Privacy Policy
Last updated: July 16, 2026
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, the purposes for which we process it, 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.
Table of Contents
- Preamble
- Controller
- Overview of processing activities
- Relevant legal bases
- Security measures
- Transfer of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Provision of the online offering and web hosting
- Use of cookies
- Online questionnaires for clients (Career Potential Test, kick-off questionnaire)
- Contact and inquiry management
- Newsletter and electronic notifications
- Advertising communication via email, mail, fax, or telephone
- Web analytics, monitoring, and optimization
- Presence on social networks (social media)
- Plug-ins and embedded functions and content
- Changes and updates
- Definitions
Controller
Nick Schäfer
Nick's Advisory
An der Mannsfaust 9
60599 Frankfurt am Main, Germany
Email address: nick@nicksadvisory.com
Overview of processing activities
The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of data processed
- Basic 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.
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.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Sales promotion.
- Business processes and administrative procedures.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. Should more specific legal bases 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 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, fundamental rights, and freedoms of the data subject that require protection of personal data.
National data protection regulations in Germany: In addition to the GDPR, national data protection regulations apply in Germany. This includes in particular the Act to Adapt Data Protection Law to Regulation (EU) 2016/679 and to Implement Directive (EU) 2016/680 (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, data protection laws of the individual federal states may apply.
Note on the applicability of the GDPR and the Swiss FADP: These privacy notices serve to provide information under both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader territorial scope and greater comprehensibility, the terminology of the GDPR is used. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss FADP, the terms used in the GDPR — "processing" of "personal data", "legitimate interest" and "special categories of data" — are used. However, the legal meaning of the terms continues to be determined by the Swiss FADP insofar as it applies.
Applicability of data protection provisions in the country of establishment: In the country in which the controller is established, national data protection provisions apply in addition to the General Data Protection Regulation (GDPR).
Security measures
In accordance with statutory requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, entry, disclosure, and availability of the data, and their segregation. We have also established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data risks. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data-protection-friendly default settings.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with 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.
Transfer of personal data
In the course of our processing of personal data, it may be transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks, or providers of services and content embedded on a website. In such cases, we comply with statutory requirements and, in particular, enter into corresponding contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Data processing in third countries: Insofar as we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or this occurs in the context of using third-party services or disclosing or transmitting data to other persons, bodies, or companies (which is apparent from the postal address of the respective provider, or if the transfer of data to third countries is expressly mentioned in the privacy policy), this is always done in accordance with statutory requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have entered into standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and set out 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 occur within the framework of the DPF, the standard contractual clauses serve as a reliable fallback. This ensures that your data remains adequately protected even in the event of any political or legal changes.
For each individual service provider, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, express consent, or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found on the EU Commission's website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
General information on data storage and deletion
We delete personal data that we process in accordance with statutory provisions as soon as the underlying consents are revoked or no further legal grounds for processing exist. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule apply where statutory obligations or specific interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the assertion of legal claims or the protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.
Where multiple retention or deletion periods are specified for a given piece of data, the longest period always applies.
Start of period at the end of the year: Unless a period begins expressly on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the point in 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, arising in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to such processing, including profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw 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, and to information about this data as well as further information and a copy of the data in accordance with statutory requirements.
- Right to rectification: In accordance with statutory 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 statutory requirements, you have the right to request that data concerning you be deleted without delay, or alternatively, in accordance with statutory requirements, to request a restriction of the processing of the data.
- Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with statutory requirements, in a structured, commonly used, and machine-readable format, 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 concerning you infringes the GDPR.
Business services
We process personal data of our contractual and business partners, such as clients, prospective clients, and other cooperation partners (collectively "contractual partners"), for the purpose of initiating, performing, and executing contractual relationships and comparable legal relationships. This also includes pre-contractual measures carried out upon request, as well as communication in connection with the respective contractual relationship.
The processing serves in particular to fulfill our primary and ancillary contractual obligations. This includes providing the agreed services, any update and information obligations, handling warranty and other performance disruptions, processing withdrawals, terminations of continuing obligations, reversals of transactions, refunds, and processing other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.
We process, in particular, master data such as name, address, and, where applicable, company; contact data such as email address and phone number; contract and service data such as the subject matter and term of the contract, order or transaction number; usage and service data; payment and billing data; as well as communication content and history. Where necessary, we also process data disclosed or transmitted to us in the course of carrying out an order.
In addition, we process the data to protect our rights and to fulfill statutory obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations, and, where applicable, verification and accountability obligations. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and contractual partners from misuse and 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 to fulfill statutory obligations.
Personal data is disclosed to third parties only insofar as this is necessary for the performance of the contract, the implementation of pre-contractual measures, the protection of legitimate interests, or the fulfillment of statutory obligations. We provide separate information about any further processing, in particular for marketing purposes, elsewhere in this privacy policy.
We inform contractual partners which data is required in individual cases as part of the data collection process, for example through corresponding markings in online forms or in personal contact.
Data is deleted once it is no longer required for the aforementioned purposes and no statutory retention obligations preclude deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in connection with a specific order is deleted after the order is completed and any retention periods have expired, provided no further statutory or contractual obligations to store the data exist.
The legal basis for processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and fulfilling the respective contractual relationship, as well as Art. 6(1)(c) GDPR for fulfilling statutory obligations. Insofar as processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it serves to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business transactions, the assertion and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests lie in particular in ensuring secure and legally compliant business operations, as well as safeguarding our entrepreneurial ability to act.
- Types of data processed: Basic data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or phone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g. IP addresses, 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 administrative procedures.
- Retention and deletion: Deletion in accordance with the information in the section "General information on data storage 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 information on processing activities, procedures, and services:
- Online shop, order forms, e-commerce, and service fulfillment: We process our clients' data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as pay for and receive them. Where necessary for the fulfillment of an order, we use service providers, in particular postal, shipping, and delivery companies, to carry out delivery or performance to our clients. For processing payment transactions, we use the services of banks and payment service providers. The information required is marked as such during the order or comparable purchase process and includes the details needed for delivery, provision, and billing, as well as contact information to allow for follow-up queries; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Provision of the online offering 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 end device.
- Types of data processed: Usage data (e.g. page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
- 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 such as computers and servers). Security measures.
- Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing activities, procedures, and services:
- Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from an appropriate server provider (also referred to as "web host"); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
- Vercel: Hosting platform on which this website is provided (content delivery network and serverless infrastructure); Service provider: Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://vercel.com; Privacy policy: https://vercel.com/legal/privacy-policy. Data processing agreement: https://vercel.com/legal/dpa.
- 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, the date and time of access, the amount of data transferred, a message indicating successful retrieval, the browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g. to avoid overloading the servers (in particular 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). Deletion of data: 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 excluded from deletion until the respective incident has been finally clarified.
Use of cookies
"Cookies" are functions that store information on and read information from users' end devices. Cookies can be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as generating analyses of visitor flows. We use cookies in accordance with statutory provisions. Where necessary, we obtain users' prior consent. Where consent is not required, we rely on our legitimate interests. This applies where storing and reading information is essential to provide expressly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We clearly inform you about the scope of any such consent and which cookies are used.
Information on legal bases under data protection law: Whether we process personal data using cookies depends on consent. Where consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as explained above in this section and in the context of the respective services and procedures.
Retention period: With regard to retention period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest once a user has left an online offering and closed their end device (e.g. browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the end device is closed. For example, this allows the login status to be saved and preferred content to be displayed directly when the user visits a website again. Similarly, user data collected via cookies may be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that these are persistent and that the storage period may be up to two years.
General information on withdrawal and objection (opt-out): Users can withdraw any consent given at any time and can also object to the processing in accordance with statutory requirements, including via their browser's privacy settings.
- Types of data processed: Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).
Further information on processing activities, procedures, and services:
- Processing of cookie data on the basis of consent: We use a consent management solution to obtain users' consent to the use of cookies or the procedures and providers named within the consent management solution. This procedure serves to obtain, log, manage, and withdraw consent, in particular relating to the use of cookies and comparable technologies used to store, read, and process information on users' end devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing activities and providers named in the consent management procedure. Users also have the option of managing and withdrawing their consent. Consent declarations are stored to avoid repeated requests and to provide evidence of consent in accordance with statutory requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or via comparable technologies, in order to be able to associate the consent with a specific user or their device. Unless specific information about consent management service providers is given, the following general information applies: the retention period for consent is up to two years. In doing so, a pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. the relevant categories of cookies and/or service providers), and information on the browser, system, and end device used; Legal bases: Consent (Art. 6(1)(a) GDPR).
Online questionnaires for clients (Career Potential Test, kick-off questionnaire)
For clients of our career coaching, we provide online questionnaires accessible only via direct link on dedicated subpages (in particular a self-assessment questionnaire, the "Career Potential Test", and a preparatory questionnaire for the career kick-off). We process the contact data provided in the form (name and email address) as well as the answers to the questionnaire, including optional free-text entries (for the kick-off questionnaire, for example, information about your professional situation, goals, and, on a voluntary basis, salary range). Evaluation takes place directly in the user's browser; the answers and result are additionally sent once by email to the controller in order to prepare the coaching session. The person completing the questionnaire also receives a copy of their answers or result at the email address they provided. No further storage of the answers on the web server takes place. For sending emails, we use the service provider Brevo named in the section "Newsletter and electronic notifications".
- Types of data processed: Basic data (e.g. name); content data (answers to the questionnaire statements, free-text entries).
- Data subjects: Service recipients and clients; prospective customers.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations (preparation and delivery of the career coaching).
- Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); consent (Art. 6(1)(a) GDPR).
Contact and inquiry management
When contacting us (e.g. by mail, contact form, email, phone, or via social media), as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry is processed insofar as this is necessary to respond to the inquiry and any requested measures.
- Types of data processed: Contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts, as well as related information such as 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 an 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 storage 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 information on processing activities, procedures, and services:
- Contact form: When contacting us via our contact form, by email, or through other means of communication, we process the personal data transmitted to us in order to respond to and handle the respective inquiry. This usually includes details such as name, contact information, and, where applicable, further information provided to us that is necessary for appropriate handling. 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 statutory permission. Insofar as the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the users' consent. As a rule, providing your email address is sufficient to register for our newsletter. In order to offer you a personalized service, however, we may ask for your name for personal address in the newsletter, or for 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 prove that consent was previously given. Processing of this data is limited to the purpose of a potential defense against claims. An individual request for deletion 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 in a block list.
The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it was conducted properly. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interest in an efficient and secure sending system.
Content:Information about us, our services, promotions, and offers.
- Types of data processed: Basic data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or phone numbers); meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- 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).
- Option to object (opt-out): You can cancel receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of every newsletter, or you may otherwise use one of the contact options listed above, preferably email.
Further information on processing activities, procedures, and services:
- Brevo: Email marketing platform used to manage sign-up to the email list, the double opt-in process, and the sending of emails; Service provider: Brevo GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the provider.
Advertising communication via email, mail, fax, or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, mail, or fax, in accordance with statutory requirements.
Recipients have the right to withdraw consent given at any time, or to object to advertising communication at any time free of charge via the contact options named above.
Following withdrawal or objection, we store the data required to prove the previous authorization for contacting or sending, for up to three years after the end of the year of withdrawal or objection, on the basis of our legitimate interests. Processing of this data is limited to the purpose of a possible defense against claims. On the basis of our legitimate interest in permanently observing users' withdrawal or objection, we further store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, or name).
- Types of data processed: Basic data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. text or image messages and posts, as well as related information such as 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 storage and deletion".
- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Web analytics, monitoring, and optimization
Web analytics (also referred to as "reach measurement") serves to evaluate visitor flows on our online offering and may include behavioral, interest-related, 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 what time our online offering, or its functions or content, is used most frequently, or invite repeat use. We are also able 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 stated below, profiles — i.e. data combined for a specific usage process — may be created for these purposes, and information may be stored in and read from a browser or end device. The information collected includes, in particular, the websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. Insofar as users have consented to the collection of their location data, either towards us or towards the providers of the services we use, the processing of location data is also possible.
In addition, users' IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear-text 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.
Information on legal bases: Where 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 time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g. IP addresses, 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, recognition of returning visitors); profiles with user-related information (creation of 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 storage 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 information on processing activities, 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 associate analytics information with an end device, in order to identify which content users have accessed within one or more usage processes, which search terms they used, whether they revisited content, or interacted with our online offering. The time and duration of use are also stored, as well as the sources of users referring to our online offering, and technical aspects of their end devices and browsers.
Pseudonymous user profiles are created using information from the use of different devices, with cookies potentially being used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides approximate 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 equivalents). For EU traffic, IP address data is used solely for this purpose of deriving 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 lookups are performed on EU-based servers before 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/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://business.safety.google/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); Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout, ad personalization settings: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data).
Presence on social networks (social media)
We maintain online presences within social networks and, in this context, process user data in order to communicate with users active there or to provide information about us.
We would like to point out that user data may be processed outside the European Union in this context. This may result in risks for users, for example because the enforcement of user rights could be made more difficult.
Furthermore, users' data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users' usage behavior and resulting interests. These profiles may in turn be used, for example, to place advertisements within and outside the networks that are presumed to correspond to users' interests. For this purpose, cookies are generally stored on users' computers, in which their usage behavior and interests are stored. In addition, data may also be stored in usage profiles independently of the devices used by users (in particular if they are members of the respective platforms and are logged in there).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), please refer to the privacy policies and information provided by the operators of the respective networks.
Even in the case of requests for information and the exercise of data subject rights, we point out that these can be asserted most effectively directly with the providers. Only the providers have access to the user data in each case and can take corresponding measures and provide information directly. Should you nevertheless require assistance, you may contact us.
- Types of data processed: Contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts, as well as related information such as authorship or time of creation). Usage data (e.g. page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; feedback (e.g. collecting feedback via an online form). Public relations.
- Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing activities, procedures, and services:
- Instagram: Social network enabling the sharing of photos and videos, commenting on and favoriting posts, sending messages, and following 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).
- TikTok: Social network and video platform enabling the publishing and sharing of short videos, commenting on and favoriting posts, and following profiles; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.tiktok.com. Privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/en.
- LinkedIn: Social network — We are, jointly with LinkedIn Ireland Unlimited Company, responsible for the collection (but not the further processing) of visitor data used to generate the "Page Insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, seniority, company size, and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have entered into a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular the security measures LinkedIn must observe, and in which LinkedIn has agreed to fulfill data subject rights (i.e. users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company established in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.linkedin.com/legal/privacy-policy). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Plug-ins and embedded functions and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or maps (hereinafter uniformly referred to as "content").
Integration always requires that the third-party providers of this content process the user's IP address, as without the IP address they would not be able to send the content to the user's browser. The IP address is therefore required for the display of this content or functions. We endeavor to use only content whose respective providers use the IP address solely 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. Through "pixel tags", information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on users' devices and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering, but may also be combined with such information from other sources.
Information on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is that 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 time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g. IP addresses, 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 storage 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).
Changes and updates
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as changes require an action on your part (e.g. consent) or other individual notification.
Insofar as we provide addresses and contact information of companies and organizations in this privacy policy, please note that these addresses may change over time and we ask that you verify the details before making contact.
Definitions
In this section, you will find an overview of the terminology used in this privacy policy. Insofar as the terms are legally defined, their statutory definitions apply. The following explanations are, however, primarily intended to aid understanding.
- Basic data: Basic data includes essential information necessary for the identification and administration of contractual partners, user accounts, profiles, and similar associations. This data may include, among other things, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Basic data forms the foundation for any formal interaction between individuals and services, institutions, or systems, by enabling clear identification 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 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 means of communication such as social media handles and instant messaging identifiers.
- Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information describing the context, origin, and structure of other data. It may include details such as file size, creation date, document author, and change history. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, social network messages, 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, as well as audit logs used to track and review processes.
- Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages, and the paths they take when navigating through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data consisting of using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may relate to various information regarding demographics, behavior, and interests, such as interaction with websites and their content). Profiling purposes may include, for example, interest in certain content or products, click behavior on a website, or place of residence. Cookies and web beacons are frequently used for profiling purposes.
- Log data: Log data is information about events or activities recorded in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system issues, monitor security, or generate performance reports.
- Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the 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 when users visit their websites and which content they are interested in. This allows them, for example, to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes to recognize returning visitors and thereby obtain more accurate analyses of the use of an online offering.
- Controller: "Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether collecting, evaluating, storing, transmitting, or deleting it.
- Contract data: Contract data is 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 category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed upon, 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 details, payment amounts, transaction data, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
Created with the free privacy policy generator Datenschutz-Generator.de by Dr. Thomas Schwenke
This English version is a convenience translation. In case of any discrepancy, the German version prevails.