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Privacy Policy

Preamble

The following Privacy Policy is intended to inform you about what types of your personal data (hereinafter also referred to as “Data”) we process, for what purposes, and to what extent. This 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 the “Online Offering”).

The terms used are not gender-specific.

As of: May 21, 2026

Table of Contents

  • Preamble
  • Data Controller
  • Overview of Processing Activities
  • Applicable Legal Bases
  • Security Measures
  • Transfer of Personal Data
  • International Data Transfers
  • General Information on Data Storage and Deletion
  • Rights of Data Subjects
  • Provision of the Online Offer and Web Hosting
  • Use of Cookies
  • Blogs and Publication Media
  • Contact and Inquiry Management
  • Newsletters and Electronic Notifications
  • Surveys and Polls
  • Affiliate Programs and Affiliate Links
  • Social Media Presences
  • Plug-ins, embedded functions, and content
  • Changes and updates
  • Definitions

Data Controller

Joan Chandelíers
c/o IP-Management #9095
Ludwig-Erhard-Str. 18
20459 Hamburg
Germany

Email address: contact@editionchandeliers.com 

Overview of processing activities

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

Types of data processed

  • Master data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Event data (Facebook).
  • Log data.

Categories of data subjects

  • Prospective customers.
  • Communication partners.
  • Users.
  • Participants.

Purposes of Processing

  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Conversion measurement.
  • Target group formation.
  • Affiliate tracking.
  • Organizational and administrative procedures.
  • Server monitoring and error detection.
  • Feedback.
  • Surveys and questionnaires.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online services and user-friendliness.
  • IT infrastructure.
  • Public relations.

Applicable Legal Bases

Applicable Legal Bases under the GDPR: Below is an overview of the legal bases under 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 country of residence or our country of domicile. Furthermore, should more specific legal bases apply 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 personal data concerning him or her for a specific purpose or for several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request.
  • 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 data protection regulations apply in Germany. These include, in particular, the Act on the Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions regarding 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 the transfer as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss DSG: This privacy notice serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader geographical scope and clarity, the terms used in the GDPR are employed. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “sensitive personal data” used in the Swiss Data Protection Act (DSG), the terms “processing” of “personal data,” as well as “legitimate interest” and “special categories of data.” However, the legal meaning of the terms continues to be determined in accordance with the Swiss Data Protection Act (DSG) within the scope of its applicability.

Security Measures

In accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihoods and severity of threats to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, ensuring availability, and data segregation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the erasure of data, and responses to data breaches. Additionally, we take the protection of personal data into account from the outset 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 via T TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the advanced and more 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 in encrypted form.

Transfer of Personal Data

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

International Data Transfers

Data Processing in Third Countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in connection with the use of third-party services or the disclosure or transfer of data to other individuals, agencies, or companies (which is evident from the postal address of the respective provider or if the privacy policy expressly refers to data transfers to third countries), this is always done in accordance with legal requirements.

For data transfers to the U.S., we primarily rely on the Data Privacy Framework (DPF), which was recognized as an adequate legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have entered into standard contractual clauses with the respective providers that comply with the requirements of the European Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as an additional safeguard. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of any political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses

, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found on the European Commission’s website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal basis for processing exists. This applies to cases where the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule apply if legal obligations or specific interests require longer retention or archiving of the data.

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

Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are multiple specifications regarding the retention period or deletion deadlines for a particular piece of data, the longest period shall always apply. We process data that is no longer retained for the originally intended purpose, but rather due to legal requirements or other reasons, exclusively for the purposes that justify its retention.

Retention and Deletion 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 work instructions and other organizational documents necessary for their understanding (Section 147(1)(1) in conjunction with (3) AO, Section 14b(1) UStG, Section 257(1)(1) in conjunction with (4) HGB).
  • 8 years - Accounting documents, such as invoices and expense receipts (Section 147(1)(4) and (4a) in conjunction with (3), first sentence, AO, and Section 257(1)(4) in conjunction with (4) HGB) .
  • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents to the extent they are relevant for taxation, e.g., hourly wage slips, payroll sheets, costing documents, price tags, as well as payroll documents, provided they are not already accounting vouchers, and cash register receipts (Section 147(1)(2), (3), and (5) in conjunction with (3) of the German Fiscal Code (AO), Section 257(1)(2) and (3) in conjunction with (4) of the German Commercial Code (HGB)) .
  • 3 years – Data required to address potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on past business experience and standard industry practices, are stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Rights of Data Subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for the purpose of direct marketing, 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 related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw any consent you have given at any time.
  • Right of Access: You have the right to request confirmation as to whether your personal data is being processed, as well as access to such data, 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 correction of inaccurate data concerning you.
  • Right to Erasure and Restriction of Processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right, in accordance with legal requirements, 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 transmitted 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 workplace, or the place of the alleged infringement, if you believe that the processing of your personal data violates the provisions of the GDPR.

Provision of the Online Service and Web Hosting

We process users’ 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 device.

  • Types of data processed: Usage data (e.g., page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons); log data (e.g., log files regarding logins, data retrieval, or access times) Content data (e.g., textual or visual messages and posts, as well as related information such as details regarding authorship or the time of creation).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); Security measures; Audience measurement (e.g., access statistics, identification of returning visitors); Conversion measurement (measuring the effectiveness of marketing measures). Server monitoring and error detection.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of online services on rented server space: To provide our online services, we use server space, computing capacity, and software that we rent or otherwise obtain from a server provider (also known as a “web host”); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, a 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 may be used, on the one hand, for security purposes, e.g., to prevent server overload (particularly in the case of malicious attacks, so-called DDoS attacks), and, on the other hand, to ensure server capacity and stability; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.
  • Email Sending and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information regarding the email transmission (e.g., the providers involved) as well as the contents of the respective emails. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent in encrypted form over the Internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume any responsibility for the transmission path of the e between the sender and the recipient on our server; Legal basis: Legitimate interests (Art. 6( 1, sentence 1, lit. f) GDPR).
  • STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service Provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.strato.de; Privacy Policy:https://www.strato.de/datenschutz/. Data Processing Agreement: Provided by the service provider.
  • Squarespace: Squarespace offers Software as a Service for the creation and hosting of websites; Service Provider:Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://www.squarespace.com; Privacy Policy:https://www.squarespace.com/privacy; Data Processing Agreement: https://www.squarespace.com/dpa. B Basis for transfers to third countries:B Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.squarespace.com/dpa).

B Use of Cookies

The term “cookies” refers to functions that store and retrieve information on users’ end devices. Cookies may also be used for various purposes, such as ensuring functionality, security, and convenience of online services, as well as for analyzing visitor traffic. We use cookies in accordance with legal regulations. To this end, we obtain users’ consent in advance when necessary. If consent is not required, we rely on our legitimate interests. This applies when the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online services. Consent may be revoked at any time. We provide clear information regarding the scope of this and which cookies are used.

Notes on legal bases under data protection law: 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 storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, this allows the login status to be saved and preferred content to be displayed directly when the user visits a website again. Similarly, user data collected via cookies may be used for audience measurement. Unless we provide users with explicit information regarding the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users may revoke the consents they have given at any time and may also object to the processing in accordance with legal requirements, including through their browser’s privacy settings.

  • Types of data processed: Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, individuals involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further information on processing operations, procedures, and services:

  • Processing of cookie data based on consent: We use a consent management solution to obtain users’ consent for the use of cookies or for the procedures and providers specified within the consent management solution. This procedure serves to obtain, log, managing, and revoking consents, particularly with regard to the use of cookies and comparable technologies used to store, read, and process information on users’ end devices. As part of this procedure, users’ consents for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management procedure, . Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid repeated requests and to maintain proof of consent in accordance with legal requirements. Storage takes place on the server and/or in a cookie (so-called opt-in cookie) or using comparable technologies to associate the consent with a specific user or their device. Unless specific information regarding the providers of consent management services is available, the following general guidelines apply: Consent is stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, details regarding 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 basis: Consent (Art. 6(1)(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 to the extent necessary for its presentation and for communication between authors and readers, or for security reasons. For further details, please refer to the information regarding the processing of visitors to our publication medium within the scope of this privacy policy.

  • 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., textual or visual messages and posts, as well as related information such as details regarding authorship or the time of creation); Usage data (e.g., page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved).
  • Data subjects: Users (e.g., website visitors, users of online services) .
  • Purposes of processing and legitimate interests: Feedback (e.g., collection of feedback via online form); provision of our online offering and user-friendliness; security measures; organizational and administrative procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone posts unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be held liable for the comment or post and are therefore interested in the author’s identity.
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  • Furthermore, we reserve the right to process user data for the purpose of spam detection based on our legitimate interests.
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  • On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies to prevent multiple voting.
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  • The personal information provided in the context of comments and posts, any contact and website information, as well as the content details, are permanently stored by us until the user objects; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Contact and Inquiry Management

When contacting us (e.g., by mail, contact form, email, phone, or via social media) as well as within the context of existing user and business relationships, the information provided by the inquiring individuals is processed to the extent necessary to respond to contact inquiries and any requested actions.

  • Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as details regarding authorship or the time of creation); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, and involved individuals).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via an online form). Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further information on processing activities, procedures, and services:

  • Contact form: When you contact us via our contact form, by email, or through other communication channels, we process the personal data provided to us to respond to and handle the respective inquiry. This typically includes details such as your name, contact information, and, if applicable, additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal basis: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR) .
  • HubSpot CRM: Management of customer contacts, tracking of sales activities, automation of marketing campaigns, analysis of sales data, creation and management of email campaigns, integration with other tools and platforms, management of customer support inquiries, AI-powered content generation, personalized email creation, predictive sales forecasting, automated workflow descriptions, and AI chatbots for customer interaction; Service Provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central, Guild Street, Dublin 1, Ireland; Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://www.hubspot.de/ pa/crm; Privacy Policy: https://legal.hubspot.com/de/privacy-policy; Data Processing Agreement: https://legal.hubspot.com/dpa. Basis for Transfers to Third Countries:Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.hubspot.com/dpa).

Newsletters and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) exclusively with the recipients’ consent or on a legal basis. If the content of the newsletter is specified during the subscription process, this content is decisive for the user’s consent. To subscribe to our newsletter, providing your email address is usually sufficient. However, to offer you a personalized service, we may ask you to provide your name so we can address you personally in the newsletter or to provide additional information, if such information is necessary for the purpose of the newsletter.

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

The logging of the registration process is based on our legitimate interests for the purpose of verifying its proper . To the extent that we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.

Content:

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

  • 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 phone numbers) ; meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons). Usage data (e.g., page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g., via email or mail).
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
  • Right to object (opt-out): You may unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email, for this purpose.

Further information on processing procedures, methods, and services:

  • Measurement of open and click rates: The newsletters contain so-called “web beacons,” i.e., a pixel-sized file that is retrieved from our server or that of the newsletter provider—if we use a mailing service provider—when you open the newsletter. As part of this retrieval, technical information—such as details about your browser and system—as well as your IP address and the time of retrieval are initially collected. This information is used to technically improve our newsletter based on technical data or the target groups and their reading behavior, determined by their access locations (which can be identified using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. This information is assigned to individual newsletter recipients and stored in their profiles until they are deleted . The analyses help us identify our users’ reading habits and tailor our content to them, or send different content based on our users’ interests. The measurement of open rates and click-through rates, as well as the storage of measurement results in user profiles and their further processing, are based on the users’ consent. Unfortunately, it is not possible to revoke consent for performance measurement separately; in this case, the entire newsletter subscription must be canceled or you must object to it. In this case, the stored profile information will be deleted;; Legal basis: Consent (Art. 6(1)(a) GDPR).
  • HubSpot Email Marketing: Sending emails, creating personalized campaigns, automating workflows, segmenting target groups, integrating with CRM systems, analyzing performance through reports and dashboards; Service provider: HubSpot Ireland Limited, Ground Floor, Two Dockland Central Guild Street, Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hubspot.com/products/marketing/email; Privacy Policy: https://legal.hubspot.com/de/privacy-policy; Data Processing Agreement:https://legal.hubspot.com/dpa. B Basis for transfers to third countries:B Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.hubspot.com/dpa).

B Surveys and Polls

We conduct surveys and polls to collect information for the respective stated purpose of the survey or poll. The surveys and polls we conduct (hereinafter “Polls”) are evaluated anonymously. Personal data is processed only to the extent necessary for the provision and technical implementation of the surveys (e.g., processing the IP address to display the survey in the user’s browser or using a cookie to enable the survey to be resumed).

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as details regarding authorship or the time of creation). Usage data (e.g., page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • Data subjects: Participants.
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via an online form). Surveys and questionnaires (e.g., surveys with input fields, multiple-choice questions).
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

 

Social Media Presence

We maintain online presences on social media platforms and, in this context, process user data to communicate with users active on those platforms or to provide information about us.

Please note that user data may be processed outside the European Union in this context. This may entail risks for users, as, for example, this could 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 users’ behavior and the resulting interests. These profiles may in turn be used, for instance, to display advertisements within and outside the networks that are presumed to correspond to users’ interests . Therefore, cookies are generally stored on users’ computers to record their usage behavior and interests. Additionally, data may also be stored in these user profiles regardless of the devices used by the users (particularly 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 to object (opt-out) , please refer to the privacy policies and information provided by the operators of the respective networks.

We also note that requests for information and the exercise of data subject rights are most effectively addressed directly with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as details regarding authorship or the time of creation). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Instagram: Social network that enables sharing photos and videos, commenting on and liking posts, sending messages, and following profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for transfers to third countries: Data Privacy Framework (DPF) .
  • Facebook Pages: Profiles within the Facebook social network – The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page (“Fan Page”). This includes, in particular, information about user behavior (e.g., content viewed or interacted with, actions taken) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/.Facebook also uses this data to provide us with statistical analyses 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 (“Information on Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which governs, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users may therefore direct requests for information or deletion directly to Facebook. Users’ rights (in particular the right to access, erasure, objection, and lodging a complaint with 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 any potential transfer to Meta Platforms Inc. in the U.S.; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy:https://policies.google.com/privacy; Basis for third-country transfers:B Data Privacy Framework (DPF). B Opt-out option:B https://myadcenter.google.com/personalizationoff.

Plug-ins, 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 collectively referred to as “content”).

This integration always requires that the third-party providers of this content process the user’s IP address, as they would be unable to send the content to the user’s browser without it. The IP address is therefore necessary for the display of this content or these functions. We strive to use only such 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. Through “pixel tags,” information such as visitor traffic on the pages of this website can be analyzed. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details regarding the use of our online offering, as well as being linked to such information from other sources.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is this consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and user-friendly services). In this context, we would also like to draw your attention to the information regarding the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved). Event data (Facebook) (“Event data” refers to information sent to the provider Meta—for example, via Meta pixels (whether through apps or other channels)—that relates to individuals or their actions. This data includes details such as website visits, interactions with content and features, app installations, and product purchases. Event data is processed with the aim of creating target audiences for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. “Event data” is deleted by Meta after a maximum of two years, and the target audiences created from it are deleted when our Meta user accounts are deleted.
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; audience measurement (e.g., access statistics, identification of returning visitors); tracking (e.g., interest-based/behavioral profiling, use of cookies); audience targeting; marketing. Profiles containing user-related information (Creation of user profiles).
  • Retention 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(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Integration of third-party software, scripts, or frameworks (e.g., jQuery): We integrate software into our online offering that we retrieve from servers operated by other providers (e.g., function libraries that we use for the display or user-friendliness of our online offering). In doing so, the respective providers collect the users’ IP addresses and may process them for the purpose of transmitting the software to the users’ browsers, as well as for security purposes and to evaluate and optimize their offerings. - We integrate software into our online offering which we retrieve from servers operated by third-party providers (e.g., function libraries that we use to enhance the presentation or user-friendliness of our online offering). In doing so, the respective providers collect users’ IP addresses and may process them for the purpose of transmitting the software to the user’s browser, for security purposes, as well as for the evaluation and optimization of their services; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Facebook Plugins and Content: Facebook Social Plugins and Content - This may include, for example, content such as images, videos, or text and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https: //developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, in the context of a transfer (but not the further processing), of “event data” that Facebook collects via the Facebook social plugins (and content embedding features) running on our online offering, or receives as part of a transfer for the following purposes: a) Displaying content and advertising information that corresponds to users’ presumed interests; b) Delivery of commercial and transaction-related messages (e.g., contacting users via Facebook Messenger); c) Improvement of ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is presumed to correspond to users’ interests). We have entered into a special agreement with Facebook (“Addendum for Controllers,” https:// www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not take place under joint controllership but rather on the basis of a data processing agreement (“Data Processing Terms,” https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the U.S., on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum,” https://www.facebook.com/legal/EU_data_transfer_addendum) . Users’ rights (in particular the right to access, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy Policy:https://www.facebook.com/privacy/policy/. Basis for Transfers to Third Countries: Data Privacy Framework (DPF).
  • Instagram Plugins and Content: Instagram Plugins and Content - This may include, for example, content such as images, videos, or text, as well as buttons that allow users to share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, within the scope of a transfer (but not the further processing), of “Event Data” that Facebook collects via Instagram features (e.g., content embedding features) executed on our online offering or receives as part of a transfer for the following purposes: a) Displaying content and advertising information that corresponds to users’ presumed interests; b) Delivery of commercial and transactional messages (e.g., contacting users via Facebook Messenger); c) Improvement of ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is presumed to correspond to users’ interests). We have entered into a special agreement with Facebook (“ Addendum for Controllers," https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not take place under joint controllership but rather on the basis of a data processing agreement (“Data Processing Terms,” https://www.facebook.com/legal/terms/dataprocessing) and, with regard to processing in the U.S., on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum,” https://www.facebook.com/legal/EU_data_https://www.facebook.com/legal/terms/ data_security_terms) and, with regard to processing in the U.S., on the basis of standard contractual clauses ("Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum) . Users’ rights (in particular the right to access, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/.
  • YouTube Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.youtube.com; Privacy Policy:https://policies.google.com/privacy; Basis for transfers to third countries:B Data Privacy Framework (DPF). Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.

Changes and Updates

We ask that you regularly review the content of our Privacy Policy. We will update the Privacy Policy as soon as changes to our data processing activities make this necessary. We will notify you as soon as the changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this Privacy Policy, please note that these addresses may change over time, and we ask that you verify the information before contacting them.

Definitions

This section provides an overview of the terms used in this Privacy Policy. To the extent that these terms are defined by law, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • Master data: Master data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
  • Content data: Content data encompasses information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates
  • Contact data:
  • Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses, and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.
  • Conversion tracking: Conversion tracking (also known as “visit-action analysis”) is a method used to determine the effectiveness of marketing measures. To do this, a cookie is typically stored on users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Meta, communication, and process data: Meta, communication, and process data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include details on file size, creation date, the author of a document, and revision histories. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission methods. Operational data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, as well as audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information that reveals how users use applications, which features they prefer, how long they stay on specific pages, and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
  • Personal Data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie), or to one or more specific characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles containing user-related information: The processing of “profiles containing user-related information,” or " “profiles” encompasses any form of automated processing of personal data that consists of using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.). e.g., interests in specific content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data consists of information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details regarding the use or operation of a system. Log data is often used to analyze system issues, for security monitoring, or to generate performance reports.
  • Audience measurement: Audience measurement (also known as web analytics) is used to evaluate visitor traffic to an online service and can include the behavior or interests of visitors regarding specific information, such as e.g., website content. With the help of web analytics, operators of online services can, e.g., identify at what times users visit their websites and what content they are interested in. This allows them, for example, to better tailor the content of their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to identify returning visitors and thus obtain more accurate analyses of the use of an online service.
  • Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online service and use the processed data to technically optimize our online service. We process performance, load, and comparable technical metrics that provide information about the stability and any anomalies in our online service. In the event of errors or anomalies, individual user requests of our online service are recorded to identify and resolve the sources of problems.
  • Tracking: “Tracking” refers to the ability to track user behavior across multiple online services. Typically, behavioral and interest-based information regarding the online services used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: The “controller” is the natural or legal person, public authority, institution, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it be the collection, evaluation, storage, transmission, or deletion.
  • Contract Data: Contract data consists of specific information relating to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged, or sold. This data category is essential for the administration and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the nature of the agreed-upon services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
  • Target audience creation: The term “Custom Audiences” refers to when target groups are identified for advertising purposes, such as displaying advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be inferred that this user is interested in advertisements for similar products or the online store where they viewed the products. The term “Lookalike Audiences” (or similar target groups) refers to the display of content deemed suitable to users whose profiles or interests are presumed to correspond to those of the users on whose profiles the audience was based. Cookies and web beacons are typically used for the purpose of creating Custom Audiences and Lookalike Audiences.