Preamble

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 privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offering”). Last updated: April 15, 2026

Table of Contents

Controller

Gudrun Hollensteiner Coookies Dorothea-Bernstein-Weg 5 22081 Hamburg Email address: gudrun@coookies.de Legal Notice: https://coookies.de/impressum/

Overview of Processing Activities

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of Data Processed

  • Inventory data.
  • Employee data.
  • Payment data.
  • Location data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Sweepstakes and competition participants.
  • Business and contractual partners.
  • Participants.
  • Third parties.
  • Whistleblowers.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Audience building.
  • Organizational and administrative procedures.
  • Conducting sweepstakes and competitions.
  • Feedback.
  • Surveys and questionnaires.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Whistleblower protection.
  • Public relations.
  • Business processes and business management procedures.

Relevant Legal Bases

Relevant legal bases under the 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 relevant in individual cases, we will inform you of these in the privacy policy.
  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests, fundamental rights, and freedoms of the data subject which require the protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific provisions regarding the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated individual decision-making including profiling. Furthermore, state data protection laws of the individual federal states may apply.

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, circumstances, and purposes of the processing, as well as the different likelihoods and severity of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk. These 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, input, transfer, availability assurance, and separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account from the outset of the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default. Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we rely on 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 more advanced and secure version of SSL, ensures that all data transmissions meet 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 for users that their data is being transmitted securely and in encrypted form.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that such data is transferred to or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, entities, or companies (which is evident from the postal address of the respective provider or when the privacy policy explicitly refers to data transfers 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 on July 10, 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers, which 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 an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected at all times, even in the event of 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 D The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of demonstrating its proper execution. Insofar as we commission a service provider with sending emails, this is done on the basis of our legitimate interests in an efficient and secure sending system. Contents: Information about us, our services, promotions, and offers.
  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). 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).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g., by email or postal mail).
  • Legal bases: Consent (Art. 6(1)(a) GDPR).
  • Opt-out option: You can cancel the receipt of our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter, or you can use one of the contact options listed above, preferably email, for this purpose.
Further information on processing operations, procedures, and services:
  • Measurement of open and click rates: The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from our server or, if we use a mailing service provider, from their server when the newsletter is opened. In the course of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval. This information is used for the technical improvement of our newsletter based on technical data or target groups and their reading behavior based on their retrieval locations. ; Legal bases: Consent (Art. 6(1)(a) GDPR).

Sweepstakes and Competitions

We process personal data of participants in sweepstakes and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, execution, and settlement of the sweepstake, the participants have consented to the processing, or the processing serves our legitimate interests (e.g., in the security of the sweepstake or the protection of our interests against misuse through possible collection of IP addresses when submitting sweepstake entries). If participants’ entries are published in the context of sweepstakes (e.g., as part of a vote or presentation of sweepstake entries or winners, or reporting on the sweepstake), we point out that the names of the participants may also be published in this context. Participants can object to this at any time. If the sweepstake takes place within an online platform or a social network (e.g., Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants in the context of the sweepstake and that inquiries regarding the sweepstake should be directed to us. Participants’ data will be deleted as soon as the sweepstake or competition has ended and the data is no longer required to inform the winners or because no further inquiries about the sweepstake are expected. As a general rule, participants’ data will be deleted no later than 6 months after the end of the sweepstake. Winners’ data may be retained longer in order to, for example, answer inquiries about prizes or fulfill prize obligations; in this case, the retention period depends on the type of prize and is, for example, up to three years for goods or services in order to handle warranty cases. Furthermore, participants’ data may be stored longer, e.g., in the form of reporting on the sweepstake in online and offline media. If data was also collected for other purposes in the context of the sweepstake, its processing and retention period are governed by the privacy notices for that use (e.g., in the case of newsletter registration in the context of a sweepstake).
  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or visual messages and posts as well as related information, such as information about authorship or time of creation).
  • Data subjects: Sweepstakes and competition participants.
  • Purposes of processing and legitimate interests: Conducting sweepstakes and competitions.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Surveys and Questionnaires

We conduct surveys and questionnaires to collect information for the respectively communicated survey or questionnaire purpose. The surveys and questionnaires we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the surveys (e.g., processing the IP address to display the survey in the user’s browser or using a cookie to enable the survey to be resumed).
  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or visual messages and posts as well as related information, such as information about 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).
  • Data subjects: Participants.
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form). Surveys and questionnaires (e.g., surveys with input options, multiple-choice questions).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:

Web Analytics, Monitoring and Optimization

Web analytics (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used, or invite reuse. Likewise, we can identify which areas require optimization. In addition to web analytics, we may also use testing procedures to test and optimize, for example, different versions of our online offering or its components. Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and then read out. 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 to us or to the providers of the services we use, location data may also be processed. In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear-text user data (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of users, but only the information stored in their profiles for the purposes of the respective procedures. Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
  • 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, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, detection of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It serves to assign analytics information to a device in order to identify what content users accessed within one or multiple usage sessions, what search terms they used, revisited, or interacted with in our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their 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 geographic 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 data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, not accessible, and not used for any further purposes. 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(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).

Online Marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of its effectiveness. For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”) or similar procedures are used to store information about the user that is relevant for the display of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information, such as the browser used, the computer system used, and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed. In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear-text user data (such as email addresses or names) is stored in the context of online marketing procedures, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual user identity, but only the information stored in their profiles. The information in the profiles is generally stored in cookies or by similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing procedure provider. In exceptional cases, it is possible to assign clear-text data to the profiles, primarily when users are, for example, members of a social network whose online marketing procedure we use and the network links user profiles with the aforementioned information. We ask you to note that users may enter into additional agreements with the providers, for example by giving consent during registration. We generally only receive access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely for the success analysis of our marketing measures. Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years. Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is the permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy. Notes on revocation and objection: We refer to the privacy notices of the respective providers and the objection options (so-called “opt-out”) indicated for the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered on a summary basis for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://youradchoices.ca/. c) USA: https://optout.aboutads.info/. d) Cross-regional: https://optout.aboutads.info.
  • 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, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, detection of returning visitors); Tracking (e.g., interest/behavior-based profiling, use of cookies); Audience building; Marketing; Profiles with user-related information (creation of user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
  • Google Ads and conversion measurement: Online marketing procedure for the purpose of placing content and advertisements within the advertising network of the service provider (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the advertisements, i.e., whether users used them as an occasion to interact with the advertisements and to use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and Standard Contractual Clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Customer Reviews and Rating Procedures

We participate in review and rating procedures to evaluate, optimize, and promote our services. If users rate us through the participating review platforms or procedures or otherwise provide feedback, the General Terms and Conditions or Terms of Use and the privacy notices of the providers also apply. As a rule, the review also requires registration with the respective providers. To ensure that the reviewing persons have actually used our services, we transmit, with the consent of customers, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or article number). This data is used solely to verify the authenticity of the user.
  • Types of data processed: Contract data (e.g., subject matter of the contract, 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, timestamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients. Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form). Marketing.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

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 users active there or to offer information about us. We point out that user data may be processed outside the European Union. This may entail risks for users because, for example, the enforcement of user rights could be made more difficult. Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. These may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of users. For these purposes, cookies are generally stored on users’ computers, in which the usage behavior and interests of users are stored. Furthermore, data may be stored in the usage profiles independently of the devices used by users (in particular if they are members of the respective platforms and are logged in). For a detailed description of the respective processing forms and the opt-out options, we refer to the privacy policies 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 latter have access to user data and can directly take appropriate measures and provide information. Should you nevertheless need assistance, you can contact us.
  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or visual messages and posts as well as related information, such as information about 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).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
  • Instagram: Social network, enables sharing of photos and videos, commenting and favoriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Facebook Pages: Profiles within the social network Facebook – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page (“fan page”). This includes, in particular, information about user behavior (e.g., content viewed or interacted with, actions taken) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations through the “Page Insights” service, which provide insight into how people interact with our page and its content. The basis for this is an agreement with Facebook (“Information about Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which, among other things, regulates security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct information or deletion requests directly to Facebook. The rights of users (in particular the right of access, deletion, objection, complaint to a supervisory authority) remain unaffected. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). For further processing, including any possible transfer to Meta Platforms Inc. in the USA, Meta Platforms Ireland Limited is solely responsible; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors that is used to create “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum,” https://legal.linkedin.com/pages-joint-controller-addendum), which specifies, in particular, what security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct information or deletion requests directly to LinkedIn). The rights of users (in particular the right of access, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of data is solely the responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Pinterest: Social network, enables sharing of photos, commenting, favoriting and curating posts, messaging, subscribing to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.pinterest.com. Privacy policy: https://policy.pinterest.com/de/privacy-policy.
  • Snapchat: Social network, enables sharing of photos and videos, commenting and favoriting posts, messaging, subscribing to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.snapchat.com/; Privacy policy: https://www.snap.com/de-DE/privacy/privacy-policy. Basis for third-country transfers: Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses).

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 may include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as “content”). The integration always requires that the third-party providers of this content process the IP address of users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required for the display of this content or functions. We endeavor to use only 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. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. 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, time of visit, and other information about the use of our online offering, as well as be linked with such information from other sources. Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is the permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
  • 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, timestamps, identification numbers, persons involved). Location data (information about the geographic position of a device or person).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures, and services:
  • Google Fonts (hosted on own server): Provision of font files for the purpose of a user-friendly presentation of our online offering; Service provider: The Google Fonts are hosted on our server; no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Google Maps: We integrate maps from the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
Data retention and deletion: Personal data is only processed for as long as is necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data we process. This data is processed exclusively for the defined purposes.
  • Types of data processed: Inventory data (e.g., full name, residential address, contact information); Employee data (information about employees and other persons in an employment relationship); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or visual messages and posts as well as related information, such as information about authorship); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used)
  • Data subjects: Employees (e.g., employees, applicants, temporary workers); Third parties. Whistleblowers.
  • Purposes of processing and legitimate interests: Whistleblower protection.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Consent (Art. 6(1)(a) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Changes and Updates

We ask you to regularly inform yourself 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 addresses may change over time and please verify the information before contacting.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.
  • Employees: Employees refers to persons who are in an employment relationship, whether as workers, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It involves the obligation of the employer to pay remuneration to the employee while the employee performs their work. The employment relationship encompasses various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee carries out their work activities, and the termination, when the employment relationship ends, whether through notice, termination agreement, or otherwise. Employee data is all information that relates to these persons and is in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, vacation entitlements, health data, and performance evaluations.
  • Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email 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 unique assignment and communication.
  • Content data: Content data comprises information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure used to determine the effectiveness of marketing measures. As a rule, a cookie is stored on the devices of users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the advertisements we placed on other websites were successful.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the manner in which data is processed, transmitted, and managed. Meta data, also known as data about data, comprises information that describes the context, origin, and structure of other data. It may include information about file size, creation date, author of a document, and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and verification of operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information that shows how users use applications, which functions they prefer, how long they spend on certain pages, and which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information,” or “profiles” for short, encompasses any form of automated processing of personal data consisting of the use of such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This allows them to, for example, better adapt the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Location data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a cell tower, a Wi-Fi network, or similar technical means and functions for location determination. Location data serves to indicate the geographically determinable position on earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
  • Tracking: “Tracking” refers to the ability to trace user behavior across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the tracking technology providers (so-called profiling) with regard to the online offerings used. This information can subsequently be used, for example, to display advertisements to users that presumably correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, be it collection, evaluation, storage, transmission, or deletion.
  • Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This data category is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of agreed services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
  • Payment data: Payment data comprises all information required for the processing of payment transactions between buyers and sellers. This data is of crucial importance for electronic commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and billing information. Payment data may also contain information about payment status, chargebacks, authorizations, and fees.
  • Audience building: Audience building (also known as “Custom Audiences”) refers to the determination of target groups for advertising purposes, e.g., the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. “Lookalike Audiences” (or similar audiences) refers to the display of content deemed suitable to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.

Created with the free privacy policy generator by Dr. Thomas Schwenke

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