HARIE

Privacy Policy

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that 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 "Online Offering").

The terms used are not gender-specific.

Last updated: February 19, 2026

Table of Contents

Controller

Marcel Plate
Berliner Str. 45
26127 Oldenburg

Email address: marcel@harie.coach

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.

Types of Data Processed

  • Master 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.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.
  • Participants.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Surveys and questionnaires.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.

Applicable Legal Bases

Applicable legal bases under the GDPR: The following provides an overview of the legal bases of 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 or our country of residence or domicile. 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.
  • Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG). The BDSG contains specific provisions on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and the transmission and automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual German federal states may also apply.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing, as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, in order 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 data, as well as access, input, transmission, availability assurance and separation of data. Furthermore, we have established procedures that 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 from the outset in the development and selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

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

Transfer of Personal Data

In the course of our processing of personal data, it may happen that data is transferred to or disclosed to other entities, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and in particular conclude appropriate contracts or agreements that serve to protect your data with the recipients 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 the context of using third-party services or the disclosure or transfer of data to other persons, entities or companies (which is evident from the postal address of the respective provider or when the privacy policy explicitly refers to data transfers to third countries), this always takes place in compliance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a safe legal framework by an adequacy decision of the EU Commission on July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers that 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 additional security. Should changes occur within the framework of the DPF, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected at all times, even in the event of political or legal changes.

For the 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 website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding 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 in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Retention 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 bases for processing exist. This applies to cases where the original processing purpose ceases to apply or the data is no longer needed. Exceptions to this rule exist 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 legal prosecution or for the protection of the rights of other natural or legal persons must be archived accordingly.

Our data protection notices contain additional information on the retention and deletion of data that apply specifically to certain processing operations.

Where there are multiple entries regarding the retention period or deletion deadlines for a datum, the longest period shall always prevail. Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons shall be processed exclusively for the reasons that justify its retention.

Data retention and deletion: The following general deadlines apply for retention and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the working instructions and other organizational documents necessary for their understanding (Section 147(1) No. 1 in conjunction with Section 147(3) of the German Fiscal Code (AO), Section 14b(1) of the German VAT Act (UStG), Section 257(1) No. 1 in conjunction with Section 257(4) of the German Commercial Code (HGB)).
  • 8 years - Accounting vouchers, such as invoices and cost receipts (Section 147(1) Nos. 4 and 4a in conjunction with Section 147(3) sentence 1 AO and Section 257(1) No. 4 in conjunction with Section 257(4) HGB).
  • 6 years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, other documents insofar as they are relevant for taxation purposes, e.g. hourly wage records, operating cost statements, calculation documents, price tags, but also payroll accounting documents insofar as they are not already accounting vouchers, and cash register receipts (Section 147(1) Nos. 2, 3, 5 in conjunction with Section 147(3) AO, Section 257(1) Nos. 2 and 3 in conjunction with Section 257(4) HGB).
  • 3 years - Data required to take into account potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, shall be stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 of the German Civil Code (BGB)).

Commencement of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it shall automatically commence 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 event triggering the period shall be the time at which the termination or other ending of the legal relationship takes effect.

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 those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is 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 obtain confirmation as to whether or not personal data concerning you is being processed, and to access such data, as well as further information and a copy of the data, in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be deleted without undue delay, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business Services

We process 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 purpose of initiating, executing and managing contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.

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

In particular, master data such as name, address and, where applicable, company name, contact data such as email address and telephone number, contract and service data such as subject matter, term, order or reference number, usage and service data, payment and billing data, as well as communication content and histories are processed. Where necessary, we also process data that is disclosed or transmitted to us in the course of an assignment.

Furthermore, we process data for the protection of our rights and for the fulfillment of legal obligations. This includes, in particular, commercial and tax law retention obligations, 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 the protection of our business operations and our contractual partners against misuse, endangerment of data, 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 the fulfillment of legal obligations.

The disclosure of personal data to third parties takes place exclusively insofar as this is necessary for the performance of the contract, the implementation of pre-contractual measures, the safeguarding of legitimate interests, or the fulfillment of legal obligations. We will separately inform you of any further processing, in particular for marketing purposes, within the scope of this privacy policy.

We inform the contractual partners of which data is required in each individual case in the context of data collection, for example in online forms through appropriate labeling or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and there are no legal retention obligations to the contrary. Legal retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the course of a specific assignment will be deleted after completion of the assignment and expiry of any retention periods, provided there are no further legal or contractual obligations to store them.

The legal basis for processing is Art. 6(1)(b) GDPR for the implementation of pre-contractual measures and the fulfillment of the respective contractual relationship, as well as Art. 6(1)(c) GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Where the processing is based on Art. 6(1)(f) GDPR, it serves to protect our legitimate interests in proper and efficient business organization, internal administration and documentation of business transactions, the enforcement and defense of legal claims, the assurance of IT and data security, the prevention of misuse and fraud, and the economic management and development of our business operations. These interests exist in particular in ensuring secure and legally compliant business operations and in safeguarding our entrepreneurial capacity to act.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter, term, customer category); Usage data (e.g. page views and dwell time, 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, persons involved).
  • Data subjects: 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 business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Online shop, order forms, e-commerce and service fulfillment: We process the data of our customers to enable them to select, acquire or order the chosen products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, shipping and freight companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the ordering or comparable acquisition process and includes the information required for delivery, provision and billing, as well as contact information to enable any necessary consultation; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • Provision of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "Users") in order to provide our contractual services to them and on the basis of legitimate interests to ensure the security of our offering and to develop it further. The required information is identified as such in the context of the order, purchase or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information to enable any necessary consultation; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Payment Procedures

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

The data processed by the payment service providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount and recipient-related information. The information is necessary to carry out the transactions. However, the data entered is only processed by and stored with the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or declining payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and credit checks. In this regard, we refer to the terms and conditions and privacy notices of the payment service providers.

The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the exercise of rights of withdrawal, information and other data subject rights.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter, term, customer category); Usage data (e.g. page views and dwell time, 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, persons involved).
  • Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Paddle: Payment services (technical integration of online payment methods); Service provider: Paddle.com Market Limited, Judd House, 18-29 Mora Street, London EC1V 8BT, United Kingdom; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Website: https://www.paddle.com; Privacy policy: https://www.paddle.com/legal/privacy. Basis for third-country transfers: Standard Contractual Clauses, Adequacy Decision (UK).

Provision of the Online Offering and Web Hosting

We process user data in order to provide our online services to them. For this purpose, we process the user's IP address, which is necessary to deliver 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 dwell time, 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, persons involved); Log data (e.g. log files concerning logins or data retrieval or access times). Content data (e.g. textual or visual messages and posts, as well as information relating to them, such as details of authorship or time of creation).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering 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 Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as "web host"); Legal bases: 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 web pages and files accessed, date and time of access, data volumes transferred, 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 can be used for security purposes, e.g. to avoid server overload (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilization and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally 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 recipients and senders, as well as further information relating to email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. We ask that you note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted in transit, 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 reception on our server; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of Cookies

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

Notes on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage duration: With regard to storage duration, 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 device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Similarly, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that cookies are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with legal requirements, including via the privacy settings of their browser.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons 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 notes on processing operations, procedures and services:

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

Registration, Login and User Account

Users can create a user account. During registration, users are informed of the required mandatory information and this is processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The data processed includes in particular login information (username, password and an email address).

In the course of using our registration and login functions and using the user account, we store the IP address and the time of the respective user action. Storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data is generally not disclosed to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so.

Users may be informed by email about events relevant to their user account, such as technical changes.

  • 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 information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). 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 and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organizational and administrative procedures. Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion". Deletion upon termination.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Registration with real names: Due to the nature of our community, we ask users to use our offering only with their real names. This means that the use of pseudonyms is not permitted; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • User profiles are not public: User profiles are not publicly visible or accessible.
  • Deletion of data upon termination: When users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • No obligation to retain data: It is the users' responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all data stored during the term of the contract; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

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 respond to the contact inquiries and any requested measures.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts, as well as information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further notes on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form, email or other communication channels, we process the personal data transmitted to us to respond to and process the respective inquiry. This usually includes information such as name, contact information and, where applicable, further 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).

Newsletter and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter "Newsletter") only with the consent of the recipients or on the basis of a legal permission. Insofar as the contents of the Newsletter are described in the course of registration, they are decisive for the users' consent. In order to subscribe to our Newsletter, it is generally sufficient to provide your email address. However, in order to provide you with a personalized service, we may request your name for personal address in the Newsletter or further information if this is necessary for the purpose of the Newsletter.

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

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the sending of emails, this takes place on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

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 telephone numbers). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6(1)(a) GDPR).
  • Opt-out option: You can cancel the receipt of our Newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the Newsletter either at the end of each Newsletter or you can use one of the contact options listed above, preferably email.

Promotional Communication via Email, Post, Fax or Telephone

We process personal data for the purposes of promotional communication, which may take place via various channels such as email, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke consents given at any time or to object to promotional communication at any time free of charge via the contact options mentioned above.

After revocation or objection, we store the data required to prove previous authorization for contact or sending for up to three years after the end of the year of the revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a potential defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the email address, telephone number, name).

  • 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 information relating to them, such as details of authorship or time of creation).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post); Marketing. Sales promotion.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Surveys and Questionnaires

We conduct surveys and questionnaires to gather information for the respectively communicated survey or questionnaire purpose. The surveys and questionnaires we conduct (hereinafter "Surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user's browser or to enable the survey to be resumed using a cookie).

  • 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 information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and dwell time, 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 online form). Surveys and questionnaires (e.g. surveys with input options, multiple-choice questions).
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Web Analytics, Monitoring and Optimization

Web analytics (also referred to as "reach measurement") is used to evaluate visitor flows to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at which times our online offering or its functions or content are most frequently used, or invite reuse. We can also identify which areas need optimization.

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

Unless otherwise stated below, profiles, i.e. data summarized in a usage process, may be created for these purposes and information may be stored in a browser or on a device and then read from it. The information collected includes, in particular, websites visited and elements used therein, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, location data may also be processed.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context 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.

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 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 refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. page views and dwell time, 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, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, detection of returning visitors); Profiles with user-related information (creating user profiles). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, 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)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analytics information to a device in order to identify which content users have accessed within one or multiple usage sessions, which search terms they used, revisited, or interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offering and technical aspects of their devices and browsers.
    In this process, pseudonymous profiles of users are created with information from the use of different devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. Analytics does, however, provide rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

Presences in Social Networks (Social Media)

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

We point out that user data may be processed outside the European Union. This may give rise to risks for users, as it could, for example, make it more difficult to enforce user rights.

Furthermore, user data within social networks is typically processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. These may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are generally stored on users' devices, in which the usage behavior and interests of users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (in particular if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing operations and the opt-out options, 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 latter have access to the user data and can directly take appropriate measures and provide information. Should you nevertheless need assistance, you can 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 of authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • 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 Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Instagram: Social network, enables the sharing of photos and videos, commenting on and favoriting posts, messaging, 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).

Plugins 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 be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "Content").

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not 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 such content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and further details about 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 the 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 refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. page views and dwell time, 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, persons involved).
  • Data subjects: 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 in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate into our online offering software that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). In doing so, the respective providers collect the IP address of the users and may process it for the purposes of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offering. - We integrate into our online offering software that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or user-friendliness of our online offering). In doing so, the respective providers collect the IP address of the users and may process it for the purposes of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offering; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Google Fonts (hosted on own server): Provision of font files for a user-friendly display of our online offering; Service provider: Google Fonts are hosted on our server, no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Google Fonts (retrieved from Google server): Retrieval of fonts (and symbols) for the purpose of a 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 provider of the fonts 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 that is necessary for the provision of 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 the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from 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 describing the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referral 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 customize the font generated for the respective browser type. The user agent is logged primarily for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts "Analytics" page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations can be generated based on the number of font requests. According to Google's own information, Google does not use any of the information collected by Google Fonts to create end user profiles or to display targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

Amendments and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as 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.

Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time and please check the information before contacting us.

Definitions

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

  • Master data: Master data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar allocations. 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). Master data forms the basis for any formal interaction between persons and services, facilities or systems by enabling unique allocation 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 may 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 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 persons 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 the way in which 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 information about file size, creation date, author of a document and change histories. Communication data captures the exchange of information between users via 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 workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing 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 showing how users use applications, which features they prefer, how long they spend on certain pages and through which paths they navigate 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. 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, includes any type 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 different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for system problem analysis, security monitoring or performance reporting.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate visitor flows of 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 which times users visit their websites and which content they are interested in. This enables 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 the purposes of reach analysis in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • 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, whether or not by automated means. The term is broad and covers practically any handling of data, be it 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 data category is essential for the management 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 start and end dates of the contract, the type of agreed services or products, pricing 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 includes all information required for the processing of payment transactions between buyers and sellers. This data is of critical importance for electronic commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank account details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorizations and fees.

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