Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly as "data") we process, for what purposes, and to what extent within the framework of providing our application.

The terms used are not gender-specific.

Status: July 20, 2026

Controller

Yana Borzykh
Breslauer Str. 111
42277 Wuppertal
Email address: borzykhyana@gmail.com, schneideryana51@gmail.com
Legal Notice (Impressum): https://proresidencegermany.com/de/impressum/

Contact Details of the Data Protection Officer

[None provided / Not applicable]

Overview of Processing Activities

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

Types of Data Processed:

• Master data (e.g., names, addresses).
• Employee data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication, and procedural data.
• Log data.

Categories of Data Subjects:

• Service recipients and clients.
• Employees.
• Interested parties.
• Communication partners.
• Users.
• Business and contractual partners.
• Third parties.
• Whistleblowers.

Purposes of Processing:

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Reach measurement.
• Office and organizational procedures.
• Organizational and administrative procedures.
• Feedback.
• Profiles with user-related information.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.
• Whistleblower protection.
• Public relations.
• Business processes and commercial procedures.

Representative in the European Union

[None provided / Not applicable]

Legal Bases of Processing

Applicable legal bases under the GDPR: The following is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be applicable in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Performance of a contract and prior inquiries (Art. 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Compliance with a legal obligation (Art. 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Act on Protection Against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, entry, disclosure, safeguarding availability, and separation of data relating to it. Furthermore, we have established procedures to ensure the exercise of data subject rights, the erasure of data, and responses to data hazards. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): In order to protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and encrypted.

Transmission of Personal Data

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

Data transmission within the organization: We may transmit personal data to other departments or units within our organization or grant them access to it. If data is passed on for administrative purposes, it is based on our legitimate entrepreneurial and business interests, or it takes place if it is necessary to fulfill our contract-related obligations, or if the consent of the data subjects or legal permission is available.

International Data Transfers

Data Processing in 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 occurs within the framework of using third-party services or disclosing or transmitting data to other persons, bodies, or companies (which becomes apparent from the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers, which correspond to the specifications of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should changes arise within the framework of the DPF, the Standard Contractual Clauses step in as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.

In the case of individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are available. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at dataprivacyframework.gov.

For data transfers to other third countries, corresponding security measures apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information offered by the EU Commission: europa.eu.

General Information on Data Storage and Erasure

We erase personal data that we process in accordance with legal regulations as soon as the underlying consent is revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require a longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax reasons, or whose storage is necessary for legal enforcement or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and erasure of data that apply specifically to certain processing activities.

If several details regarding the retention period or erasure deadlines of a specific piece of data are provided, the longest period shall always prevail. Data that is no longer kept for its originally intended purpose, but rather due to legal requirements or other reasons, is processed exclusively for the reasons that justify its retention.

Retention and Erasure of Data: The following general periods apply to retention and archiving under German law:

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the working instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
• 8 years – Accounting vouchers, such as invoices and expense vouchers (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
• 6 years – Other business documents: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents insofar as they are of importance for taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price tags, but also payroll documents insofar as they are not already accounting vouchers, and cash register strips (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
• 3 years – Data required to take into account potential warranty and damage compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Commencement of Period at the End of the Year: Unless a period explicitly begins on a specific date and is at least one year long, it starts automatically at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within the framework of which data is stored, the event triggering the period is the time at which the termination or other end of the legal relationship becomes effective.

Rights of the Data Subjects

Rights of Data Subjects under the GDPR: As a data subject under the GDPR, you are entitled to various rights, which arise in particular from Articles 15 to 21 of the GDPR:

• Right to Object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is connected with such direct marketing.
• Right to Revoke Consent: You have the right to revoke consent once granted at any time.
• Right of Access: You have the right to request confirmation as to whether relevant data is being processed and to receive access to this data as well as further information and a copy of the data in accordance with legal requirements.
• Right to Rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.
• Right to Erasure and Restriction of Processing: In accordance with legal requirements, you have the right to demand that data concerning you be erased immediately, or alternatively, in accordance with legal requirements, to demand a restriction of the processing of the data.
• Right to Data Portability: You have the right to receive data concerning you that you have provided to us, in accordance with legal requirements, in a structured, commonly used, and machine-readable format or to demand its transmission to another controller.
• Complaint to a Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the provisions of the GDPR.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers, and other cooperation partners (collectively referred to as “Contractual Partners”), for the purpose of initiating, establishing, and processing contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures carried out upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfill our principal and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the processing of warranty and other performance disruptions, the handling of revocations, terminations of long-term obligations, reversals, refunds, as well as the processing of other contract-related declarations and inquiries. Both one-off contracts and continuous contractual relationships are covered.

In particular, master data such as name, address and, if applicable, company name, contact data such as email address and telephone number, contract and performance data such as contract object, contract duration, order or transaction number, usage and performance data, payment and billing data, as well as communication content and histories are processed. Where necessary, we also process data disclosed or transmitted to us within the framework of executing an order.

In addition, we process the data to protect our rights and to fulfill legal obligations. This includes, in particular, commercial and tax retention obligations, documentation obligations, and, if applicable, proof and accountability obligations. Furthermore, processing is carried out on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as the protection of our business operations and our Contractual Partners from misuse, hazard to data, secrets, and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers, or other vicarious agents, insofar as this is necessary for contract performance or to fulfill legal obligations.

Personal data is passed on to third parties exclusively to the extent necessary for contract fulfillment, to carry out pre-contractual measures, to safeguard legitimate interests, or to fulfill legal obligations. We will provide separate information in this privacy policy about any processing going beyond this, in particular for marketing purposes.

We inform the Contractual Partners which data is required in individual cases within the framework of data collection, for example in online forms through corresponding marking or in personal contact.

The data is erased as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations stand in the way. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted to us within the framework of a specific order will be erased by us after completion of the order and expiry of any retention periods, unless other legal or contractual obligations to store exist.

The legal basis for the processing is Art. 6 para. 1 lit. b GDPR for the execution of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6 para. 1 lit. f GDPR. Insorfar as the processing is based on Art. 6 para. 1 lit. f GDPR, it is carried out to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business transactions, enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, as well as commercial management and further development of our business operations. These interests consist in particular in ensuring safe and legally secure business operations as well as maintaining our entrepreneurial capacity to act.

• Types of Data Processed: Master 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., contract object, duration, customer category).
• Data Subjects: Service recipients and clients; Interested parties. Business and contractual partners.
• Purposes of Processing and Legitimate Interests: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and commercial procedures.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Performance of a contract and prior inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 S. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Payment Procedures

Within the framework of contractual and other legal relationships, on the basis of legal obligations, or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively “Payment Service Providers”). Payment transactions are carried out in accordance with the state of the art exclusively via encrypted connections, so that the entered data is protected from unauthorized access during transmission.

The data processed by the Payment Service Providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract, total, and recipient-related details. The details are required to carry out the transactions. However, the entered data is only processed by the Payment Service Providers and stored by them. This means we do not receive account- or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data is transmitted by the Payment Service Providers to credit agencies. This transmission aims at identity and credit checks. For this purpose, we refer to the Terms and Conditions and the privacy notices of the Payment Service Providers.

The business conditions and the privacy notices of the respective Payment Service Providers apply to payment transactions; these can be called up within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, access, and other data subject rights.

• Types of Data Processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., contract object, duration, customer category); Usage data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons).
• Data Subjects: Service recipients and clients; Business and contractual partners. Interested parties.
• Purposes of Processing and Legitimate Interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and commercial procedures.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Performance of a contract and prior inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• PayPal: Payment services (technical connection of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal bases: Performance of a contract and prior inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR); Website: paypal.com. Privacy Policy: paypal.com/legalhub/paypal/privacy-full.
• Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal bases: Performance of a contract and prior inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR); Website: visa.de. Privacy Policy: visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung.html.

Provision of the Online Offer and Web Hosting

We process user data to be able 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 duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons); Log data (e.g., log files concerning logins or the retrieval of data or access times). Content data (e.g., text or image messages and posts as well as information concerning them, such as details on authorship or time of creation).
• Data Subjects: Users (e.g., website visitors, users of online services).
• Purposes of Processing and Legitimate Interests: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Provision of Online Offer on Rented Storage Space: For the provision of our online offer, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called “Webhoster”); Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).
• Collection of Access Data and Log Files: Access to our online offer is logged in the form of so-called “Server Log Files”. The server log files can include the address and name of the retrieved websites and files, date and time of retrieval, transferred data volumes, notification of successful retrieval, 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 on the one hand for security purposes, e.g., to prevent overloading of the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR). Erasure of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from erasure until the final clarification of the respective incident.
• STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: strato.de; Privacy Policy: strato.de/datenschutz/. Data Processing Agreement: Provided by the service provider.
• WordPress.com: Hosting and software for creating, providing, and operating websites, blogs, and other online offers; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: automattic.com; Data Processing Agreement: wordpress.com. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).

Einsatz von Cookies (Use of Cookies)

The term “Cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for different purposes, such as functionality, security, and convenience of online offers, as well as for creating analyses of visitor flows. We use cookies in accordance with statutory regulations. For this purpose, we obtain the users’ prior consent if required. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential to explicitly provide requested content and functions. These include, for example, the storage of settings and ensuring the functionality and security of our online offer. Consent can be revoked at any time. We inform clearly about its scope and which cookies are used.

Information on Data Protection Legal Bases: Whether we process personal data using cookies depends on consent. If consent is 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 storage duration, a distinction is made between the following types of cookies:

• Temporary Cookies (also: Session Cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g., browser or mobile application).
• Permanent Cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content displayed directly when the user visits a website again. Likewise, user data collected using cookies can be used for reach measurement. Unless we provide users with explicit details on the type and storage duration of cookies (e.g., in the context of obtaining consent), they should assume that these are permanent and the storage duration can be up to two years.

General Information on Revocation and Objection (Opt-Out): Users can revoke consents they have granted at any time and, furthermore, object to the processing in accordance with legal regulations, also by means of the privacy settings of their browser.

• Types of Data Processed: Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons).
• Data Subjects: Users (e.g., website visitors, users of online services).
• Legal Bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR). Consent (Art. 6 para. 1 S. 1 lit. a) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Processing of Cookie Data on the Basis of Consent: We use a consent management solution in which the user’s consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consents, in particular regarding the use of cookies and comparable technologies used to store, read, and process information on users’ end devices. Within the framework of this procedure, users’ consents for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific details on the providers of consent management services are available, the following general notices apply: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers) as well as information about the browser, the system, and the end device used; Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR).

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter “Publication Medium”). Readers’ data is processed for the purposes of the Publication Medium only insofar as it is necessary for its presentation and communication between authors and readers or for reasons of security. For the rest, we refer to the information on the processing of visitors to our Publication Medium within the scope of these privacy notices.

• Types of Data Processed: Master 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 concerning them, such as details on authorship or time of creation); Usage data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons).
• Data Subjects: Users (e.g., website visitors, users of online services).
• Purposes of Processing and Legitimate Interests: Feedback (e.g., collecting feedback via online form); Provision of our online offer and user-friendliness; Security measures. Organizational and administrative procedures.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Comments and Contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and contributions (insults, forbidden political propaganda, etc.). In this case, we ourselves could be prosecuted for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user details for the purpose of spam detection based on our legitimate interests. On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies to avoid multiple votes. The personal information communicated within the framework of comments and contributions, any contact and website information as well as the content details will be permanently stored by us until the user objects; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Kontakt- und Anfrageverwaltung (Management of Contacts and Inquiries)

When contacting us (e.g., by post, contact form, email, telephone, or via social media) as well as within the framework of existing user and business relationships, the details of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

• 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 concerning them, such as details on authorship or time of creation). Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons).
• Data Subjects: Communication partners.
• Purposes of Processing and Legitimate Interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR). Performance of a contract and prior inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Contact Form: When contacting us via our contact form, by email, or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes details such as name, contact information and, if applicable, further information communicated to us and required for appropriate processing. We use this data exclusively for the stated purpose of contacting and communication; Legal bases: Performance of a contract and prior inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Webanalyse, Monitoring und Optimierung (Web Analysis, Monitoring, and Optimization)

Web analysis (also referred to as “reach measurement”) serves to evaluate visitor flows to our online offer and can include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used, or invite users to revisit. Likewise, it is possible for us to understand which areas need optimization.

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

Unless otherwise stated below, profiles, i.e., data combined for a usage process, can be created for these purposes, and information can be stored in a browser or in an end device and then read. The collected details include in particular visited websites and elements used there, as well as technical information, such as the browser used, the computer system used, and details on usage times. If users have agreed to the collection of their location data towards us or towards the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored within the framework of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the details stored in their profiles for the purpose of the respective procedures.

• 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 consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
• Types of Data Processed: Usage data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons).
• Data Subjects: Users (e.g., website visitors, users of online services).
• Purposes of Processing and Legitimate Interests: Reach measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”. Storage of cookies of up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users’ devices for a period of two years).
• Security Measures: IP masking (pseudonymization of the IP address).
• Legal Bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Google Analytics: We use Google Analytics to measure and analyze the use of our online offer based on a pseudonymous user identification number. This identification number does not contain unique data, such as names or email addresses. It serves to assign analytical information to an end device in order to recognize which content users have called up within one or various usage processes, which search terms they have used, whether they have called these up again, or have interacted with our online offer. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offer and technical aspects of their end devices and browsers. Pseudonymous profiles of users are created with information from the use of different devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). In the case of EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible, and is not used for further purposes. When Google Analytics collects measurement data, all IP requests are carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR); Website: google.com/analytics; Security measures: IP-masking (pseudonymization of the IP address); Privacy Policy: safety.google; Data Processing Agreement: safety.google; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (safety.google); Objection option (Opt-Out): Opt-Out Plugin: google.com/dlpage/gaoptout, settings for the display of advertisements: google.com/personalizationoff. Further information: safety.google (Types of processing and processed data).

Präsenzen in sozialen Netzwerken (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We point out that user data may be processed outside the area of the European Union. This may result in risks for users because, for example, the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and resulting user interests. The latter may in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on the users’ computers, in which the usage behavior and the interests of the users are stored. In addition, data can also be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and logged in there).

For a detailed presentation of the respective forms of processing and the possibilities of objection (Opt-out), we refer to the privacy policies and details provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data in each case and can directly take appropriate measures and provide information. Should you nevertheless require help, you can turn to 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 concerning them, such as details on authorship or time of creation); Usage data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Master data (e.g., full name, residential address, contact information, customer number, etc.). Meta, communication, and procedural data (e.g., IP addresses, times, identification numbers, involved persons).
• Data Subjects: Users (e.g., website visitors, users of online services).
• Purposes of Processing and Legitimate Interests: Communication; Feedback (e.g., collecting feedback via online form); Public relations; Provision of our online offer and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Instagram: Social network, enables the sharing of photos and videos, commenting and favoriting of posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: instagram.com; Privacy Policy: instagram.com. Basis for third-country transfers: Data Privacy Framework (DPF).
• Facebook Pages: Profiles within the social network Facebook – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data of visitors to our Facebook page (“Fanpage”). This includes in particular information about user behavior (e.g., viewed or interacted content, actions performed) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). More details on this can be found in the Facebook Data Policy: facebook.com. Facebook also uses this data to provide us with statistical evaluations via the “Page Insights” service, which provide information on how people interact with our page and its content. The basis for this is an agreement with Facebook (“Page Controller Addendum”: facebook.com), in which, among other things, security measures and the exercise of data subject rights are regulated. Further notices can be found here: facebook.com. Users can therefore direct requests for access or erasure directly to Facebook. The rights of users (in particular access, erasure, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including a possible transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: facebook.com; Privacy Policy: facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (facebook.com/legal/EU_data_transfer_addendum).
• LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they perform. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as details from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information on the processing of user data by LinkedIn can be found in the LinkedIn privacy policy: linkedin.com. We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, linkedin.com), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for access or erasure directly to LinkedIn). The rights of users (in particular the right of access, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular as regards the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: linkedin.com; Privacy Policy: linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (linkedin.com/legal/privacy-policy). Objection option (Opt-Out): linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Threads: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Website: threads.net. Privacy Policy: instagram.com.
• YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); Privacy Policy: safety.google; Basis for third-country transfers: Data Privacy Framework (DPF). Objection option (Opt-Out): google.com/personalizationoff.

Datenschutzinformationen für Hinweisgeber (Privacy Information for Whistleblowers)

In this section, you will find information on how we handle data from persons who give notices (whistleblowers), as well as from affected and involved parties within the framework of our whistleblower procedure. Our goal is to provide an uncomplicated and confidential opportunity to report violations while at the same time ensuring the protection of the identity of all involved parties and compliance with statutory data protection specifications.

• Types of Data Processed: Master data (e.g., full name, residential address, contact information, customer number, contract data); Employee data (information on 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 concerning them, such as details on authorship or times of creation). Usage data (e.g., page views and duration of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions of our reporting system).
• Data Subjects: Service recipients and clients; Employees (e.g., employees, applicants, temporary workers, and other staff); Third parties. Whistleblowers.
• Purposes of Processing and Legitimate Interests: Whistleblower protection.
• Retention and Erasure: Erasure according to the details in the section “General Information on Data Storage and Erasure”.
• Legal Bases: Consent (Art. 6 para. 1 S. 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 S. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Further Notices on Processing Activities, Procedures, and Services:

• Legal Bases (Germany): Insofar as we process data to fulfill our legal obligations under the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6 para. 1 S. 1 lit. c) GDPR and, in the case of special categories of personal data, Art. 9 para. 2 lit. g) GDPR, § 22 BDSG, each in conjunction with § 10 HinSchG. This refers to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its statutory tasks and, in the case of using the data collected in the reporting procedure, the taking of further follow-up measures such as internal investigations, reviews, the conclusion of the procedure, or forwarding to competent authorities within the framework of statutory provisions.
• Types of Data Processed: Within the framework of receiving and processing notices as well as in the subsequent whistleblower procedure, we can collect various data. These include in particular the data provided by a whistleblower, such as: Name, contact details, and location of the person giving the notice, Names and data on potential witnesses or persons affected by the notice, Names and data on the persons against whom the notice is directed, Data on the alleged misconduct, Further relevant details, provided that these contribute to the clarification of the reported facts and are provided voluntarily by the whistleblower or within the framework of the interview.
• Special Categories of Personal Data: It may happen that we record special types of personal data within the framework of our activities, in particular if these are communicated by a whistleblower. These include: health data, data on religious or philosophical beliefs, trade union membership, racial or ethnic origin, as well as data on sex life or sexual orientation, provided that these are strictly necessary for the review of the notice.

Änderung und Aktualisierung (Changes and Updates)

We ask you to inform yourself regularly about the content of our privacy policy. We adjust the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require a cooperative action on your part (e.g., consent) or other individual notification becomes necessary.

Insofar as we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the details before contacting them.

Begriffsdefinitionen (Definitions of Terms)

In this section, you will find an overview of the terminology used in this privacy policy. Insofar as the terminology is legally defined, its legal definitions apply. The following explanations, on the other hand, are intended primarily to aid understanding.

• Employees (Beschäftigte): Employees are persons who are in an employment relationship, whether as staff, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It includes the obligation of the employer to pay remuneration to the employee while the employee performs his or her work. The employment relationship includes various phases, including the establishment in which the employment contract is concluded, the performance in which the employee carries out his or her work activity, and the termination when the employment relationship ends, whether by dismissal, termination agreement, or otherwise. Employee data is all information relating to these persons and standing in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance appraisals.
• Contact Data (Kontaktdaten): Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, Communication, and Procedural Data (Meta-, Kommunikations- und Verfahrensdaten): Meta, communication, and procedural data are categories containing information about the way data is processed, transmitted, and managed. Metadata, also known as data about data, includes information describing the context, origin, and structure of other data. It can include details on file size, creation date, the author of a document, and modification histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved persons, timestamps, and transmission paths. Procedural data describes the processes and sequences within systems or organizations, including workflow documentations, logs of transactions and activities, as well as audit logs used to track and review operations.
• Usage Data (Nutzungsdaten): Usage data refers to information recording how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages, and via which paths they navigate through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in recognizing trends, preferences, and potential problem areas within digital offers.
• Personal Data (Personenbezogene Daten): “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• Profiles with User-Related Information (Profile mit nutzerbezogenen Informationen): The processing of “profiles with user-related information”, or “profiles” for short, comprises any kind of automated processing of personal data consisting of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
• Log Data (Protokolldaten): Log data is information about events or activities logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used for analyzing system problems, security monitoring, or creating performance reports.
• Reach Measurement (Reichweitenmessung): Reach measurement (also referred to as web analytics) serves to evaluate visitor flows to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, operators of online offers can recognize, for example, at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses on the use of an online offer.
• Controller (Verantwortlicher): “Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing (Verarbeitung): “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether collecting, evaluating, storing, transmitting, or erasing.
• Contract Data (Vertragsdaten): Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include start and end dates of the contract, the type of agreed services or products, price agreements, terms of payment, termination rights, renewal options, and special conditions or clauses. It serves as a legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
• Payment Data (Zahlungsdaten): Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for electronic commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data can also contain information about payment status, chargebacks, authorizations, and fees.

Created with the free Datenschutz-Generator.de by Dr. Thomas Schwenke