Privacy Policy

Preamble

With the following Privacy Policy, we would like to inform you about what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. This Privacy Policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “Online Offer”).

The terms used are not gender-specific.

As of: May 5, 2026

Table of contents

Data Controller

ROVEMA GmbH
Industriestrasse1
35463 Fernwald

Authorized representatives: Karl Pühringer, Dr. Dirk Panhans

Email address: info@rovema.de

Phone: +49 (0)641/409-0

Legal Notice: www.rovema.com/impressum/

Contact Data Protection Officer

Michaela Genderka
Data Protection Officer (TÜV)
eMGe-DaTa Systematic Data Protection
Michaela Genderka
Blumenstraße 13, 47918 Tönisvorst
Email: m.genderka@emge-data.de
+49 (0) 2151 94 22 060

Overview of data processing

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

Types of data processed

  • Master data.
  • Employee data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and process data.
  • Log data.

Categories of data subjects

  • Service recipients and clients.
  • Employees.
  • Prospective clients.
  • Communication partners.
  • Users.
  • Business and contractual partners.
  • Third parties.
  • Customers.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Audience measurement.
  • Tracking.
  • Office and organizational procedures.
  • Remarketing.
  • Target group formation.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online services and user-friendliness.
  • IT infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and management procedures.

Relevant legal bases

Applicable legal bases under the GDPR: Below is an overview of the legal bases under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your country of residence or our country of domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the Privacy Policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request.
  • 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 data protection regulations apply in Germany. These include, in particular, the Act on the Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and the transfer of data, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

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

Security Measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, and disclosure of the data, ensuring its availability, and its segregation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the erasure of data, and responses to data breaches. Furthermore, we take the protection of personal data into account from the very beginning of the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default, as set forth in , through technical design and privacy-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the 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 encrypted.

Transmission of Personal Data

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

International Data Transfers

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

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

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

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

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, explicit consent, or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found on the European Commission’s website: 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 provisions as soon as the underlying consents are revoked or there are no further legal grounds for processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule apply if legal obligations or 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 proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.

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

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

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

  • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents necessary for their understanding (Section 147(1)(1) in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) No. 1 in conjunction with (4) HGB).
  • 8 years – accounting documents, such as invoices and expense receipts (Section 147(1)(4) and (4a) in conjunction with (3), first sentence, AO, and Section 257(1)(4) in conjunction with (4) HGB).
  • 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents to the extent they are relevant for taxation, e.g. hourly wage slips, operating statement forms, cost calculation documents, price tags, as well as payroll documents, provided they are not already accounting vouchers, and cash register receipts (Section 147(1)(2), 3, 5 in conjunction with para. 3 AO, § 257 para. 1 nos. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years – Data necessary to address potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on past business experience and standard industry practices, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and lasts 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 under which data is stored, the event triggering the time limit is the date on which the termination or other termination 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 through 21 of the GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out pursuant to Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed, as well as access to this data, further information, and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the location of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

Business processes and procedures

Personal data of service recipients and clients—including customers, clients, or, in specific cases, clients, patients, or business partners, as well as other third parties—is processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The data collected serves to fulfill contractual obligations and to organize operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies, and the assurance of internal accounting and financial processes. Additionally, the data supports the protection of the controller’s rights and facilitates administrative tasks as well as the organization of the company.

Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. Upon expiration of statutory retention periods or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.

  • 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 phone numbers); Content data (e.g., textual or visual messages and posts, as well as related information such as details regarding authorship or the time of creation); Contract data (e.g., subject matter of the contract, term, customer category); Log data (e.g., log files regarding logins, data retrieval, or access times); 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 process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Employee data (information regarding employees and other individuals in an employment relationship).
  • Data subjects: Service recipients and clients; prospective clients; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services); employees (e.g., staff, applicants, temporary workers, and other personnel). Customers.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; financial and payment management; security measures. IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legitimate interests (Art. 6(1)(f) GDPR). Legal obligation (Art. 6(1)(c) GDPR).

Further information on processing operations, procedures, and services:

  • Customer Management and Customer Relationship Management (CRM): Procedures required within the scope of customer management and customer relationship management (CRM) (e.g., customer acquisition in compliance with data protection requirements, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with due regard for data protection, data management and analysis to support customer relationships, administration of CRM systems, secure account management, customer segmentation, and target group formation); Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Contact management and maintenance: Procedures necessary for the organization, maintenance, and security of contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adjusting contact strategies); Legal basis: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • General payment transactions: Procedures necessary for the execution of payment transactions, the monitoring of bank accounts, and the control of cash flows (e.g., creation and verification of wire transfers, processing of direct debits, review of account statements, monitoring of incoming and outgoing payments, management of returned direct debits, account reconciliation, cash management); Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Accounting, Accounts Payable, Accounts Receivable: Procedures necessary for the recording, processing, and control of business transactions in the area of accounts payable and accounts receivable (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, handling of dunning procedures, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Financial Accounting and Taxes: Procedures required for the recording, management, and control of financial transactions, as well as for the calculation, reporting, and payment of taxes (e.g., account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning procedures, account reconciliation, tax consulting, preparation and filing of tax returns, handling of tax matters); Legal basis: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Sales: Processes required for the planning, implementation, and monitoring of measures for the marketing and sale of products or services (e.g., customer acquisition, quotation preparation , and follow-up, order processing, customer consultation and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Marketing, Advertising, and Sales Promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and target group identification, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Public Relations: Processes required in the context of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media coverage, organization of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Guest Wi-Fi: Procedures necessary for the setup, operation, maintenance, and monitoring of a wireless network for guests (e.g., installation and configuration of Wi-Fi access points, creation and management of guest accounts, monitoring of the network connection, ensuring network security, troubleshooting connection issues, updating network software, compliance with data protection regulations); 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).

Provision of online services and web hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage data (e.g., page views and duration of visit, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons). Log data (e.g., log files regarding logins, data retrieval, or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, processes, and services:

  • Provision of online services on rented server space: To provide our online services, we use server space, computing capacity, and software that we rent or otherwise obtain from a server provider (also known as a “web host”); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, a notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (particularly in the case of malicious attacks, so-called DDoS attacks), and, on the other hand, to ensure server capacity and stability; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.
  • dogado: Services in the field of providing IT infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: dogado GmbH, Saarlandstr. 25, D-44139 Dortmund, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:www.dogado.de; Privacy Policy:www.dogado.de/legal/datenschutz. Data Processing Agreement: Provided by the service provider.

Use of Cookies

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

Notes on the legal basis under data protection law: 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: Cookies are classified into the following categories based on their storage duration:

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

General Information on Withdrawal and Objection (Opt-out): Users may withdraw the consent they have provided at any time and may also object to the processing in accordance with legal requirements, including through their browser’s privacy settings.

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

Further information on processing operations, procedures, and services:

  • Processing of cookie data based on consent: We use a consent management solution to obtain users’ consent for the use of cookies or for the procedures and providers specified within the consent management solution. This procedure serves to obtain, log, manage, and revoke consents, particularly with regard to the use of cookies and comparable technologies used to store, read, and process information on users’ end devices. As part of this process, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management process. Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid repeated requests and to maintain proof of consent in accordance with legal requirements. Storage takes place on the server and/or in a cookie (so-called opt-in cookie) or via comparable technologies to enable the consent to be assigned to a specific user or their device. Unless specific information regarding the providers of consent management services is available, the following general guidelines apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, details regarding the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, the system, and the end device used; Legal basis: Consent (Art. 6(1)(a) GDPR).
  • CookieFirst: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of notices regarding data protection and cookies, enabling users to revoke or adjust their consents; Service provider: Digital Data Solutions B.V., Plantage Middenlaan 42a, 1018 DH Amsterdam, Netherlands; Website:cookiefirst.com/de/; Privacy policy:cookiefirst.com/legal/privacy-policy/; Additional information: Stored data (on the service provider’s server): The user’s IP address, date and time of consent, browser information, the URL from which consent was submitted, an anonymous, random, and encrypted key value, and the user’s consent status.
This cookie table was created and updated by the CookieFirst consent management platform.

Contact and Inquiry Management

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

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

Further information on processing procedures, processes, and services:

  • Contact Form: When you contact us via our contact form, by email, or through other communication channels, we process the personal data you provide to respond to and handle your inquiry. This typically includes information such as your name, contact details, and, if applicable, additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal bases: Contract performance 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 “newsletters”) exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during the subscription process, this content is decisive for the user’s consent. To subscribe to our newsletter, providing your email address is usually sufficient. However, in order to offer you a personalized service, we may ask you to provide your name so we can address you personally in the newsletter, or to provide additional information if it is necessary for the purpose of the newsletter.

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

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

Content:

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

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

Further information on processing procedures, methods, and services:

  • Brevo: Email delivery and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:www.brevo.com; Privacy Policy:www.brevo.com/legal/privacypolicy/. Data Processing Agreement: Provided by the service provider.

Further information on processing methods, procedures and services used:

  • Measurement of opening rates and click rates: The newsletters contain a so-called "web beacons", which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website:https://www.brevo.com/; Privacy Policy:https://www.brevo.com/de/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy decision (Germany).

Web Analysis, Monitoring and Optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include pseudonymized data on visitor behavior, interests, or demographic information, such as age or gender. With the help of reach analysis, we can, for example, determine at what times our online offering or its functions and content are most frequently used, or encourage repeat visits. It also allows us to identify which areas require optimization.

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

Unless otherwise specified below, profiles—i.e., data aggregated for a specific usage session—may be created for these purposes, and information may be stored in a browser or on a device and subsequently retrieved. The data collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and details regarding usage times. If users have consented to the collection of their location data by us or by 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 truncating the IP address) to protect users. In general, no personally identifiable user data (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization; instead, pseudonyms are used. 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, cost-effective, and user-friendly services). In this context, we would also like to draw your attention to the information regarding the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, individuals involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Audience measurement (e.g., access statistics, identification of returning visitors); profiles containing user-related information (creation of user profiles). Remarketing.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion." Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

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

 

Plug-ins, embedded functions, and content

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

This integration always requires that the third-party providers of this content process the user’s IP address, as they would be unable to send the content to the user’s browser without it. The IP address is therefore necessary for the display of this content or these functions. We strive to use only such content whose respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags allow information, such as visitor traffic on the pages of this website, to be analyzed. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details regarding the use of our online offering, as well as being linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-based/behavioral profiling, use of cookies); target group formation. Marketing.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion." Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Google Fonts (Retrieval from Google Server): Retrieval of fonts (and icons) for the purpose of technically secure, maintenance-free, and efficient use of fonts and icons with regard to up-to-date content and loading times, their consistent display, and consideration of potential licensing restrictions. The font provider is provided with 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 the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server belonging to the font provider in the United States. When visiting our website, users’ browsers send 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) from Google Fonts and, subsequently, 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 webpage 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 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 wishes to load fonts. This data is logged so that Google can determine how often a specific font family is requested. With the Google Fonts Web API, the user agent must match the font generated for the respective browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that 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 to generate an aggregated report on the top integrations based on the number of font requests. According to Google, it does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website:fonts.google.com; Privacy Policy:policies.google.com/privacy; Basis for transfers to third countries: Data Privacy Framework (DPF). Further information:developers.google.com/fonts/faq/privacy.
  • YouTube videos: Videos stored on YouTube are embedded within our online offering. These YouTube videos are integrated via a special domain using the “youtube-nocookie” component in what is known as “enhanced privacy mode.” In “enhanced privacy mode,” only information—including your IP address, browser details, and device information—that YouTube requires for the display, control, and optimization of the video ad may be stored on your device in cookies or via comparable methods until the video starts playing. Once you play the videos, additional information may be processed by YouTube for the purpose of analyzing usage behavior, storing data in the user profile, and personalizing content and ads. The storage period for cookies can be up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website:www.youtube.com; Privacy Policy:policies.google.com/privacy; Basis for transfers to third countries: Data Privacy Framework (DPF). Further information:support.google.com/youtube/answer/171780.

Changes and Updates

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

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

Definitions

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

  • Employees: Employees are defined as individuals who are in an employment relationship, whether as staff members, 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 compensation while the employee performs their work. The employment relationship comprises various phases, including the establishment phase, in which the employment contract is concluded; the performance phase, in which the employee performs their work; and the termination phase, when the employment relationship ends, whether through termination, a termination agreement, or otherwise. Employee data refers to all information relating to these individuals and pertaining to 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.
  • Master data: Master data comprises essential information required for the identification and management of 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, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique identification and communication.
  • Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates
  • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses, and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.
  • Meta, communication, and process data: Meta, communication, and process data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include details on file size, creation date, the author of a document, and change histories. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission methods. Process data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, as well as audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information that reveals how users utilize applications, which features they prefer, how long they stay on specific pages, and the paths they take to 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" refers to 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 specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles containing user-related information: The processing of “profiles containing user-related information,” or “profiles” for short, encompasses any form of automated processing of personal data that involves using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.), or to predict them (e.g., interests in specific content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data consists of information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details regarding the use or operation of a system. Log data is often used to analyze system issues, for security monitoring, or to generate performance reports.
  • Audience measurement: Audience measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and may include the behavior or interests of visitors regarding specific information, such as website content. With the help of audience analysis, operators of online offerings can, for example, determine at what times users visit their websites and what content they are interested in. This allows them, for example, to better tailor the content of their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to identify returning visitors and thus obtain more accurate analyses of the use of an online service.
  • Remarketing: The terms "remarketing" or "retargeting" refer to situations where, for example, a website records which products a user has shown interest in for advertising purposes, in order to remind the user of these products on other websites, such as through advertisements.
  • Tracking: "Tracking" refers to the ability to track users’ behavior across multiple online services. As a rule, behavioral and interest-based information regarding the online services used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: A “controller” is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collection, evaluation, storage, transmission, or deletion.
  • Contract Data: Contract data consists of specific information relating to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged, or sold. This data category is essential for the administration and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the nature of the agreed-upon services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. 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 to process payment transactions between buyers and sellers. This data is of critical importance for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification codes, and billing information. Payment data may also include information regarding payment status, chargebacks, authorizations, and fees.
  • Target Audience Creation: The term "Custom Audiences" refers to the process of defining target audiences for advertising purposes, such as displaying advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be inferred that this user is interested in advertisements for similar products or the online store where they viewed the products. The term "Lookalike Audiences" (or similar target groups) is used when content deemed suitable is displayed to users whose profiles or interests are presumed to match those of the users whose profiles were used to create the audience. Cookies and web beacons are typically used for the purpose of creating Custom Audiences and Lookalike Audiences.