Privacy Policy

Preamble

With the following privacy policy, we would like 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. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender-specific. Status: September 15, 2024

Table of Contents

• Preamble
• Controller
• Contact Data Protection Officer
• Overview of Processing Operations
• Relevant Legal Bases
• Security Measures
• Transfer of Personal Data
• General Information on Data Storage and Deletion
• Rights of Data Subjects
• Provision of the Online Offer and Web Hosting
• Contact and Inquiry Management
• Communication via Messenger
• Presence in Social Networks (Social Media)
• Changes and Updates
• Definitions

Controller

Sophia Huber
Salzburgerstraße 22
81241 Munich
Germany

Email address: [email protected]
Phone: +491711770590

Contact Data Protection Officer

Sophia Huber
[email protected]

Overview of Processing Operations

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

Types of Data Processed

• Inventory data.
• Contact data.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of Data Subjects

• Communication partners.
• Users.

Purposes of Processing

• Communication.
• Security measures.
• Organizational and administrative procedures.
• Feedback.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.
• Public relations.

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the 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 relevant 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 their personal data for one or more specific purposes.
• Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• 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 special provisions on the right to access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated 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 the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, disclosure, ensuring availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data compromise. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through privacy-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users 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 for users that their data is being transmitted securely and encrypted.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or there are no further legal grounds for processing. This applies to cases where the original processing purpose ceases to exist or the data is no longer needed. Exceptions to this rule exist if statutory retention obligations or special interests require 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 prosecution 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 deletion of data that specifically apply to certain processing operations.

If multiple retention periods or deletion deadlines are specified for a piece of data, the longest period is always applicable.

If a period does not explicitly start on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the period is the time when the termination or other termination of the legal relationship becomes effective.

Data that is no longer needed for the originally intended purpose but is retained due to legal requirements or other reasons is processed exclusively for the reasons justifying its retention.

Further Information on Processing Operations, Procedures and Services:

Retention and deletion of data: The following general periods apply for retention and archiving under German law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents necessary for their understanding, accounting documents and invoices (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
• 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters and other documents that are of importance for taxation, e.g. hourly wage slips, calculation documents, and claims for damages or similar contractual claims and rights to be considered as well as to process related inquiries, based on previous business experiences and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject under the GDPR, you have various rights, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and certain information.
• Right to rectification: You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.
• Right to erasure and restriction of processing: You have the right to obtain the erasure of personal data concerning you without undue delay, or, alternatively, to obtain restriction of processing of the data.
• Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
• Right to lodge a complaint with 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, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

Provision of the Online Offer and Web Hosting

We process users' data in order to provide them with our online services. For this purpose, we process the IP address of the user, 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. web pages visited and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved). Log data (e.g. log files concerning logins or data retrieval or access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: 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 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).

Further Information on Processing Operations, 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 "web hoster"); Legal bases: Legitimate interests (Art. 6(1)(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 may include the address and name of the retrieved web pages and files, date and time of retrieval, data volumes transferred, 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 for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability; Legal bases: 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 whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

Contact and Inquiry Management

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

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and posts as well as information relating to them, such as authorship or time of creation); Usage data (e.g. web pages visited and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offer 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)(b) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further Information on Processing Operations, Procedures and Services:

Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data provided to us to respond to and process the respective request. This usually includes information such as name, contact details and any additional information communicated to us and necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.

You can also contact us by alternative means, e.g. via telephone or email. Please use the contact options communicated to you or the contact options provided within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use a current version of the messengers with activated encryption to ensure that the encryption of the message contents is active.

However, we also point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and process technical information about the device of the communication partners and, depending on the settings of their device, also location information (so-called metadata).

Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they e.g. contact us on their own initiative, we use messenger in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and fulfillment of the needs of our communication partners for communication via messengers. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time.

• Types of data processed: Contact data (e.g. postal and email addresses or Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data provided to us to respond to and process the respective request. This usually includes information such as name, contact details and any additional information communicated to us and necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR). Content data (e.g. text or image messages and posts as well as information relating to them, such as authorship.
• Data subjects: Communication partners.
• Purposes of processing: Communication.
• Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
• Legal bases: Consent (Art. 6(1)(a) GDPR); Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Presence in Social Networks (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 European Union. This may result in risks for users, as this could, for example, make it more difficult to enforce users' rights.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data can be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in there).

For a detailed presentation of the respective forms of processing and the possibilities for objection (opt-out), we refer to the privacy policies and information 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 most effectively asserted with the providers. Only the providers have access to the users' data and can directly take appropriate measures and provide information. Should you still need help, then you can contact us.

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and posts as well as information relating to them, such as authorship or time of creation). Usage data (e.g. web pages visited and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: 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 bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Operations, Procedures and Services:

Instagram: Social network, enables sharing of photos and videos, commenting on and favoriting 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(1)(f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification becomes necessary due to the changes.

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

Definitions

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand.

• Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), birth dates and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities or systems by enabling unique assignment and communication.
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include texts, 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 itself, 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, telephone numbers, postal addresses and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
• Meta, communication and procedural data: Meta, communication and procedural data: are categories that contain information about how data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information about file size, creation date, document author and edit histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and 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 includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages and through which paths they navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are 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 ('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.
• Log data: Log data is 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 about the use or operation of a system. Log data is often used to analyze system problems, monitor security or create performance reports.
• Controller: The "controller" is 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: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or erasure.