Commercial register no.
Link to legal notes
Data protection officer contact
Types of data processed
Processing of special categories of personal data (Art. 9 para. 1 GDPR):
In principle, no special categories of personal data are processed unless they are provided by the user for processing, e.g., entered in online forms.
Categories of data subjects involved in the processing:
Below, we will refer to the data subjects collectively as "users."
Purpose of the processing:
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie) or by one or more characteristics specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term covers practically every handling of data.
"Controller" means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
As of: 11.06.2018
1. Applicable legal bases
3. Safety precautions
We implement appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art of the technology, the cost of implementation and the nature, scope, context and purposes of the processing as well as the risks of varying likelihood and severity to rights and freedoms of natural persons posed by the processing, to ensure a level of protection appropriate to the risk; these measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling the (physical) access to the data as well as entering, transferring, safeguarding the availability and separation. In addition, we have established procedures to ensure that data subjects' rights are exercised, that data is deleted and that we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data-protection-friendly default settings (Art. 25 GDPR).
The security measures in particular include the encrypted transmission of data between your browser and our server.
4. Cooperation with data processors and third parties
Insofar as we disclose data to other persons and companies (data processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g., if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR, is necessary for the performance of the contract), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g., when using agents, web hosting providers, etc.).
If we commission third parties with the processing of data on the basis of a so-called data processing agreement, this is done on the basis of Art. 28 GDPR.
5. Transfers to third countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in connection with the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. of the GDPR are met. This means that the processing takes place, for example, on the basis of appropriate safeguards, such as the official confirmation of a level of protection comparable to that in the EU (e.g., for the USA through the "Privacy Shield") or the observance of officially recognized special contractual obligations (so-called "standard contractual clauses").
6. Rights of data subjects
You have the right to request confirmation as to whether or not personal data concerning you are being processed and to get access to this data and to get further information and a copy of the data, in accordance with Art. 15 GDPR.
According to Art. 16 GDPR, you shall have the right to have incomplete personal data concerning you completed or inaccurate data concerning you rectified.
According to Art. 17 GDPR, you shall have the right to obtain the erasure of personal data concerning you without undue delay or, alternatively, to obtain a restriction of processing of the data, pursuant to Art. 18 GDPR.
You shall have the right to receive the personal data concerning you that you have provided to us, in accordance with Art. 20 GDPR, and to demand that it be transmitted to another controller.
Pursuant to Art. 77 GDPR, you shall also have the right to lodge a complaint with the competent supervisory authority.
7. Right to withdraw
You shall have the right to withdraw your consent granted, pursuant to Art. 7 para. 3 GDPR, with effect for the future.
8. Right to object
You shall have the right to object at any time to the future processing of the personal data concerning you, in accordance with Art. 21 GDPR. The objection may in particular be exercised against processing of personal data for the purposes of direct marketing.
9. Cookies and right to object to direct marketing
10. Erasure of personal data
Germany: According to statutory requirements, the data are stored for six years in accordance with Section 257(1) German Commercial Code (HGB) (account books, inventories, opening balance sheets, annual financial statements, business letters, accounting records, etc.) and for 10 years in accordance with Section 147(1) German Fiscal Code (AO) (books, records, management reports, accounting records, commercial and business letters, documents relevant for taxation, etc.).
11. Contacting us
When contacting us (via contact form or e-mail), the user's details will be processed in order to handle the contact request and its processing, in accordance with Art. 6 Para. 1 lit. b) GDPR.
The user data may be stored in our customer relationship management system (CRM System) or comparable system to organize inquiries.
12. Collection of access data and log files
On the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR, we collect data regarding each access to the server on which this service is stored (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited web page), IP address and the requesting provider.
Log file information is stored for a maximum of seven days for security reasons (e.g., to clarify abuse or fraud) and then deleted. Data whose further storage is necessary for evidence purposes are excluded from deletion until the relevant incident has been finally clarified.
13. Online presences in social media
On the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR, we maintain the following online presences on social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services. When retrieving the respective networks and platforms, the terms and conditions and the privacy policies of their respective operators apply.
14. Cookies and reach measurement
Cookies are pieces of information that are transmitted from our web server or third-party web servers to the user's web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.
We use session cookies, which are only stored for the duration of the current visit to our online presence (e.g., to enable the storage of your login status or the shopping cart function and thus enable the use of our online offer). A randomly generated unique identifier, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted as soon as you finish using our online service and log out or close your browser, for example.
If users want to prevent cookies from being stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The deactivation of cookies can lead to functional restrictions of this online offer.
15. Google Analytics
Google is certified under the Privacy Shield framework and thus is committed to complying with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online services by users, to compile reports on the activities within this online service and to provide us with other services associated with the use of this online service and the Internet. Pseudonymous user profiles of the users can be created from the processed data.
We use Google Analytics to display ads placed via advertising services from Google and its partners only to those users who have shown an interest in our online offer or who have specific characteristics (e.g., interest in specific topics or products determined on the basis of the websites visited) that we transmit to Google ("remarketing" or "Google Analytics Audiences"). With the help of Remarketing Audiences, we also want to ensure that our ads are in line with the potential interest of users and do not appear annoying.
We only use Google Analytics with IP anonymization activated. This means that the user’s IP address will be truncated by Google within the area of member states of the European Union or other contracting states to the agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and truncated there.
The IP address transmitted by the user's browser shall not be merged with other data in Google’s possession. Users may prevent the storage of cookies by making pertinent changes to the settings of their browser software; they may also prevent the recording of the data generated by the cookie and affiliated with their use of the online offer and its transfer to Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information about the handling of user data by Google and about settings and objection options, please consult the following Google websites: https://www.google.com/intl/de/policies/privacy/partners ("How Google uses information from sites or apps that use our services"), https://policies.google.com/technologies/ads ("How Google uses data for advertising purposes"), https://adssettings.google.com/authenticated ("Manage information Google uses to display ads")
Otherwise, personal data will be anonymized or erased after 14 months.
16. Facebook social plugins
On the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use social plugins ("plugins") from the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). The plugins can display interaction elements or content (e.g., videos, graphics or text) and are recognizable by one of the Facebook logos (white "f" on a blue tile, the term "like" or a "thumbs up" sign) or are marked with the addition "Facebook Social Plugin." The list and appearance of the Facebook social plugins can be found here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield framework and thus is committed to complying with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
Whenever a user calls a function of this online offer that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted directly from Facebook to the user's device and integrated into the online offer. In the process, user profiles of the users can be created from the processed data. We therefore have no influence on the extent of data Facebook collects with the help of this plugin and therefore inform the user according to our state of knowledge.
By integrating the plugins, the information that a user has accessed the corresponding page of the online offer is transmitted to Facebook. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. When users interact with the plugins, e.g., by clicking the Like button or commenting, the corresponding information is transferred directly from their device to Facebook and stored there. If a user is not a Facebook member, it is still possible for Facebook to determine and store their IP address. According to Facebook, in Germany only an anonymized IP address is stored.
The purpose and scope of data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options to protect the privacy of users, can be found in Facebook's data protection notice: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect information about him or her via this online offer and merge it with his or her Facebook member data, he or she must log out of Facebook and delete cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are available within the Facebook profile settings at https://www.facebook.com/settings?tab=ads, or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are adopted for all devices, such as desktop computers or mobile devices.
17. Agency services
We process our customers’ data within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation/handling of campaigns and processes, server administration, data analysis/consulting services and training services.
We process master data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), and usage and metadata (e.g., within the scope of evaluating and measuring the success of marketing measures). We do not process special categories of personal data in principle, unless these are components of a commissioned processing. Affected parties include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing is Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data which are necessary for the substantiation and fulfillment of the contractual services and point out the necessity of their provision. Disclosure to external parties only takes place if it is required within the framework of an order. When processing the data provided to us within the framework of an order, we shall act in accordance with the instructions of the principal and the statutory requirements for processing pursuant to Art. 28 GDPR and shall not process the data for any purposes other than those specified in the order.
We delete the data after expiration of legal warranty and comparable obligations. The necessity of the retention of the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiration (six years, according to Section 257(1) German Commercial Code (HGB); 10 years, according to Section 147(1) German Fiscal Code (AO)). In the case of data disclosed to us by the principal within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.
18. Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the framework of the provision of our contractual services. The processing is based on Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing is based on administration, financial accounting, office organization and archiving of data, i.e., tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information specified for these processing activities.
We disclose or transmit data to the tax authorities, consultants such as tax consultants or auditors, and other billing offices and payment service providers.
Furthermore, on the basis of our business interests, we store information on suppliers, organizers and other business partners, e.g., for the purpose of establishing contact at a later date. This data, which is mainly company-related, is in general stored permanently.
19. Data protection notice concerning the application process
We process applicant data only for the purpose and within the framework of the application procedure in accordance with statutory requirements. The processing of applicant data is carried out to fulfill our (pre)contractual obligations within the scope of the application procedure as defined by Art. 6 Para. 1 lit. b. GDPR and Art. 6 para. 1 lit. f. GDPR if the data processing (e.g., in the context of legal proceedings) becomes necessary for us (in Germany, § 26 Federal Data Protection Act (BDSG) additionally applies).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the mandatory applicant data are marked; otherwise they can be derived from the job descriptions and basically include personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily provided in the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g., health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data, if these are necessary for the exercise of the profession).
Where provided, applicants may submit their applications via an online form on our website. The data will be transmitted to us in encrypted form according to the state of the art.
Applicants can also send us their application by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and the applicants themselves must ensure their encryption. We therefore cannot assume any responsibility for the transmission of the application between the sender and reception on our server and therefore recommend using an online form or postal dispatch. Instead of applying via the online form or e-mail, applicants still have the option of sending their application by post.
In the event of a successful application, the data provided by the applicant may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' 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, deletion will take place after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you agree to the receipt of it and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as "newsletter") only with the consent of the recipient or with legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our products, offers, promotions and our company.
Double-opt-in and logging: The registration to our newsletter takes place via a so-called double-opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with another person's e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise, changes of your data stored with the e-mailing service provider are logged.
Furthermore, according to its own information, the dispatch service provider may use this data in pseudonymous form, i.e., without reference to a user, to optimize or improve its own services, e.g., for technical optimization of dispatch and the presentation of the newsletter or for statistical purposes, in order to determine from which countries, the recipients originate. However, the e-mailing service provider does not use the data of our newsletter recipients to contact them or pass them on to third parties.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally we ask you to enter a name in order to personally address you in the newsletter.
Performance measurement: The newsletters contain a so-called web beacon, i.e., a file the size of a pixel that is retrieved from the server of the e-mailing service provider when the newsletter is opened. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval, are first collected. This information is used for the technical improvement of the services on the basis of technical data or target groups and their reading behavior on the basis of their retrieval location (which can be determined with the help of the IP address) or access times. Statistical measurement also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our nor the e-mailing service provider's intention to observe individual users. Rather, the evaluations serve us to understand the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The dispatch of the newsletter and the performance measurement are based on the consent of the recipients according to Art. 6 para. 1 lit. a, Art. 7 GDPR in connection with § 7 para. 2 no. 3 Law Against Unfair Competition (UWG) or legal permission according to § 7 para. 3 Law Against Unfair Competition (UWG).
The registration procedure is logged on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR and serves as proof of consent to receive the newsletter.
Cancellation/revocation: Newsletter recipients may cancel the receipt of our newsletter at any time, i.e., revoke their consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. At the same time, your consent to the performance measurement is revoked. A separate revocation of the performance measurement unfortunately is not possible; in this case, the entire newsletter subscription must be canceled. Following the cancellation of the newsletter, the personal data are deleted, unless their retention is legally required or justified, in which case their processing is limited only to these exceptional purposes. In particular, we may store the canceled e-mail addresses for up to three years on the basis of our legitimate interests before we delete them for the purpose of sending the newsletter in order to be able to prove your consent to the receipt of the newsletter. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
21. Integration of third-party services and content
Based on our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use content or service offerings from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content"). This always presupposes that the third-party providers of this content identify the user’s IP address, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents. We strive to use only those contents whose providers use the IP address only for the distribution of the contents. 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 may 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 times and other information about the use of our online offer, and may also be referenced to similar information from other sources.
The following presentation provides an overview of third-party providers and their contents, along with links to their privacy policies, which contain further information on the processing of data and, in some cases already mentioned here, possible opt-out options: