where we provide addresses and contact information for companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information 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 Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is 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 obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the 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, or to request that it be transferred to another controller, in accordance with the law.
  • Complaint to 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

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

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Controller: a “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.