Data Protection

1. Basic Information on Data Processing and Legal Bases

1.1. This privacy policy informs you about the nature, scope, and purpose of the processing of personal data within our online offering and the associated websites, functions, and content (hereinafter collectively referred to as “online offering” or “website”). The privacy policy applies regardless of the domains, systems, platforms, and devices (e.g., desktop or mobile) on which the online offering is executed.

1.2. The terms used, such as “personal data” or their “processing”, refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

2. Types of Processed Data / Categories of Data Subjects

2.1. The personal data of users processed within the scope of this online offering include:

• Inventory data (e.g., names and addresses of customers),
• Contact data (e.g., email, phone numbers),
• Communication data,
• Contract data (e.g., services used, names of contact persons, payment information),
• Usage data (e.g., websites visited on our online offering, interest in our products)
• Meta/communication data (e.g., device information, IP addresses) and
• Content data (e.g., entries in the contact form).

2.2. The term “user” encompasses all categories of persons affected by data processing. These include our business partners, customers, interested parties, and other visitors to our online offering. The terms used are to be understood as gender-neutral.

2.3. We process personal data of users only in compliance with the relevant data protection regulations. This means that user data is only processed when there is legal permission, in particular when data processing is necessary for the provision of our contractual services (e.g., processing of orders) and online services, is legally required, user consent has been obtained, as well as based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation and security of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR, especially in reach measurement, creation of profiles for advertising and marketing purposes, as well as collection of access data and use of third-party services.

2.4. We point out that the legal basis for consent is Art. 6 Para. 1 lit. a. and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures is Art. 6 Para. 1 lit. b. GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c. GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 Para. 1 lit. f. GDPR.

2.5. The following persons are affected by data processing:

• Contract and business partners,
• Users of our online offering,
• Interested parties who are interested in our online offering or contact us for other reasons and
• Customers.

3. Security Measures

In accordance with Art. 32 GDPR, we take appropriate organizational, contractual, and technical security measures in line with the state of the art, taking into account implementation costs and the nature, scope, circumstances, and purposes of data processing, as well as the varying likelihood and severity of the risk to rights and freedoms, to ensure an appropriate level of protection for your data. This ensures compliance with data protection laws and protects this data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

3.1. Security measures include, in particular, the encrypted transmission of data between your browser and our server. You can recognize such encrypted connections by the URL in your browser’s address bar beginning with “https://”. This is a communication protocol that allows data to be transmitted securely as part of transport encryption.

4. Transfer of Data to Third Parties and Third-Party Providers

4.1. Data is only transferred to third parties within the framework of legal requirements. We only pass on user data to third parties if this is necessary for contractual purposes, for example, on the basis of Art. 6 Para. 1 lit. b GDPR, or on the basis of legitimate interests pursuant to Art. 6 Para. 1 lit. f. GDPR in the economic and effective operation of our business.

4.2. We only use subcontractors to provide our services if we have taken appropriate legal precautions as well as corresponding technical and organizational measures to ensure the protection of processed personal data in accordance with the relevant legal regulations.

4.3. If content, tools, or other means described in this privacy policy are used by other providers (hereinafter collectively referred to as ‘third-party providers’), we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

4.4. If we use a third-party provider whose registered office is located in a third country (outside the European Union (EU) or the European Economic Area), it can be assumed that data transfer to the countries where the third-party provider is based takes place. Data transfer to third countries only occurs if an adequate level of data protection, user consent, or other legal permission exists.

5. Provision of Contractual Services

5.1. We process inventory data (e.g., names and addresses as well as contact details of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 Para. 1 lit b. GDPR. We inform contract partners about which data are required for the aforementioned purposes before or during data collection, e.g., in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks or similar), or in person. Within the scope of applicable law, we only pass on this data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations, or with your consent (e.g., to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).

5.2. We delete the data after expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal reasons of archiving (e.g., for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner within the scope of a contractual relationship in accordance with the specifications of the contract, generally after fulfillment of the contractual services.

6. Contact

6.1. When contacting us (via contact form or email), the user’s information is processed for handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b GDPR. In doing so, we only process the data we need to handle your request.

6.2. Users’ information can be stored in our Customer Relationship Management System (‘CRM System’) or comparable inquiry organization.

7. Web Hosting

7.1. In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

7.2. Based on our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

7.3. Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is necessary for evidential purposes is exempt from deletion until the respective incident is finally clarified.

7.4. The web hosting services also include sending, receiving and storing emails. For these purposes, the addresses of recipients and senders, as well as other information regarding email sending (e.g., the providers involved), including the contents of the respective emails, are processed. Although our email communication has transport encryption, these are not encrypted on the servers from which they are sent and received. The content of email communication is therefore generally susceptible to manipulation.

8. Cookies Reach Measurement

8.1. When you visit our website, information may be stored on your computer in the form of a cookie. Cookies are pieces of information transferred from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Most browsers are set to accept cookies automatically. We would like to point out that using our online offer without cookies is only possible to a limited extent. In particular, the use of your customer account is generally not possible, as cookies are technically necessary for this. However, you can also use your browser to prevent only certain cookies from being set (e.g., third-party cookies), for example if you want to prevent web tracking. You can find more information on this in your browser’s help function. Further information on third-party cookies that are set or processed when visiting our website can be found in the following privacy policy, if we use them. We also include other technologies that fulfill the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as ‘User ID’) in the term cookies.

• A distinction must be made between cookies that are set by the website operator when visiting a website (also called ‘first-party cookies’) and cookies that are set by third parties (also called ‘third-party cookies’). We only have technical control over the former. We further differentiate between the following cookies.
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their browser.
• Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users, which are used for reach measurement or marketing purposes, can also be stored in such a cookie.
• Necessary (also: essential or strictly necessary) cookies: On the one hand, cookies can be absolutely necessary for the operation of a website (e.g., to store logins or other user inputs or for security reasons).
• Statistics, marketing, and personalization cookies: Furthermore, cookies are usually also used in the context of reach measurement and when a user’s interests or behavior (e.g., viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as ‘tracking’, i.e., tracking the potential interests of users. We inform you separately about the use of ‘tracking’ technologies in our privacy policy or in the context of obtaining consent.

8.2. We use ‘session cookies’ that are only stored for the duration of the current visit to our online presence (e.g., to enable the storage of your login status or the shopping cart function and thus make the use of our online offer possible at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and, for example, log out or close the browser.

8.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser.

8.4. The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the economic operation of our online offer and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.

Depending on whether the processing is based on consent or legal permission, you have the option to withdraw your given consent or object to the processing of your data through cookie technologies (‘Opt-Out’) at any time. You can initially declare your opt-out through your browser settings by objecting to the setting of cookies in your browser’s system settings. An objection to the use of cookies for online marketing purposes can also be declared through a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. Additionally, you can receive further objection notices within the information on the service providers and cookies used.

Before we process or allow data to be processed in the context of using cookies, we ask users for revocable consent. Before consent is given, only cookies that are necessary for the operation of our online service are used. Their use is based on our interest and the users’ interest in the expected functionality of our online service. This includes usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Users of our online service are affected by this processing. The processing is carried out on the legal basis of consent (Art. 6 Para. 1 S. 1 lit. a GDPR) or legitimate interests pursuant to Art. 6 Para. 1 S. 1 lit. f. GDPR.

9. Integration of Videos

9.1. We use videos to display the submitted contributions. Since local hosting of videos is not efficient enough, we occasionally rely on external video providers. In this case, we use the services of Vimeo, Inc., West 18th Street, New York 10011, USA (‘Vimeo’).

9.2. By integrating the videos, the provider’s servers are accessed. For the associated use of data, we refer to the respective privacy policies of the provider. Vimeo’s privacy policy can be accessed via the following link: https://vimeo.com/privacy.

9.3. The legal basis for the integration of videos and the associated transfer of personal data is Art. 6 Para. 1 lit. b GDPR for registered users of our service. The integration is necessary because currently no comparable video solution is available to provide protected videos.

9.4. For non-registered users, the legal basis for the transfer of personal data is Art. 6 Para. 1 lit f. GDPR.

9.5. To ensure an adequate level of data protection when transferring data to the USA, we have concluded the so-called standard contractual clauses with the provider of Vimeo. As an additional protective measure, we generally embed videos in the ‘Do Not Track’ variant, so that the scope of transferred personal data is reduced to a minimum.

9.6. Alternatively, we may also use the service provider YouTube. Videos from the ‘YouTube’ platform of the third-party provider Google are embedded in our website but continue to be hosted on the YouTube platform. When the video is played, a connection is established with YouTube. The privacy policy can be accessed here: https://www.google.com/policies/privacy/ and an opt-out can be found here: https://www.google.com/settings/ads/. With Google, we have

10. Integration of Third-Party Services and Content

10.1. Based on our legitimate interests (i.e., interest in analyzing, optimizing, and economically operating our online services in accordance with Art. 6 Para. 1 lit. f. GDPR) or based on your consent (Art. 6 Para. 1 lit. a GDPR), we use content or service offerings from third-party providers within our online services to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This is done to provide our online services and to create user-friendliness for our online offerings. This always presupposes that the third-party providers of this content perceive the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to 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 third-party cookies on the user’s device and may contain technical information about the browser and operating system, referring websites, visit time, and other details about the use of our online offering, as well as being linked with such information from other sources.

10.2. The following overview provides information about third-party providers and their content, along with links to their privacy policies, which contain further information on data processing and, in some cases already mentioned here, opt-out options:

• If our customers use third-party payment services (e.g., PayPal or Sofortüberweisung), the terms and conditions and privacy notices of the respective third-party providers apply, which can be accessed within the respective websites or transaction applications.
• External fonts from Google Ireland., https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts is done through a server call to Google (usually in the USA). Privacy Policy: https://www.google.com/policies/privacy/. You can find an opt-out here https://www.google.com/settings/ads/.
• Maps from the “Google Maps” service provided by the third-party provider Google. The privacy policy can be found here: https://www.google.com/policies/privacy/. You can find an opt-out option here: https://www.google.com/settings/ads/
• Our online offerings use functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Every time one of our pages containing LinkedIn features is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click the LinkedIn “Recommend Button” and are logged into your LinkedIn account, it is possible for LinkedIn to associate your visit to our website with you and your user account. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. The privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy and an opt-out is available here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Functions of the Twitter service may be integrated within our online offering. These functions are offered by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. In the process, data is also transferred to Twitter. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Twitter. Twitter’s privacy policy can be found at http://twitter.com/privacy. You can change your privacy settings on Twitter in the account settings at http://twitter.com/account/settins.
• We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time one of our pages containing XING functions is accessed, a connection to XING servers is established. To our knowledge, no personal data is stored in this process. In particular, no IP addresses are stored or usage behavior is analyzed. Privacy policy: https://www.xing.com/app/share?op=data_protection.

11. Rights of the Data Subject

If personal data concerning you is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

11.1. Right to Information
You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request the following information from the controller:

• The purposes for which the personal data is being processed;
• The categories of personal data being processed;
• The recipients or categories of recipients to whom your personal data has been or will be disclosed;
• The planned duration of storage of your personal data or, if specific information is not possible, criteria for determining the storage duration;
• The existence of a right to rectification or erasure of your personal data, a right to restriction of processing by the controller, or a right to object to such processing;
• The existence of a right to lodge a complaint with a supervisory authority;
• All available information on the source of the data, if the personal data is not collected from the data subject;
• The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information about whether your personal data is transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate safeguards pursuant to Article 46 GDPR in connection with the transfer.

11.2. Right to Rectification
You have the right to rectification and/or completion from the controller, if the processed personal data concerning you is inaccurate or incomplete. The controller must make the correction without delay.

11.3. Right to Restriction of Processing
Under the following conditions, you can request the restriction of processing of your personal data:

• If you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
• The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• The controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims, or
• If you have objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds.

Where processing of your personal data has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

11.4. Right to Erasure
a) Obligation to erase
You can request from the controller that your personal data be erased without undue delay, and the controller is obliged to erase this data without undue delay where one of the following grounds applies:

• The personal data concerning you is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a) GDPR, and where there is no other legal ground for the processing.
• You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
• The personal data concerning you has been unlawfully processed.
• The personal data concerning you has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data concerning you was collected in relation to offered services of the information society according to Art. 8 Para. 1 GDPR.

b) Information to Third Parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 Para. 1 GDPR, it shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform controllers who are processing the personal data that you as the data subject have requested the erasure of all links to, or copies or replications of, those personal data.

c) Exceptions
The right to erasure does not exist to the extent that processing is necessary

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health in accordance with Art. 9 Para. 2 lit. h and i as well as Art. 9 Para. 3 GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 Para. 1 GDPR insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
• for the establishment, exercise or defense of legal claims.

11.5. Right to Notification
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the latter is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right to be informed about these recipients by the controller.

11.6. Right to Data Portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where

• the processing is based on consent pursuant to Art. 6 Para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR or on a contract pursuant to Art. 6 Para. 1 lit. b GDPR and
• the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This shall not adversely affect the rights and freedoms of others.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

11.7. Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 Para. 1 lit. e or f GDPR, including profiling based on those provisions.

The controller shall no longer process the personal data concerning you unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

11.8. Right to Withdraw Data Protection Consent
You have the right to withdraw your data protection consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

11.9. Automated Individual Decision-Making, Including Profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• is necessary for entering into, or performance of, a contract between you and the data controller,
• is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
• is based on your explicit consent.

However, these decisions must not be based on special categories of personal data referred to in Article 9(1) of the GDPR unless Article 9(2)(a) or (g) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in points (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

11.10. Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.

12. Deletion of Data

12.1. The data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations preventing its deletion. In particular, deletion will also occur when other legal grounds for permission cease to apply. If users’ data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax reasons.

12.2. According to legal requirements, data is retained for 6 years pursuant to § 257 (1) of the German Commercial Code (HGB) (accounting books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years pursuant to § 147 (1) of the German Fiscal Code (AO) (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).

13. Right to Object

Users may object to the future processing of their personal data in accordance with legal requirements at any time. The objection may in particular be made against processing for direct marketing purposes.

14. Changes to the Privacy Policy

14.1. We reserve the right to change the privacy policy to adapt it to changed legal situations, or in the event of changes to the service or data processing. This applies, however, only with regard to declarations on data processing. If user consents are required or components of the privacy policy contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.

14.2. Users are requested to inform themselves regularly about the content of the privacy policy.