Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to briefly 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 connection with the provision of our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

Last updated: July 29, 2026

Table of Contents

Controller

Christina Ternes Dietrich-Bonhoeffer-Str. 18 10407 Berlin

Email address: webmaster23@tinaternes.com

Overview of Processing Activities

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

Types of Data Processed

  • Inventory data.
  • 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.
  • Prospective customers.
  • 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.
  • Remarketing.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online offering and user experience.
  • Information technology infrastructure.
  • Whistleblower protection.
  • Public relations.
  • Business processes and administrative procedures.

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 base our processing of personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in this 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 a party, or for taking steps at the request of the data subject prior to entering into a contract.
  • 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 a third party, except where such interests are overridden by the interests, fundamental rights, and fundamental freedoms of the data subject that 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. This includes, in particular, the Act to Adapt Data Protection Law to Regulation (EU) 2016/679 and to Implement Directive (EU) 2016/680 (Bundesdatenschutzgesetz – BDSG, Federal Data Protection Act). The BDSG contains, in particular, special regulations regarding 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 the transmission as well as automated decision-making in individual cases, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

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 processing, as well as the varying likelihood of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to it, its entry, transfer, ensuring its availability, and its separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data-protection-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): In order to protect the data of users transmitted through 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, being the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

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 transmission of data to other persons, entities, or companies (which is 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 entered into Standard Contractual Clauses with the respective providers, which comply with the requirements 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 layer of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should any changes occur within the framework of the DPF, the Standard Contractual Clauses will take effect as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of any political or legal changes.

For each individual service provider, 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 website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding safeguards apply, in particular Standard Contractual Clauses, explicit consent, or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found on the EU Commission’s information portal: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

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 no further legal grounds for processing exist. This applies to cases in which the original purpose of processing no longer applies or the data are no longer needed. Exceptions to this rule apply where legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the pursuit of legal claims or for the protection of 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 applies specifically to particular processing operations.

Where several retention or deletion periods are specified for a given piece of data, the longest period shall always apply. Data that is no longer retained for its originally intended purpose, but rather due to legal requirements or other reasons, will be processed exclusively for the reasons 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 working instructions and other organizational documents required for their understanding (Section 147(1) No. 1 in conjunction with (3) of the German Fiscal Code (AO), Section 14b(1) of the German VAT Act (UStG), Section 257(1) No. 1 in conjunction with (4) of the German Commercial Code (HGB)).
  • 8 years – Accounting vouchers, such as invoices and expense receipts (Section 147(1) No. 4 and 4a in conjunction with (3) sentence 1 AO, as well as Section 257(1) No. 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 insofar as they are relevant for taxation purposes, e.g., hourly wage records, operating accounting sheets, calculation documents, price labeling, as well as payroll documents insofar as they are not already accounting vouchers, and cash register tapes (Section 147(1) No. 2, 3, 5 in conjunction with (3) AO, Section 257(1) No. 2 and 3 in conjunction with (4) HGB).
  • 3 years – Data required to take into account potential warranty and damage claims or similar contractual claims and rights, and to process related inquiries, based on past business experience and common industry practice, are stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 of the German Civil Code (BGB)).

Commencement of periods at the end of the year: If a period does not expressly begin on a specific date and amounts to at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the triggering event is the point in time at which the termination or other ending of the legal relationship becomes effective.

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 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes 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 given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to request access to this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to demand that data concerning you be deleted without delay, or alternatively, to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with the legal requirements, in a structured, commonly used, and machine-readable format, or to request that it be transferred 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, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Business Services

We process the personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers, and other cooperation partners (collectively referred to as “contractual partners”), for the purposes of initiating, executing, and processing contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures carried out upon request, as well as communication related to the respective contractual relationship.

The processing serves in particular to fulfill our primary and ancillary contractual obligations. This includes the provision of the agreed services, any update and information obligations, the handling of warranty claims and other performance disruptions, the processing of withdrawals, terminations of continuing obligations, reversals, refunds, as well as the handling of other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.

We process, 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 the subject matter of the contract, contract term, order or process number; usage and performance data; payment and billing data; as well as communication content and history. Where necessary, we also process data disclosed or transmitted to us in the course of carrying out an order.

Furthermore, we process the data to safeguard our rights and to fulfill legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations, and, where applicable, verification and accountability obligations. In addition, processing takes place on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and our contractual partners from misuse, threats to data, trade secrets, and other legal interests. 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 advisors, or other agents, insofar as this is necessary for the performance of the contract or to fulfill legal obligations.

Personal data will only be disclosed to third parties insofar as this is necessary for the performance of the contract, for carrying out pre-contractual measures, for safeguarding legitimate interests, or for fulfilling legal obligations. We will inform you separately, within the framework of this privacy policy, of any further processing, in particular for marketing purposes.

We inform contractual partners which data is required in individual cases as part of the data collection process, for example through appropriate labeling in online forms or during personal contact.

Data will be deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations preclude deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in connection with a specific order will be deleted upon completion of the order and expiry of any applicable retention periods, provided no further legal or contractual obligations to retain the data exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and for fulfilling the respective contractual relationship, as well as Art. 6(1)(c) GDPR for fulfilling legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Insofar as the processing is based on Art. 6(1)(f) GDPR, it serves to safeguard our legitimate interests in a proper and efficient business organization, internal administration and documentation of business transactions, the assertion and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, as well as the economic management and further development of our business operations. These interests consist in particular of ensuring a secure and legally compliant business operation as well as safeguarding our entrepreneurial capacity to act.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and time spent, 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, timestamps, identification numbers, persons involved).
  • Data subjects concerned: Service recipients and clients; prospective customers; business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures; business processes and administrative procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1(b) GDPR); legal obligation (Art. 6(1) sentence 1(c) GDPR); legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Further information on processing operations, procedures, and services:

  • Online shop, order forms, e-commerce, and performance of services: We process the data of our customers in order to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and provision, delivery, or performance. Where necessary for the execution of an order, we engage service providers, in particular postal, freight, and shipping companies, to carry out the delivery or performance vis-à-vis our customers. For processing payment transactions, we make use of the services of banks and payment service providers. The required information is identified as such within the order or comparable purchasing process and includes the information needed for delivery, or provision, and billing, as well as contact information to allow for any necessary follow-up communication. Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1(b) GDPR).

Use of Online Platforms for Marketing and Sales Purposes

We offer our services on online platforms operated by other service providers. In this context, the privacy notices of the respective platforms apply in addition to our own privacy notices. This applies in particular with regard to the processing of payment transactions and the procedures used on the platforms for reach measurement and interest-based marketing.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and time spent, 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, timestamps, identification numbers, persons involved).
  • Data subjects concerned: Service recipients and clients; business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; marketing; business processes and administrative procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1(b) GDPR); legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Further information on processing operations, procedures, and services:

  • Singulart

    • Singulart: Online marketplace for art and online art gallery; service provider: Singulart SAS, 25 Rue du Petit Musc, 75004 Paris, France; legal bases: legitimate interests (Art. 6(1) sentence 1(f) GDPR); website: https://www.singulart.com/de; privacy policy: https://www.singulart.com/de/privacy (also accessible via the “Privacy Center” on the website).

  • Artmajeur

    • Artmajeur: Online marketplace for art and online art gallery; service provider: Artmajeur SARL, 494 Rue Léon Blum, 34000 Montpellier, France; legal bases: legitimate interests (Art. 6(1) sentence 1(f) GDPR); website: https://www.artmajeur.com/de; privacy policy: https://www.artmajeur.com (accessible in the footer under “Privacy Policy”).

Provision of the Online Offering and Web Hosting

We process user data in order to be able to provide our online services to users. For this purpose, we process the user’s IP address, which is necessary in order 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 time spent, 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, timestamps, identification numbers, persons involved); log data (e.g., log files concerning logins or the retrieval of data or access times); content data (e.g., textual or visual messages and posts as well as information relating to them, such as details on authorship or the time of creation).
  • Data subjects concerned: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of the online offering on our own/dedicated server hardware: To provide our online offering, we use server hardware operated by us, as well as the associated storage space, computing capacity, and software; legal bases: legitimate interests (Art. 6(1) sentence 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 web pages and files accessed, date and time of access, amounts of data 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. Server log files can be used, on the one hand, for security purposes, e.g., to avoid overloading the servers (in particular in the case of malicious attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilization and stability of the servers; legal bases: legitimate interests (Art. 6(1) sentence 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 excluded from deletion until the respective incident has been finally clarified.
  • 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 relating to the sending of emails (e.g., the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of spam detection. Please note that emails are generally not sent in encrypted form on 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 can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server; legal bases: legitimate interests (Art. 6(1) sentence 1(f) GDPR).
  • WordPress.com: Hosting and software for the creation, provision, and operation of websites, blogs, and other online offerings; service provider: Automattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; legal bases: legitimate interests (Art. 6(1) sentence 1(f) GDPR); website: https://wordpress.com; privacy policy: https://automattic.com/de/privacy/; data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider).

Use of Cookies

The term “cookies” refers to functions that store information on users’ end devices and read information from them. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows. We use cookies in accordance with legal requirements. To this end, we obtain the prior consent of users where necessary. Where consent is not required, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to provide content and functions expressly requested by the user. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We provide clear information about its scope and which cookies are used.

Information on legal bases under data protection law: Whether we process personal data using cookies depends on consent. Where consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

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

General information on withdrawal and objection (opt-out): Users may withdraw any consent they have given at any time and may also object to the processing in accordance with legal requirements, including by means of their browser’s privacy settings.

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

Further information on processing operations, procedures, and services:

  • Processing of cookie data based on consent: We use a consent management solution in which users’ consent to the use of cookies or to the procedures and providers named within the consent management solution is obtained. This procedure serves to obtain, log, manage, and withdraw consent, in particular with regard to 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’ consent for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure, is obtained. Users also have the option of managing and withdrawing their consent. Consent declarations are stored in order to avoid a repeated request and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies, in order to be able to associate the consent with a specific user or their device. Unless specific information on the providers of consent management services is available, the following general information applies: The consent is stored for a period of up to two years. In doing so, a pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of the consent (e.g., the categories of cookies and/or service providers concerned), and information about the browser, system, and end device used; legal bases: consent (Art. 6(1) sentence 1(a) GDPR).

Contact and Inquiry Management

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 information provided by the inquiring persons is processed insofar as this is necessary to respond to the contact inquiries and any requested actions.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts as well as information relating to them, such as details on authorship or the time of creation); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects concerned: 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 offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Legitimate interests (Art. 6(1) sentence 1(f) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1(b) GDPR).

Further information on processing operations, procedures, and services:

  • Contact form: When contacting us via our contact form, by email, or through other means of communication, we process the personal data transmitted to us in order to respond to and process the respective inquiry. This generally includes information such as name, contact information, and, where applicable, further information communicated to us that is required 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) sentence 1(b) GDPR), legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Web Analytics, Monitoring, and Optimization

Web analytics (also referred to as “reach measurement”) serves to evaluate the flow of visitors to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, in pseudonymous form. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite repeat use. Likewise, we are able to understand which areas require optimization.

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

Unless otherwise indicated below, profiles—i.e., data combined into a usage process—may be created for these purposes, and information may be stored in a browser or on an end device and then read out. The information collected includes, in particular, the websites visited and the elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. Insofar as users have consented to the collection of their location data vis-à-vis us or the providers of the services we use, the processing of location data is also possible.

In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no plain-text user data (such as email addresses or names) is stored within the framework of web analytics, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Information on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for the data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, 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 time spent, 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, timestamps, identification numbers, persons involved).
  • Data subjects concerned: 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); remarketing.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.” Storage of cookies for up to 2 years (unless otherwise indicated, cookies and similar storage methods may 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(1) sentence 1(a) GDPR); legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Further information on processing operations, procedures, and services:

  • Matomo: Matomo is software used for the purposes of web analytics and reach measurement. When using Matomo, cookies are generated and stored on the user’s end device. The user data collected through the use of Matomo is processed exclusively by us and is not shared with third parties. Cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; legal bases: consent (Art. 6(1) sentence 1(a) GDPR). Deletion of data: Cookies have a maximum storage period of 13 months.

Presence on Social Networks (Social Media)

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

We would like to point out that user data may be processed outside the territory of the European Union in this context. This may pose risks for users, as it could, for example, make it more difficult to enforce user rights.

Furthermore, the data of users within social networks is generally 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 within and outside the networks that presumably correspond to users’ interests. For this purpose, cookies are generally stored on users’ computers, in which the usage behavior and interests of users are stored. In addition, data may also be stored in usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).

For a detailed presentation of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Also with regard to requests for information and the exercise of data subject rights, we would like to 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 take appropriate measures directly and provide information. Should you nevertheless require assistance, you may contact us.

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

Further information on processing operations, procedures, and services:

  • Instagram: Social network, enables the sharing of photos and videos, commenting on and favoriting posts, sending messages, and 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) sentence 1(f) GDPR); website: https://www.instagram.com; privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).

Plug-ins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the users’ IP address, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, visit time, and other information on the use of our online offering, but may also be combined with such information from other sources.

Information on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for the data processing is such consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, 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 time spent, 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, timestamps, identification numbers, persons involved).
  • Data subjects concerned: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.” Storage of cookies for up to 2 years (unless otherwise indicated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal bases: Consent (Art. 6(1) sentence 1(a) GDPR); legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Further information on processing operations, procedures, and services:

  • Google Fonts (obtained from Google servers): Retrieval of fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform display, and consideration of possible licensing restrictions. The font provider is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for providing the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts, and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google’s servers, and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged and used for debugging purposes and to generate aggregated usage statistics used to measure the popularity of font families. These aggregated usage statistics are published on the “Analytics” page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertisements; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: legitimate interests (Art. 6(1) sentence 1(f) GDPR); website: https://fonts.google.com/; privacy policy: https://business.safety.google/privacy/; basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

  • Spam and bot protection through Cloudflare: We use services from Cloudflare, Inc. on our website to protect our website from unwanted access, spambots, DDoS attacks, and malware. For this purpose, traffic between your browser and our server is routed through and analyzed by Cloudflare’s global network.

    Data processed: IP address, system configuration information, request information (HTTP headers), and log data. Legal basis: Legitimate interests (Art. 6(1) sentence 1(f) GDPR). Our legitimate interest lies in ensuring IT security, defending against spam and bot attacks, and safeguarding the accessibility of our website. Third-country transfer (USA): The data transfer to the USA is based on the EU-U.S. Data Privacy Framework (DPF), under which Cloudflare, Inc. is certified, as well as on the European Commission’s Standard Contractual Clauses.

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require you to cooperate (e.g., consent) or require any other individual notification.

Insofar as we provide addresses and contact information for companies and organizations in this privacy policy, please note that addresses may change over time, and we ask that you verify the information before making contact.

Definitions of Terms

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

  • Employees: Employees refers to persons who are in an employment relationship, whether as staff members, salaried 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 employer’s obligation to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various phases, including its establishment, in which the employment contract is concluded; its performance, in which the employee carries out their work; and its termination, when the employment relationship ends, whether through dismissal, termination agreement, or otherwise. Employee data is all information relating to these persons 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 evaluations.
  • Inventory data: Inventory data comprises essential information necessary for identifying and managing contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities, or systems, by enabling clear identification and communication.
  • Content data: Content data comprises 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 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, communication, and procedural data are categories that contain information about the manner in which 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 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 through various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, records of transactions and activities, as well as audit logs used to track and review processes.
  • Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data encompasses a wide range of information showing how users use applications, which functions they prefer, how long they linger on certain pages, and through which paths they navigate an application. Usage data may 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 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 factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information,” or “profiles” for short, comprises any form of automated processing of personal data consisting 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 relate to various 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: Log data is information about events or activities that have been recorded 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, for security monitoring, or to generate performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the flow of visitors to an online offering and may include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and in what content they are interested. This allows them, for example, to better adapt the content of their 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 accurate analyses of the use of an online offering.
  • Remarketing: “Remarketing” or “retargeting” refers to the practice of noting, for advertising purposes, which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g., in advertisements.
  • Controller: “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: “Processing” is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether it be collection, evaluation, storage, transmission, or deletion.
  • Contract data: 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 category of data 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 may include the start and end dates of the contract, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
  • Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and invoice information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.

Created with the free privacy policy generator from Dr. Thomas Schwenke, Datenschutz-Generator.de