Privacy Policy

Effective Date: January 2, 2024

Table of Contents

  • Data Controller
  • Contact Data Protection Officer
  • Overview of Data Processing
  • Legal Bases for Processing
  • Security Measures
  • Transfer of Personal Data
  • Data Erasure
  • Rights of Data Subjects
  • Use of Cookies


Data Controller:

Mr. Bartosz Reinhold

Nephrolyx GmbH

Johann-Hittorf-Straße 8

12489 Berlin

Germany

Email Address: contact@nephrolyx.com

 

Contact Data Protection Officer

Data Protection Officer:

Email: datenschutz@nephrolyx.com

 

Overview of Data Processing

The following overview summarizes the types of data processed and the purposes of their processing, as well as the individuals affected.

Types of Processed Data:

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

 

Categories of Data Subjects:

  • Customers
  • Prospects
  • Communication partners
  • Users
  • Business and contract partners

 

Purposes of Processing:

  • Provision of contractual services and fulfillment of contractual obligations
  • Contact inquiries and communication
  • Security measures
  • Direct marketing
  • Range measurement
  • Tracking
  • Office and organizational procedures
  • Conversion measurement
  • Management and response to inquiries
  • Feedback
  • Marketing
  • Profiles with user-related information
  • Provision of our online services and user-friendliness
  • Information technology infrastructure


Legal Bases for Processing

Relevant legal bases under the GDPR: The following provides an overview of the legal bases for processing personal data under the GDPR. Please note that in addition to the GDPR, national data protection regulations may apply in your country of residence or establishment. In specific cases, more specific legal bases may also apply, which will be disclosed 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 a party or for the performance of pre-contractual measures requested by the data subject.
  • 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 a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data.

 

National data protection regulations in Germany: In addition to the GDPR, national data protection regulations apply in Germany. These include the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG), which contains special provisions on the right to access, 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. In addition, the data protection laws of individual federal states may apply.

Note on the applicability of GDPR and Swiss DPA: These data protection notices serve to inform you in accordance with both the Swiss Federal Data Protection Act (Swiss DPA) and the General Data Protection Regulation (GDPR). Therefore, please be aware that for the sake of broader geographic application and clarity, the terms and definitions used in the GDPR are employed. In particular, instead of the terms used in the Swiss DPA, such as “processing” of “personal data,” “legitimate interest,” and “special categories of personal data,” the GDPR terms “processing” of “personal data,” “legitimate interest,” and “special categories of data” are used. However, the legal significance of these terms continues to be determined in accordance with the Swiss DPA.

Security Measures

We implement appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs, the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risks to the rights and freedoms of natural persons, to ensure a level of security 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, disclosure, availability, and separation thereof. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the erasure of data, and responses to data threats. We also take data protection into account when developing or selecting hardware, software, and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.

IP Address Anonymization: If IP addresses are processed by us or our service providers and technologies, and the processing of a full IP address is not necessary, the IP address is shortened (also called “IP masking”). This means that the last two digits or the last part of the IP address after a period is removed or replaced with placeholders. The purpose of shortening the IP address is to prevent or significantly hinder the identification of a person based on their IP address.

TLS/SSL Encryption (https): To protect the data of users transmitted through our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.

 

Transfer of Personal Data

As part of our processing of personal data, it may be necessary to transfer data to other entities, companies, legally independent organizational units, or individuals or to disclose it to them. Recipients of this data may include service providers or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data Transfer within the Organization: We may transfer personal data to other units within our organization or grant them access to this data. If such transfer is carried out for administrative purposes, it is based on our legitimate business and operational interests or is carried out if it is necessary to fulfill our contractual obligations or if consent has been obtained from the data subjects or if there is a legal basis for the transfer.

 

Data Erasure

The data processed by us will be deleted in accordance with legal requirements as soon as the consents granted for processing are revoked or other permissions are no longer applicable (e.g., when the purpose of processing such data has ceased to exist or they are no longer required for that purpose). If data is not deleted because it is necessary for other legally permissible purposes, its processing will be restricted to those purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person. Our data protection information may also provide further details regarding the storage and erasure of data that primarily apply to specific processing activities.

 

 

Rights of Data Subjects

 

Rights of data subjects under the GDPR: As data subjects, you have various rights under the GDPR, particularly as set out in Articles 15 to 21 of the 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 that is based on Article 6(1)(e) or (f) of the GDPR, including profiling based on those provisions. If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw consent that you have given at any time.
  • Right to Information: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to request access to such data and additional information and a copy of the data in accordance with legal requirements.
  • Right to Rectification: You have the right, in accordance with legal requirements, to request the completion of your personal data or the rectification of inaccurate personal data concerning you.
  • Right to Erasure and Restriction of Processing: Subject to legal requirements, you have the right to request the immediate erasure of personal data concerning you or, alternatively, to request restriction of processing in accordance with legal requirements.
  • Right to Data Portability: You have the right to receive personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format and to request the transmission of that data to another controller, in accordance with legal requirements.
  • Complaint to 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 the place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

 

Use of Cookies

 

Cookies are small text files or other storage mechanisms that store information on end devices and retrieve information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the accessed content, or the functions used in an online offering. Cookies can also be used for various purposes, such as functionality, security, and the convenience of online offerings, as well as for creating analyses of visitor traffic.

Consent Information: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, except when it is not legally required. Consent is not necessary, in particular, when storing and retrieving information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e., our online offering) explicitly requested by them. Generally, essential cookies include cookies with functions related to displaying and running the online offering, load balancing, security, storing user preferences, and options, or similar purposes related to providing the main and ancillary functions of the online offering requested by users. Revocable consent is clearly communicated to users and includes information about the respective cookie usage.

Notes on Data Protection Legal Bases: The legal basis for processing users’ personal data using cookies depends on whether we request consent from users. If users consent, the legal basis for processing their data is the provided consent. Otherwise, the data processed using cookies are based on our legitimate interests (e.g., in the economical operation of our online offering and improving its usability) or, if the use of cookies is necessary to fulfill our contractual obligations, to fulfill those contractual obligations. We will inform users about the purposes for which we process cookies as part of this privacy policy or within our consent and processing processes.

Storage Duration: Regarding storage duration, the following types of cookies are distinguished:

  • Temporary Cookies (also: Session Cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their end device (e.g., browser or mobile application).
  • Permanent Cookies: Permanent cookies remain stored even after closing the end device. For example, login status can be stored, or preferred content can be displayed directly when the user revisits a website. Likewise, data collected using cookies can be used for measuring reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General Notes on Revocation and Objection (Opt-Out): Users can revoke their given consents at any time and object to the processing in accordance with legal requirements. For this purpose, users can restrict the use of cookies in their browser settings (although this may also limit the functionality of our online offering). 

Legal Bases: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR). Consent (Art. 6(1) sentence 1 lit. a) GDPR).

 

 

Further Information on Processing Procedures, Procedures, and Services:

Processing of Cookie Data Based on Consent: We use a cookie consent management process in which users’ consents to the use of cookies or the processing and providers mentioned in the context of the cookie consent management process can be obtained, managed, and revoked by users. The consent declaration is stored to avoid having to repeat the query and to be able to prove the consent in accordance with legal obligations. Storage can be done server-side and/or in a cookie (so-called opt-in cookie or similar technologies) to associate the consent with a user or their device. Subject to individual information provided by the providers of cookie management services, the following information applies: The storage duration of the consent can be up to two years. A pseudonymous user identifier is created, and 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, are stored; Legal basis: Consent (Art. 6(1) sentence 1 lit. a) GDPR).

 

Business Services

We process data of our contractual and business partners, such as customers and prospects (collectively referred to as “contractual partners”), as part of contractual and similar legal relationships, as well as associated measures and in the context of communication with contractual partners (or pre-contractual), for example, to respond to inquiries.

 

We process this data to fulfill our contractual obligations, which include, in particular, the obligations to provide the agreed-upon services, any obligations to update, and remedies for warranty and other performance disruptions. In addition, we process the data to safeguard our rights and for the purposes of administrative tasks associated with these obligations and corporate organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse, threats to 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). In accordance with applicable law, we only disclose data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of data processing, such as for marketing purposes, within the scope of this privacy policy.

We will delete the data after the expiration of statutory warranty and comparable obligations, i.e., in principle, after the expiration of 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons due to archiving. The legal retention period for records required under tax and commercial law is ten years, while the retention period for business letters received and sent is six years. The retention period begins at the end of the calendar year in which the entry was made, the inventory, opening balance sheet, annual financial statements, working instructions required to understand these documents, and other organizational documents and booking records were created, and when the commercial or business letter was received or sent, or when the booking record was created, and when the other documents were created.

If we use third-party providers or platforms to provide our services, the terms and privacy policies of the respective third-party providers or platforms apply in the relationship between users and the providers.

  • Processed data types: Inventory data (e.g., names, addresses); Payment data (e.g., bank account details, invoices, payment history); Contact data (e.g., email, phone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data subjects: Customers; Prospects; Business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer support; Security measures; Contact inquiries and communication; Office and organizational procedures; Management and response to inquiries; Conversion measurement (measuring the effectiveness of marketing measures); Profiling with user-related information (creating user profiles).
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

 

Additional information on processing procedures, procedures, and services:

  • Business analyses and market research: For business reasons and to understand market trends and the preferences of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. This analysis is carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, we may also consider the profiles of registered users along with their details, such as the services they have used. The analyses are for our own use only and are not disclosed externally, unless they are anonymous analyses with summarized, i.e., anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarized data); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Shop and e-commerce: We process our customers’ data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and delivery, or execution. If necessary for the fulfillment of an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required details are identified as such within the scope of the order, order, or similar conclusion of a contract, and include the information required for delivery, provision, and billing, as well as contact information for any queries that may arise; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).
  • Technical services: We process the data of our customers as well as contractors (hereinafter uniformly referred to as “customers”) to enable them to select, purchase, or order the selected services or works and related activities, as well as their payment and provision or execution. If necessary, we obtain access to information from end customers, employees, or other individuals and process this information in accordance with legal and contractual requirements; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).
  • Events and gatherings: We process the data of participants in events, gatherings, and similar activities offered or organized by us (hereinafter collectively referred to as “participants” and “events”) to enable their participation in the events and the utilization of services or activities associated with participation.
    Where we process health-related data, religious, political, or other special categories of data within this framework, it is done in accordance with the principle of transparency (e.g., for thematically oriented events, health and safety purposes, or with the consent of the data subjects).

The necessary information is marked as such within the framework of the order, booking, or similar contractual conclusion and includes the information required for service provision and billing, as well as contact information for any necessary communication. To the extent that we have access to information from end customers, employees, or other individuals, we process this information in accordance with legal and contractual requirements; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Providers and Services Used in the Course of Business Activities

In the course of our business activities, we use additional services, platforms, interfaces, or plugins from third-party providers (shortly referred to as “services”), while observing legal requirements.

  • Processed Data Types: Master Data (e.g., names, addresses); Payment Data (e.g., bank details, invoices, payment history); Contact Data (e.g., email, phone numbers); Content Data (e.g., entries in online forms); Contract Data (e.g., subject of the contract, term, customer category).
  • Data Subjects: Customers; Prospects; Users (e.g., website visitors)
  • Business and contractual partners.
  • Purposes of Processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

 

Provision of the Online Offering and Web Hosting

We process user data to provide our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functionality of our online services to the user’s browser or device.

  • Processed Data Types: Usage Data (e.g., visited websites, interest in content, access times); Meta, Communication, and Process Data (e.g., IP addresses, times of access, identification numbers, consent status); 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 offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

 

Additional Information on Processing Procedures, Procedures, and Services:

  • Provision of online services on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from an appropriate server provider (also called “web hoster”); Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the accessed websites and files, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the load and stability of the servers; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Data Deletion: Logfile information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident is finally clarified.
  • Email sending and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, recipient and sender addresses as well as further information regarding email transmission (e.g., the involved providers) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails on the Internet are generally not sent in encrypted form. In most cases, emails are encrypted during transport, but not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission of emails between the sender and our server; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • com: Hosting and software for the creation, provision, and operation of websites, blogs, and other online offerings; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF).

 

Blogs and Publishing Media

We utilize blogs or similar means of online communication and publication (hereinafter referred to as “publication medium”). User data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information on the processing of visitors to our publication medium, please refer to the information in these data protection notices.

  • Processed Data Types: Master Data (e.g., names, addresses); Contact Data (e.g., email, phone numbers); Content Data (e.g., entries in online forms); Usage Data (e.g., visited websites, interest in content, access times); Meta, Communication, and Process Data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Provision of contractual services and fulfillment of contractual obligations; Feedback (e.g., collecting feedback via online forms); Provision of our online offering and user-friendliness. Security measures.
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

 

Additional Information on Processing Procedures, Procedures, and Services:

  • Akismet Anti-Spam Check: Akismet Anti-Spam Check – We use the service “Akismet” based on our legitimate interests. Akismet helps distinguish between comments from real people and spam comments. For this purpose, all comment data is sent to a server in the USA, where it is analyzed and stored for comparison purposes for up to four days. If a comment is classified as spam, the data is stored beyond this period. This information includes the entered name, email address, IP address, comment content, referrer, information about the browser used, and the computer system, as well as the time of submission.Users are welcome to use pseudonyms or refrain from entering their name or email address. Users can prevent the transmission of data entirely by not using our comment system. That would be a pity, but unfortunately, we do not see any equally effective alternatives; Service Provider: Automattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy. Basis for transfer to third countries: EU-US Data Privacy Framework (DPF).

 

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, telephone, or via social media) and within the context of existing user and business relationships, the information of the inquiring individuals is processed as far as necessary to respond to the contact inquiries and any requested measures.

  • Processed Data Types: Contact Data (e.g., email, phone numbers); Content Data (e.g., entries in online forms); Usage Data (e.g., visited websites, interest in content, access times); Meta, Communication, and Process Data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data Subjects: Communication partners.
  • Purposes of Processing: Contact inquiries and communication; Management and response to inquiries; Feedback (e.g., collecting feedback via online forms). Provision of our online offering and user-friendliness.
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

 

Additional Information on Processing Procedures, Procedures, and Services:

  • Contact Form: When users contact us through our contact form, email, or other communication channels, we process the data provided to us in this context to handle the respective request; Legal Bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

 

Newsletter and Electronic Notifications

We only send newsletters, emails, and other electronic notifications (hereinafter “Newsletter”) with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described as part of the registration for the newsletter, they are decisive for the user’s consent. In addition, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personalized addressing in the newsletter or other information if necessary for the purposes of the newsletter.

Double Opt-In Procedure: The registration for our newsletter generally takes place in a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with someone else’s email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

Deletion and Restriction of Processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to prove a previously given consent. The processing of this data is limited to the purpose of potentially defending against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper conduct. If we engage a service provider for email delivery, this is done on the basis of our legitimate interests in an efficient and secure delivery system.

Contents:

Information about us, our services, promotions, and offers.

  • Processed Data Types: Master Data (e.g., names, addresses); Contact Data (e.g., email, phone numbers); Meta, Communication, and Process Data (e.g., IP addresses, timestamps, identification numbers, consent status); Usage Data (e.g., visited websites, interest in content, access times).
  • Data Subjects: Communication Partners.
  • Purposes of Processing: Direct Marketing (e.g., by email or postal mail).
  • Legal Bases: Consent (Art. 6(1)(a) GDPR). Legitimate Interests (Art. 6(1)(f) GDPR).
  • Opt-Out Option: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You can find a link to unsubscribe from the newsletter either at the end of each newsletter or can use one of the contact options listed above, preferably by email, for this purpose.

 

Additional Information about Processing Procedures, Procedures, and Services:

 

Promotional Communication via Email, Post, Fax, or Phone

We process personal data for the purpose of promotional communication, which can take place through various channels, such as email, telephone, post, or fax, in accordance with legal requirements.

Recipients have the right to revoke any granted consent at any time or to object to promotional communication at any time.

After revocation or objection, we store the data necessary for the proof of previous consent for contact or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of potentially defending against claims. Based on the legitimate interest of permanently considering the revocation or objection of users, we also store the data required to prevent further contact (e.g., email address, phone number, name, depending on the communication channel).

  • Processed Data Types: Master Data (e.g., names, addresses); Contact Data (e.g., email, phone numbers).
  • Data Subjects: Communication Partners.
  • Purposes of Processing: Direct Marketing (e.g., by email or postal mail).
  • Legal Bases: Consent (Art. 6(1)(a) GDPR). Legitimate Interests (Art. 6(1)(f) GDPR).

 

Web Analysis, Monitoring, and Optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate visitor traffic to 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, determine at what time our online offering or its functions or content are most frequently used or invite reuse. We can also track which areas need optimization.

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

Unless otherwise stated below, profiles may be created for these purposes, i.e., data summarized for a usage process, and information may be stored and read from it in a browser or on an end device. The information collected includes, in particular, visited websites and elements used there, as well as technical information such as the browser used, the operating system used, and information about 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.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, clear user data (such as email addresses or names) is not stored in the context of web analysis, A/B testing, and optimization, but pseudonyms are used. This means that we and the providers of the software used do not know the actual identity of users, but only the information stored in their profiles for the purposes of the respective procedures.

  • Processed Data Types: Usage Data (e.g., visited websites, interest in content, access times); Meta, Communication, and Process Data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Reach Measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles). Providing our online offering and user-friendliness.
  • Security Measures: IP Masking (Pseudonymization of IP Address).
  • Legal Bases: Consent (Art. 6(1)(a) GDPR). Legitimate Interests (Art. 6(1)(f) GDPR).

 

Additional Information about Processing Procedures, Procedures, and Services:

Google Optimize: Software for analyzing and optimizing online offerings based on feedback functions and pseudonymous measurements and analyses of user behavior, including A/B testing (measurement of the popularity and user-friendliness

Online Marketing

We process personal data for the purpose of online marketing, which includes marketing advertising spaces or displaying advertising and other content (collectively referred to as “content”) based on potential user interests and measuring their effectiveness.

For these purposes, user profiles are created and stored in a file (referred to as a “cookie”), or similar methods are used to store information relevant to the display of the aforementioned content. This information may include viewed content, visited websites, used online networks, as well as communication partners and technical details such as the user’s browser, computer system, usage times, and functions used. If users have consented to the collection of their location data, this data may also be processed.

IP addresses of users are also stored. However, we use IP masking techniques (i.e., pseudonymization by shortening the IP address) to protect users. In general, clear user data (such as email addresses or names) is not stored as part of the online marketing process, but pseudonyms are used. This means that neither we nor the providers of online marketing processes know the actual identity of users, only the information stored in their profiles.

The information in the profiles is typically stored in cookies or similar methods. These cookies can later be read, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing service provider on other websites that use the same online marketing process.

In exceptional cases, clear data may be associated with the profiles, such as when users are members of a social network that we use for online marketing, and the network connects users’ profiles with the provided information. Please note that users may have additional agreements with providers, such as providing consent during registration.

We generally only have access to aggregated information about the success of our advertisements. However, we can analyze which of our online marketing processes led to a conversion, such as a contract with us, as part of conversion tracking. Conversion tracking is solely used to analyze the success of our marketing measures.

Unless otherwise specified, please assume that cookies used are stored for a period of two years.

  • Processed data types: Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavioral profiling, use of cookies); Marketing; Profiles with user-related information (creation of user profiles); Conversion tracking (measurement of the effectiveness of marketing measures).
  • Security measures: IP masking (pseudonymization of IP addresses).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Opt-out options: We refer to the privacy policies of the respective providers and the opt-out options provided by them (so-called “opt-out”). If no explicit opt-out option is specified, it is possible to disable cookies in your browser settings. However, this may limit the functionality of our online offering. We recommend using the following opt-out options, which are summarized for each specific area:
  1. a) Europe: https://www.youronlinechoices.eu.
  2. b) Canada: https://www.youradchoices.ca/choices.
  3. c) USA: https://www.aboutads.info/choices.
  4. d) Cross-border: https://optout.aboutads.info.

 

Additional information about processing processes, procedures, and services:

  • Google Ads and Conversion Tracking: Online marketing processes for the placement of content and ads within the service provider’s advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are presumed to have an interest in the ads. In addition, we measure the conversion of ads, i.e., whether users have interacted with the ads and used the advertised offers (so-called conversion). 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 basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for the transfer of data to third countries: https://business.safety.google/adscontrollerterms.
  • LinkedIn Insights Tag: Code that is loaded when a user visits our online offering and tracks the user’s behavior and conversions, storing them in a profile (possible purposes: measuring campaign performance, optimizing ad delivery, creating custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR); 
  • Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Data processing agreement: https://legal.linkedin.com/dpa;

 

Plugins and Embedded Features, as well as 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 elements may include, for example, graphics, videos, or maps (collectively referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of users, as they could not send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only content whose respective providers use the IP address solely for content delivery. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic to the pages of this website. The pseudonymous information can also be stored in cookies on the users’ devices and may include technical information about the browser and operating system, referring websites, visit times, as well as further information about the use of our online offering and can also be linked with such information from other sources.

  • Processed data types: Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Marketing. Profiles with user-related information (creation of user profiles).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

 

Further information on processing procedures, methods, and services:

  • Google Fonts (provision on our own server): Provision of font files for the user-friendly presentation of our online offering; Service provider: Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • LinkedIn plugins and content: LinkedIn plugins and content – These may include content such as images, videos, or texts and buttons with which users can share content from this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Basis for third-country transfer: EU-US 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.

 

Management, Organization, and Tools

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

In this context, personal data may be processed and stored on the servers of third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes, and their contents.

If users are referred to the third-party providers or their software or platforms as part of communication, business, or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

  • Processed data types: Content data (e.g., entries in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data subjects: Communication partners; Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication; Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods, and services:

  • WeTransfer: Transfer of files over the internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wetransfer.com. Privacy Policy: https://wetransfer.com/legal/privacy.

Changes and Updates to the Privacy Policy

We kindly 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 your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we kindly ask you to note that the addresses may change over time, and we recommend checking the information before contacting them.

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