Data protection
Preamble
With the following privacy policy, we would like to inform you about what types of personal data (hereinafter also referred to as "data") 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").
The terms used are not gender-specific.
As of: July 24, 2025
Table of contents
- Preamble
- Responsible
- Contact Data protection officer
- Overview of processing
- Relevant legal basis
- Security
- Transfer of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Business processes and procedures
- Providers and services used in the course of business
- Provision of online services and web hosting
- Use of cookies
- Contact and inquiry management
- Artificial intelligence (AI)
- Video conferencing, online meetings, webinars, and screen sharing
- Cloud services
- Advertising communication via email, post, fax, or telephone
- Surveys and questionnaires
- Presence on social networks (social media)
- Plug-ins and embedded functions and content
- Management, organization, and support tools
- Processing of data within the scope of employment relationships
- Application procedures
- Data protection information for whistleblowers
- Changes and updates
- Definition of terms
Responsible
KOHL Group AG
Wankelstraße 7
50996 Cologne
Email address:
Legal notice:
www.kohl-gruppe-ag.de
Contact Data Protection Officer
Kompass Datenschutz GmbH
Jan Besold
Email:
Phone: 02233 / 6290596
Mobile: 01575/ 2623224
Overview of Processing
The following overview summarizes the types of data processed and the purposes for which they are processed, and refers to the data subjects.
Types of Data Processed
- Inventory data
- Employee data
- Payment data
- Contact data
- Content data
- Contract data
- Usage data
- Meta, communication, and procedural data
- Applicant data
- Image and/or video recordings
- Audio recordings
- Log data
Categories of Data Subjects
- Service recipients and clients
- Employees
- Prospective customers
- Communication partners
- Users
- Applicants
- Business and contractual partners
- Participants
- Depicted persons
- Third parties
- Whistleblowers
- Customers
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations
- Communication
- Security measures
- Direct marketing
- Office and organizational procedures
- Organizational and administrative procedures
- Application procedures
- Feedback
- Surveys and questionnaires
- Marketing
- Provision of our online services and user-friendliness
- Establishment and implementation of employment relationships
- Information technology infrastructure
- Whistleblower protection
- Financial and payment management
- Public relations
- Sales promotion
- Business processes and business management procedures
- Artificial intelligence (AI)
Relevant Legal Basis
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 registered office. If more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes.
- Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
- Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severe disability or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labor law and social security and social protection law and fulfill their obligations in this regard, their processing shall be carried out in accordance with Art. 9 (2) lit. b GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c GDPR or for the purposes of health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2) lit. h GDPR. In the case of disclosure of special categories of data based on voluntary consent, processing is carried out on the basis of Art. 9 (2) lit. a GDPR.
- Processing of special categories of personal data relating to health, professional activities, and social security (Art. 9 para. 2 lit. h GDPR) – Processing is necessary for the purposes of health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, care or treatment in the health or social sector, or for the management of systems and services in the health or social sector on the basis of Union law or the law of a Member State or on the basis of a contract with a member of a health profession.
National Data Protection Regulations in Germany
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
National Data Protection Regulations in Poland
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Poland. These include, in particular, the "Data Protection Act" (Ustawa z dnia 10 maja 2018 r. ochronie danych osobowych).
Reference to the Applicability of the GDPR and the Swiss DSG
This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "sensitive personal data" used in the Swiss DSG, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DSG within the scope of its applicability.
Security
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, in accordance with legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the likelihood and severity of the risk to the rights and freedoms of natural persons.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, input, transfer, and backup of the data and ensuring their separation. Furthermore, we have established procedures to ensure that data subjects can exercise their rights, that data is deleted, and that responses are provided in the event of a threat to the data. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software, and procedures in accordance with the principle of data protection, through technical design and data protection-friendly default settings.
Shortening of the IP Address
If IP addresses are processed by us or by the service providers and technologies we use and the processing of a complete IP address is not necessary, the IP address is shortened (also known as "IP masking"). In this case, the last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or significantly impede the identification of a person based on their IP address.
Securing Online Connections Using TLS/SSL Encryption Technology (HTTPS)
We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. 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), 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 to users that their data is being transmitted securely and encrypted.
Transfer of Personal Data
In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure that your data is protected.
Data Transfer Within the Organization
We may transfer personal data to other departments or units within our organization or grant them access to it. If the data is transferred for administrative purposes, this is based on our legitimate business and economic interests or is necessary to fulfill our contractual obligations or if the consent of the data subjects or legal permission has been obtained.
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 connection with the use of third-party services or the disclosure or transfer of data to other persons, agencies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.
Data Transfers to the USA
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 that comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This double safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses will serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.
We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place.
Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce:
https://www.dataprivacyframework.gov/
Transfers to Other Third Countries
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consent,
or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found on the website of the EU Commission:
EU Commission – International dimension of data protection
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent is revoked or there is no longer any legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our privacy policy contains additional information on the storage and deletion of data that applies specifically to certain processing operations.
If there are several specifications regarding the storage period or deletion deadlines for a piece of data, the longest period shall always apply. Data that is no longer required for the originally intended purpose but is retained due to legal requirements or other reasons will only be processed by us for the reasons that justify its retention.
Storage and Deletion of Data (Germany)
The following general periods apply to storage and archiving in accordance with German law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the work instructions and other organizational documents necessary for their understanding (§ 147 (1) No. 1 in conjunction with (3) AO, § 14b para. 1 UStG, § 257 para. 1 No. 1 in conjunction with para. 4 HGB).
- 8 years – Accounting documents, such as invoices and expense receipts (§ 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO, § 257 (1) No. 4 in conjunction with (4) HGB).
- 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, and other documents relevant for taxation (e.g., hourly wage slips, operating statements, calculation documents, price labels, payroll accounting documents, cash register receipts) (§ 147 (1) No. 2, 3, 5 in conjunction with (3) AO, § 257 (1) No. 2 and 3 in conjunction with (4) HGB).
- 3 years – Data necessary to consider potential warranty and damage claims or similar contractual claims and rights, including related inquiries, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the statutory provisions.
- Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request that the processing of the data be restricted.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller in accordance with legal requirements.
- Complaint to a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your workplace or the place of the alleged infringement, if you believe that the processing of personal data relating to you violates the GDPR.
Business Services
We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as "contractual partners"), within the scope of contractual and comparable legal relationships and associated measures and with regard to communication with contractual partners (or pre-contractually), for example to respond to inquiries.
We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations, and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for administrative tasks associated with these obligations and for company organization.
We also process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities).
Within the scope of applicable law, we only pass on the 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 other forms of processing, such as for marketing purposes, within the scope of this privacy policy.
We will inform contractual partners of the data required for the aforementioned purposes before or during data collection, e.g., in online forms, by means of special markings (e.g., colors) or symbols (e.g., asterisks or similar), or in person.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. for as long as it must be retained for archiving purposes for legal reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order.
Types of Data Processed
- Inventory data (e.g., full name, residential address, contact information, customer number, etc.)
- Payment data (e.g., bank details, invoices, payment history)
- Contact data (e.g., postal and email addresses or telephone numbers)
- Contract data (e.g., subject matter of the contract, term, customer category)
Data Subjects
- Service recipients and clients
- Interested parties
- Business and contractual partners
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations
- Communication
- Office and organizational procedures
- Business processes and business management procedures
Storage and Deletion
Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal Basis
- Contract fulfillment 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)
Further Information on Processing Processes, Procedures, and Services
Technical Services
We process the data of our customers and clients (hereinafter referred to uniformly as "customers") in order to enable them to select, purchase, or commission the selected services or works and related activities, as well as to enable payment and provision or execution or performance thereof.
The necessary information is identified as such in the context of the order, purchase order, or comparable contract and includes the information required for the provision of services and billing, as well as contact information to enable any necessary consultation.
Insofar as we gain access to information from end customers, employees, or other persons, we process this in accordance with the statutory and contractual requirements.
Legal basis: fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Business Processes and Procedures
Personal data of service recipients and clients – including customers, clients or, in special cases, patients or business partners and other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.
The data collected is used to fulfill contractual obligations and to organize operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies, and the assurance of internal billing and financial processes. In addition, the data supports the protection of the rights of the controller and facilitates administrative tasks and the organization of the company.
Personal data may be passed on to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. The data will be deleted after the expiry of the statutory retention periods or when the purpose of processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.
Types of Data Processed
- Inventory data (e.g., full name, residential address, contact information, customer number, etc.)
- Payment data data (e.g., bank details, invoices, payment history)
- Contact data (e.g., postal and email addresses or telephone numbers)
- Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation)
- Contract data (e.g., subject matter of the contract, term, 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 process data (e.g., IP addresses, time stamps, identification numbers, persons involved)
- Log data (e.g., log files relating to logins or the retrieval of data or access times)
- Employee data (information about employees and other persons in an employment relationship)
Data Subjects
- Service recipients and clients
- Interested parties
- Communication partners
- Business and contractual partners
- Customers
- Third parties
- Users (e.g., website visitors, users of online services)
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations
- Office and organizational procedures
- Business processes and business management procedures
- Communication
- Marketing
- Sales promotion
- Public relations
- Financial and payment management
- Security measures
- Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.))
Storage and Deletion
Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal Basis
- Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR)
Further Information on Processing Operations
- Customer Management and CRM: Procedures required in the context of customer management and customer relationship management (CRM) (e.g., customer acquisition in compliance with data protection requirements, measures to promote customer loyalty and retention, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support customer relations, administration of CRM systems, secure account management, customer segmentation and target group formation); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Contact management and maintenance: Procedures necessary for the organization, maintenance, and securing of contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adjusting contact strategies); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Customer loyalty program/customer card: As part of the customer loyalty program, the controller processes the data of participating customers for the purpose of providing the services offered under this program. For this purpose, the controller stores the information provided by customers, to the extent necessary and identified as such, in a customer profile. This profile also contains information about the use of the customer loyalty program and the use of the associated services and benefits. This information is only passed on to third parties (e.g., service providers) if this is necessary for the purposes mentioned. Customer profiles are deleted after participation in the program has ended. The respective data will only be archived to the extent that this may be necessary for legal storage purposes or for the fulfillment of legal (up to eleven years for tax information from the end of the year in which it was created) or contractual claims (up to three years from the end of the year of termination). This is recorded in the directory of processing activities; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- General payment Transactions: Procedures necessary for the execution of payment transactions, the monitoring of bank accounts, and the control of payment flows (e.g., creation and verification of transfers, processing of direct debits, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of reminders, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract fulfillment 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).
- Financial accounting and taxes: Procedures that are necessary for the recording, management, and control of financially relevant business transactions, as well as for the calculation, reporting and payment of taxes (e.g., account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning, account reconciliation, tax advice, preparation and submission of tax returns, handling of tax matters); Legal basis: Contract fulfillment 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).
- Purchasing: Procedures necessary for the procurement of goods, raw materials, or services (e.g., supplier selection and evaluation, price negotiations, order placement and monitoring, verification and control of deliveries, invoice verification, order management, warehouse management, creation and maintenance of purchasing guidelines); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Sales: Processes necessary for planning, implementing, and monitoring measures for marketing and selling products or services (e.g., customer acquisition, preparing and following up on offers, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- arketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Economic analyses and market research: The data available on business transactions, contracts, enquiries, etc. is analysed for business purposes and to identify market trends and the wishes of contractual partners and users. The group of data subjects may include contractual partners, interested parties, customers, visitors and users of the controller's online offering. The analyses are carried out for the purposes of business evaluation, marketing, and market research (e.g., to determine customer groups with different characteristics). Where available, profiles of registered users, including their details on the services they have used, are taken into account. The analyses are used exclusively by the controller and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized values. In addition, the privacy of users is respected; the data is pseudonymized for analysis purposes and, where feasible, anonymized (e.g., as aggregated data); Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Public relations:Procedures required in the context of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, preparation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, corporate branding support); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Guest Wi-Fi:Procedures necessary for the setup, operation, maintenance, and monitoring of a wireless network for guests (e.g., installation and configuration of Wi-Fi access points, creation and management of guest accounts, monitoring of network connection, ensuring network security, troubleshooting connection problems, updating network software, compliance with data protection regulations); Legal basis: Contract fulfillment 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).
Providers and Services Used in the Course of Business
Within the scope of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter referred to as "services") in compliance with legal requirements. Their use is based on our interests in the proper, lawful, and economical management of our business operations and internal organization.
Types of Data Processed
- Inventory data (e.g., full name, residential address, contact information, customer number, etc.)
- Payment data (e.g., bank details, invoices, payment history)
- Contact data (e.g., postal and email addresses or telephone numbers)
- Content data (e.g., textual or pictorial messages and posts, and related metadata)
- Contract data (e.g., subject matter of the contract, term, customer category)
Data Subjects
- Service recipients and clients
- Interested parties
- Business and contractual partners
- Employees (e.g., employees, applicants, temporary staff, and other personnel)
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations
- Office and organizational procedures
- Business processes and business management procedures
Storage and Deletion
Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal Basis
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further Information on Processing Operations, Procedures, and Services
-
DATEV: Software for accounting, communication with tax advisors and authorities, and document storage;
Service provider: DATEV eG, Paumgartnerstr. 6 - 14, 90429 Nuremberg, Germany;
Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR);
Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/;
Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/;
Order processing agreement: Provided by the service provider.
Provision of the online offer and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
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. Provision of contractual services and fulfillment of contractual obligations.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures, and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from an appropriate server provider (also known as a "web host"); Legal basis: 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." The server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the event of malicious attacks, known as DDoS attacks), and to ensure server capacity and stability; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- 1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/vereinbarung-zur-auftragsverarbeitung-avv-mit-ionos-abschliessen/.
Use of Cookies
The term "cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online services and to analyze visitor traffic. We use cookies in accordance with legal requirements. To do so, we obtain the consent of users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. This allows, for example, the login status to be stored and preferred content to be displayed directly when the user revisits a website. The user data collected using cookies may also be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage period may be up to two years.
General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to processing in accordance with the legal requirements, including through their browser's privacy settings.
Types of data processed: Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Data subjects: Users (e.g., website visitors, users of online services);
General opt-out: Users can revoke consent or object via browser settings or consent tools.
Contact and Request Management
When you contact us (e.g., by mail, contact form, email, telephone, or social media) and within the scope of existing user and business relationships, the information provided by the inquiring persons will be processed to the extent necessary to respond to the contact requests and any requested measures.
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., text or image messages and posts, as well as information relating to them, such as information about authorship or the time of creation); Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collection of feedback via online form). Provision of our online offering and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing, procedures, and services:
- Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data you provide to respond to and process your request. This usually includes information such as your name, contact details and, if applicable, other information that you provide to us and that is necessary for the proper processing of your request. We use this data exclusively for the stated purpose of establishing contact and communication; legal bases: fulfillment of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Artificial intelligence (AI)
We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in the use of AI are listed below. In accordance with the definition of an "AI system" in Article 3(1) of the AI Regulation, we understand AI to mean a machine-based system that is designed for operation with varying degrees of autonomy, can be adaptable after its introduction, and produces outputs such as predictions, content, recommendations, or decisions based on the inputs it receives, which can affect physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human control, purpose limitation, data minimization, integrity, and confidentiality. We ensure that the processing of personal data is always carried out on a legal basis. This can be either the consent of the data subjects or legal permission.
When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that AI providers comply with the applicable provisions. We also observe our obligations when using or operating the AI services we have obtained. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorization. In doing so, we attach particular importance to transparency, fairness, and the preservation of human control over AI-supported decision-making processes.
We implement appropriate and robust technical and organizational measures to protect the data processed. These ensure the integrity and confidentiality of the processed data and minimize potential risks. We ensure ongoing compliance with current legal and ethical standards through regular reviews of AI providers and their services.
Types of data processed: Content data (e.g., textual or pictorial messages and posts, as well as information relating to them, such as details of 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). Third parties.
Purposes of processing: Artificial intelligence (AI).
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures, and services:
- Microsoft Copilot: Enables the creation and editing of texts, tables, and presentations. Provides support for data analysis, task automation, and integration with various Microsoft Office applications. Uses machine learning to improve workflows and provide context-sensitive suggestions; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; legal basis: legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-copilot/organizations; Privacy Policy: https://www.microsoft.com/de-de/privacy/privacystatement; Data Processing Agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses.
Video conferences, online meetings, webinars, and screen sharing
We use platforms and applications from other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as "conferences"). When selecting conference platforms and their services, we comply with the legal requirements.
Data processed by conference platforms: When you join a conference, the conference platforms process the personal data of participants listed below. How much data is processed depends on what data is needed for a specific conference (like login details or real names) and what optional info participants give. In addition to processing for the purpose of holding the conference, the conference platforms may also process participant data for security purposes or to optimize their services. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information about professional position/function, the IP address of the Internet access, information about the participants' end devices, their operating system, the browser and its technical and language settings, information about the content of communication processes, i.e., entries in chats as well as audio and video data, and the use of other available functions (e.g., surveys). The content of communications is encrypted to the extent technically provided by the conference provider. If participants are registered as users on the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recording: If text entries, participation results (e.g., from surveys), and video or audio recordings are logged, participants will be informed of this in advance and asked for their consent where necessary.
Data protection measures taken by participants: For details on how your data is processed by the conference platforms, please refer to their privacy policies and select the security and privacy settings that are best for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g., by informing roommates, locking doors, and using the background blur function, if technically possible). Links to the conference rooms and access data must not be passed on to unauthorized third parties.
Information on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to the use of the conference platforms or certain functions (e.g., consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g., in participant lists, in the case of processing meeting results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
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., text or image messages and posts, as well as information relating to them, 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); Image and/or video recordings (e.g., photographs or video recordings of a person); audio recordings. Log data (e.g., log files relating to logins or the retrieval of data or access times).
Data subjects: Communication partners; users (e.g., website visitors, users of online services). Persons depicted.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures, and services:
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (Microsoft DPA).
Cloud services
We use software services accessible via the Internet and executed on the servers of their providers (so-called "cloud services," also referred to as "software as a service") for the storage and management of content (e.g., document storage and management, exchange of documents, content, and information with specific recipients, or publication of content and information).
In this context, personal data may be processed and stored on the providers' servers to the extent that this is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize their services.
If we use cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on users' devices for web analysis purposes or to remember user settings (e.g., in the case of media control).
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., text or image messages and posts, as well as information relating to them, 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: Interested parties; communication partners. Business and contractual partners.
Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures, and services:
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services, and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses.
- Microsoft EU Data Boundary: Our use of Microsoft Cloud services is subject to the EU Data Boundary, which ensures that data is stored and processed within the European Union (EU) and the European Free Trade Association (EFTA).
The EU Data Boundary is a defined region in which Microsoft commits to storing and processing customer data and personal data for certain online services (Microsoft 365, Azure, Dynamics 365, and the Power Platform). Companies that use these services can ensure that their data remains within the EU/EFTA region. This includes both general customer data and support data generated in the course of technical services. In many cases, pseudonymized data is also processed within this region.
The EU Data Boundary includes all EU countries as well as the EFTA countries (Liechtenstein, Iceland, Norway, and Switzerland). Microsoft operates data centers in several of these countries, including Germany, France, Ireland, the Netherlands, Sweden, Spain, and Switzerland. Additional locations may be added.
Microsoft automatically creates logs as part of its operations to ensure the security and functionality of its services. These logs mainly contain technical information, but in certain cases may also include personal data, e.g., when user actions are documented.
To protect this data, Microsoft uses techniques such as encryption, masking, and tokenization (replacing sensitive data with non-traceable strings). This ensures that Microsoft employees only see pseudonymized data and cannot draw any direct conclusions about individual users. There are also strict access rules and deletion periods for this data.
Microsoft has assured us that data transfers outside the EU only happen in a few specific cases. This might be needed to implement global cybersecurity measures or to make sure the cloud services work properly. These transfers always happen with high security standards like encryption and pseudonymization.
For more information about the EU Data Boundary and Microsoft's data protection measures, please visit the Microsoft EU Data Boundary Trust Center: https://www.microsoft.com/en-us/trust-center/privacy/eu-data-boundary.
Advertising communication via email, post, fax, or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.
After revocation or objection, we will store the data necessary to prove previous authorization 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 a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
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 pictorial messages and posts, as well as information relating to them, such as information on authorship or time of creation).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Surveys and questionnaires
We conduct surveys and questionnaires to collect information for the purpose communicated in each survey or questionnaire. The surveys and questionnaires we conduct (hereinafter referred to as "questionnaires") are evaluated anonymously. Personal data is only processed to the extent necessary for the provision and technical implementation of the surveys (e.g., processing of the IP address to display the survey in the user's browser or to enable the survey to be resumed using a cookie).
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., text or image messages and posts, as well as information relating to them, 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). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Participants. Users (e.g., website visitors, users of online services).
Purposes of processing: Feedback (e.g., collecting feedback via online forms). Surveys and questionnaires (e.g., surveys with input options, multiple-choice questions).
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures, and services:
- Microsoft Forms: Creation of online forms, collection of responses in real time, analysis of results with integrated charts. Integration with other Office applications for further data processing. Customizable forms with various question types and response options, as well as data export; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://forms.office.com/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses.
Presence on social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users, for example because it may make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of users. These may in turn be used to place advertisements within and outside the networks that are likely to correspond to the interests of users. For this reason, cookies are usually stored on users' computers, in which the usage behavior and interests of users are stored. In addition, data may also 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 there).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the event of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. However, if you require assistance, please contact us.
Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as information about authorship or the time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Communication; feedback (e.g., collection of feedback via online form). Public relations.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures, and services:
- Instagram: Social network that allows users to share photos and videos, comment on and favorite posts, send messages, and subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 Facebook social network... [Text truncated for brevity]
- Facebook groups: We use the "Groups" feature... [Text truncated for brevity]
- Facebook events: Event profiles within the Facebook social network... [Text truncated for brevity]
- LinkedIn: Social network - Joint responsibility with LinkedIn Ireland Unlimited Company... 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; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses.
- TikTok: Social network; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, Ireland, and TikTok Information Technologies UK Limited, London, UK; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy. Basis for transfers to third countries: Standard contractual clauses.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out: https://myadcenter.google.com/personalizationoff.
Plug-ins 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 referred to collectively as "content").
The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these 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 known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, but may also be linked to such information from other sources.
Information 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 consent given. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and user-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 length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Provision of our online offering and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion." Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Clean Talk: CAPTCHA service used to check whether the data entered within our online offering (e.g., on a login page or contact form) has been entered by a human or an automated program. For this purpose, the service analyzes the behavior of users of our online offering based on various characteristics. This analysis begins automatically as soon as a user uses our online offering. Various information is evaluated for the analysis (IP address, length of time the visitor stays on the website or app, or mouse movements of the user, as well as technical information about the end device and browser used by the user); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Data processing agreement: https://download.cleantalk.org/Signed_CleanTalk_GDPR_Agreement.pdf Basis for third-country transfers: Data Privacy Framework (DPF); Service provider: CleanTalk Inc, 711 S Carson Street, Suite 4, Carson City, NV 89701, USA; Website: https://cleantalk.org. Privacy policy: https://cleantalk.org/publicoffer#privacy.
Management, organization, and support tools
We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning, and providing our services. We comply with legal requirements when selecting third-party providers and their services.
In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data on transactions, contracts, other processes, and their contents.
If users are referred to third-party providers or their software or platforms in the course 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 information of the respective third-party providers.
Types of data processed: Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Processing of data in the context of employment relationships
In the context of employment relationships, personal data is processed for the purpose of effectively establishing, implementing, and terminating such relationships. This data processing supports various operational and administrative functions necessary for the management of employee relationships.
Data processing covers various aspects ranging from contract initiation to contract termination. This includes the organization and administration of daily working hours, the management of access rights and authorizations, and the handling of personnel development measures and employee appraisals. Processing also serves the purpose of accounting and administering wage and salary payments, which are critical aspects of contract execution.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data for the evaluation and optimization of operational processes. Furthermore, data processing includes the disclosure of employee data in the context of external communication and publication processes, where this is necessary for operational or legal purposes.
This data is always processed in compliance with the applicable legal framework, with the aim of creating and maintaining a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, anonymizing or deleting data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.
Types of data processed: Employee data (information about employees and other persons in an employment relationship).
Data subjects: Employees (e.g., employees, applicants, temporary staff, and other personnel).
Purposes of processing: Establishment and performance of employment relationships (processing of employee data in the context of establishing and performing employment relationships). Business processes and business procedures.
Legal basis: Contract fulfillment 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). Processing of special categories of personal data relating to health, professional, and social security matters (Art. 9 para. 2 lit. h) GDPR).
Processing of data in the context of employment relationships
In the context of employment relationships, personal data is processed for the purpose of effectively establishing, implementing, and terminating such relationships. This data processing supports various operational and administrative functions necessary for the management of employee relationships.
Data processing covers various aspects ranging from contract initiation to contract termination. This includes the organization and administration of daily working hours, the management of access rights and authorizations, and the handling of personnel development measures and employee appraisals. Processing also serves the purpose of accounting and administering wage and salary payments, which are critical aspects of contract execution.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data for the evaluation and optimization of operational processes. Furthermore, data processing includes the disclosure of employee data in the context of external communication and publication processes, where this is necessary for operational or legal purposes.
This data is always processed in compliance with the applicable legal framework, with the aim of creating and maintaining a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, anonymizing or deleting data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.
Types of data processed: Employee data (information about employees and other persons in an employment relationship).
Data subjects: Employees (e.g., employees, applicants, temporary staff, and other personnel).
Purposes of processing: Establishment and performance of employment relationships (processing of employee data in the context of establishing and performing employment relationships). Business processes and business procedures.
Legal basis: Contract fulfillment 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). Processing of special categories of personal data relating to health, professional, and social security matters (Art. 9 para. 2 lit. h) GDPR).
Application
The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required is specified in the job description or, in the case of online forms, in the information provided there.
As a rule, the required information includes personal details such as your name, address, contact details, and proof of the qualifications required for a position. Upon request, we will be happy to provide you with further information on the details required.
If available, applicants are welcome to submit their applications using our online form, which is encrypted using state-of-the-art technology. Alternatively, applications can also be sent to us by email. However, we would like to point out that emails are generally not encrypted when sent over the internet. Although emails are usually encrypted during transmission, this is not the case on the servers from which they are sent and received. We therefore cannot accept any responsibility for the security of your application during transmission between the sender and our server.
For the purposes of searching for applicants, submitting applications, and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.
Applicants are welcome to contact us regarding the method of submitting their application or send us their application by post.
Processing of special categories of data: If special categories of personal data (Art. 9 (1) GDPR, e.g. health data, such as severe disability or ethnic origin) are requested from applicants or provided by them, this data will be processed so that the controller or the data subject can exercise their rights under labor law and social security and social protection law and fulfill their obligations in this regard, in the case of the protection of the vital interests of the applicants or other persons or for the purposes of health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector.
Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job vacancy is unsuccessful, the applicant's data will be deleted. The applicant's data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified revocation by the applicant, the data will be deleted at the latest after a period of six months so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any travel expenses will be archived in accordance with tax regulations.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process, and that they may revoke their consent at any time in the future.
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., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation). Applicant data (e.g., personal details, postal and contact addresses, documents relating to the application and the information contained therein, such as cover letters, resumes, references, and other information provided by applicants in relation to a specific position or voluntarily provided by applicants about themselves or their qualifications).
Data subjects: Applicants.
Purposes of processing: Application process (justification and any subsequent implementation and possible subsequent termination of the employment relationship).
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing procedures, processes, and services:
- HRlab: Personnel administration, talent management, applicant management, employee development, seminar administration, time management, vacation management, and billing; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Data processing agreement: Provided by the service provider; Service provider: HRlab GmbH, Reinhardtstraße 58, D-10117 Berlin; Website: https://www.hrlab.de/. Privacy policy: https://www.hrlab.de/datenschutzerklaerung.
Data protection information for whistleblowers
In this section, you will find information on how we handle data from individuals who report concerns (whistleblowers) and from affected and involved parties within the scope of our whistleblowing procedure. Our goal is to provide a straightforward and secure way to report possible misconduct by us, our employees, or service providers, especially for actions that violate laws or ethical guidelines. We also ensure that reports are processed and handled appropriately.
Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); 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., text or image messages and posts, as well as information relating to them, such as details of 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: Employees (e.g., employees, applicants, temporary staff, and other personnel); third parties. Whistleblowers.
Purposes of processing: Whistleblower protection.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Changes and updates
We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out 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 for companies and organizations in this privacy policy, please note that the addresses may change over time and check the information before contacting them.
Definition of terms
This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are intended primarily to aid understanding.
- Employees: Persons in an employment relationship. Includes contract establishment, execution, and termination, including data such as salary, hours, health, and evaluations.
- Inventory data: Basic identifying information such as names, addresses, and IDs used for contracts or accounts.
- Content data: Created or published materials like text, images, video, and metadata such as author or date.
- Contact data: Communication information like phone numbers, email, postal addresses, or social media handles.
- Artificial intelligence (AI): Data processed for automated analysis, pattern recognition, predictions, or service optimization.
- Meta, communication, and process data: Data about data and processes, including timestamps, IPs, authorship, and workflow logs.
- Usage data: User behavior and interaction with digital services—e.g., navigation, frequency, duration, device info.
- Personal data: Any information that identifies a person directly or indirectly (name, ID, IP address, etc.).
- Log data: System-generated records of events such as login times, errors, or user activity.
- Controller: The individual or entity determining the purpose and means of processing personal data.
- Processing: Any operation performed on personal data—collection, storage, use, transmission, or deletion.
- Contract data: Information related to agreements, including terms, parties, and obligations.
- Payment data: Financial information required for transactions, including account numbers and payment status.