General Terms and Conditions (GTC)
§ 1 Scope
- These General Terms and Conditions (hereinafter: T&Cs) apply to all accommodation contracts, hereinafter "Rental Agreement", between Soulmates Resorts GmbH, represented by the Managing Director Matthias Linhart, Kaiser-Friedrich-Promenade 89, 61348 Bad Homburg (hereinafter "Landlord") and the customers who rent a holiday apartment (hereinafter "Tenant").
- The General Terms and Conditions apply regardless of whether the tenants are consumers, entrepreneurs or merchants.
- All agreements made between the landlord and the tenant in connection with the rental agreement arise in particular from these terms and conditions, the written order confirmation and the declaration of acceptance.
- The version of the General Terms and Conditions valid at the time of conclusion of the contract shall apply.
- The landlord does not accept any deviating terms and conditions of the tenant. This applies even if the landlord does not expressly object to their inclusion.
- If a deviation from the rental conditions is formulated in writing, this deviation takes precedence or supplements the general terms and conditions.
§ 2 General
- The subject of this contract is the rental of holiday apartments.
- The apartments are intended for the number of people specified in the offer.
- The size, layout and furnishings of the holiday apartments can be seen in the description.
- Dogs are permitted as pets, but are limited to a maximum of two per apartment. Additional pets are not permitted. Dog baskets in the living room are available for use.
- These are non-smoking apartments. Smoking is not permitted in the apartments.
§ 3 Conclusion of contract
- The presentation and advertising of the holiday apartments on the website or in other advertisements by the landlord do not constitute a binding offer to conclude a rental agreement.
- A rental agreement is only concluded upon signature by both parties, or upon booking by telephone or remote communication. A booking is binding.
- Receipt of the submitted order or reservation request will be confirmed immediately by email. Such an email does not constitute a binding acceptance of the order unless it also contains a confirmation of receipt and a declaration of acceptance.
- A contract is only concluded when the landlord accepts the booking by means of a declaration of acceptance.
- If the reservation cannot be made for the desired period, for example, because the holiday apartment is already rented, the landlord will refrain from accepting the reservation. In this case, no contract is concluded. The landlord will inform the tenant immediately and promptly refund any consideration already received.
- Should the holiday apartment not be available for the booked rental period due to damage or other unforeseeable circumstances, the tenant has the right to terminate the rental agreement immediately. In this case, the tenant will receive an immediate refund of any fees already paid. No alternative accommodation will be provided. Claims for damages due to the cancellation are excluded.
§ 4 Terms of payment, offsetting and right of retention
- All prices stated on the website and in other advertisements by the landlord are gross prices including statutory VAT.
- By concluding the rental agreement for the duration of use of the holiday apartment, the tenant undertakes to pay the contractually agreed rental price to the landlord.
- The payment options can be found on the invoice.
- The tenant has no right to make changes to the rental start date or amenities. A rebooking can only be made after consultation with the landlord. To do so, the original rental agreement must be terminated (withdrawal) and replaced with a new one.
- Tenants are not entitled to offset claims against the landlord's claims unless the counterclaims have been legally established or are undisputed. Tenants are also not entitled to offset claims against the landlord if they assert complaints about defects or counterclaims arising from the same rental agreement.
- Tenants may only exercise a right of retention if their counterclaim arises from the same rental agreement.
§ 5 Arrival and departure
- Arrival is possible daily from 3 p.m. On the day of departure, the apartment must be vacated by 10 a.m. at the latest.
- If you exceed the departure time by more than 30 minutes, you will be charged for an additional night.
- Other arrival and departure times can be arranged individually.
- If the tenant does not arrive by 10:00 p.m. on the day of arrival without notification or prior agreement, the contract will be deemed terminated after a period of notice of 48 hours without notification to the landlord.
- A (partial) refund of the rent due to early departure will generally not be made.
§ 6 Cancellation
- The tenant has the right to cancel the rental agreement for the holiday apartment free of charge up to 6 weeks (42 days) before the agreed start date. Cancellations must be made in writing via email and become effective upon receipt of the cancellation notice by the landlord.
- If the cancellation occurs less than 42 days before the agreed start date, cancellation fees amounting to 70% of the agreed rental price will apply. The calculation is based on the total rental price for the booked period.
- If the cancellation occurs less than 28 days before the agreed start date, cancellation fees amounting to 90% of the agreed rental price will apply. The calculation is based on the total rental price for the booked period.
- In case of cancellation on the day of the rental start date or in case of no-show by the tenant without prior cancellation, the entire rental price (100%) is due and must be paid by the tenant.
- In the event of the canceled vacation rental being re-let to another tenant, the landlord reserves the right to offset the costs saved through the cancellation and the proceeds from the re-letting against the cancellation fees. The landlord will endeavor to re-let the vacation rental to minimize the cancellation fees.
- The tenant reserves the right to prove that the landlord has suffered no damage or significantly less damage than the cancellation fees mentioned in paragraphs (2) to (4).
- The tenant’s statutory cancellation rights remain unaffected.
- Should cancellation by the landlord be necessary due to unforeseeable circumstances (e.g., force majeure, natural disasters, power outages, or official measures) beyond his control, the entire amount already paid will be refunded. Further claims are excluded.
- Subject to availability, a rebooking at a later date may be offered. This is at the discretion of the landlord and is not a legal obligation.
- (10)The landlord recommends that tenants take out travel cancellation insurance,
to protect yourself against unforeseeable events.
§ 7 Rental period
- The rental period begins on the arrival date contractually agreed between the parties and ends on the agreed end date. These dates are set forth in the rental agreement.
- The right of both parties to terminate the contract without notice remains unaffected by the contractually agreed rental period.
- If the tenant continues to use the rental property after the expiration of the contract, the tenancy is not considered extended. Section 545 of the German Civil Code (BGB) does not apply.
§ 8 Return of the holiday apartment
- The tenant is obligated to return the holiday apartment in a tidy, clean, and orderly condition at the end of the rental period. This includes, in particular, cleaning the kitchen, washing dishes, emptying the trash can, and removing all personal belongings.
- All keys to the holiday apartment must be deposited on the designated key holder inside next to the apartment door on the day of departure. The tenant is liable for any intentional or grossly negligent loss of keys and any resulting costs, such as replacing locks.
- Any damage or defects that occur during the rental period must be reported to the landlord immediately. The tenant is liable for all damage caused by him or his fellow travelers, unless this is due to normal wear and tear.
- In case of excessive soiling or failure to clean by the tenant, the landlord reserves the right to subsequently invoice the additional costs.
- The landlord or a person authorized by the landlord has the right to inspect the holiday apartment upon return and check for any defects or damage. If damage or significant soiling is discovered, the landlord reserves the right to charge the tenant for the costs of repairs or special cleaning.
- If the holiday apartment is not vacated and returned by the agreed time, the landlord reserves the right to demand additional compensation for use in the amount of the agreed rental price per day. Further claims for damages by the landlord remain unaffected.
- Should the tenant vacate the holiday apartment before the end of the rental period without prior agreement with the landlord, the tenant remains obligated to pay the full rental price for the agreed rental period. Early return of the holiday apartment does not release the tenant from their contractual obligations.
§ 9 Tenant’s obligations
- Tenants are obliged to treat the rented items (holiday apartment, inventory and outdoor facilities) with care.
- If damage to the holiday apartment and/or its inventory occurs during the rental period, the tenants are obliged to notify the provider immediately.
- Any defects or damage discovered upon arrival must be reported to the provider immediately.
- A reasonable period of time must be allowed to remedy damages and defects. Claims for complaints not reported promptly on-site are excluded. Complaints received by the provider only at the end of the stay or after the holiday apartment has been vacated are also excluded from compensation.
- In the event of any disruption to performance, tenants are obliged to do everything reasonable within the scope of their legal obligations to help remedy the disruption and to minimize any damage that may arise.
- On the day of departure, tenants' personal belongings must be removed, household waste must be disposed of in the designated containers, and dishes must be clean and washed and stored in the kitchen cupboards.
- Several tenants are jointly and severally liable for any damage.
- When leaving the holiday apartment, tenants are obliged to keep windows and doors closed, set all radiators to a low setting and switch off lights and technical devices.
- The installation and/or attachment of decorative materials or similar items is not permitted in the holiday apartments. Any damage to the rental property caused by the installation and/or attachment of decorative items or similar items is the responsibility of the tenant.
- (10)In all other respects, the provisions of the house rules apply, which can be viewed at any time on the landlord's website. The tenant confirms that he has read and understood the house rules and will comply with them.
§ 10 Liability
- The landlord is liable in cases of intent or gross negligence in accordance with statutory provisions. Liability for guarantees is independent of the degree of fault. In cases of slight negligence, the landlord is liable exclusively in accordance with the provisions of the Product Liability Act, for injury to life, body, or health, or for the breach of essential contractual obligations. However, the claim for damages for the slightly negligent breach of essential contractual obligations is limited to the foreseeable damage typical for the contract, unless unlimited liability applies due to injury to life, body, or health or under the provisions of the Product Liability Act. Further liability for damages is excluded.
- Essential contractual obligations are those whose fulfilment makes the proper execution of the contract possible in the first place and on whose compliance the tenant can regularly rely.
- The landlord is not liable for disruptions or impairments to the rental property that are beyond his control, such as force majeure, natural disasters, power outages or official measures.
- The landlord is only liable for items brought by the tenant, especially valuables, in cases of intent or gross negligence. Valuables are recommended to be kept in a safe place or not stored in the holiday apartment.
- The landlord assumes no liability for damages caused by improper use of the holiday apartment or by disregard of the house rules by the tenant or their fellow travelers. The tenant is liable for all damages caused by them or their fellow travelers.
- The limitations of liability pursuant to paragraphs (1) to (5) also apply to the vicarious agents and legal representatives of the landlord.
- The tenant’s claims for damages expire within the statutory limitation periods.
§ 11 Data Protection
- By accepting these General Terms and Conditions, tenants agree that necessary personal data about them may be stored, modified, and/or deleted as part of the contract concluded with them. All personal data will be treated with absolute confidentiality.
- Otherwise, the landlord's privacy policy applies: http://editor.smoobu.com/preview/c5b56a721ced4265af432cf1f5231328?t=1741632072800
§ 12 Applicable law and place of jurisdiction
- The law of the Federal Republic of Germany applies
- The contract language is German.
- Any changes or additions to this agreement must be made in writing. This also applies to changes to the written form clause.
- Should individual provisions of this agreement be or become invalid in whole or in part, the validity of the remaining provisions shall remain unaffected. The invalid provision shall be replaced by a provision that most closely reflects the purpose of the agreement and the intention of the parties at the time of its conclusion. The same applies to any unintentional gaps in the agreement.
Privacy Policy
PreambleWith the following privacy policy, we would like to inform you about which 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 Preamble
With the following privacy policy, we would like to inform you about which 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 "online offering").
The terms used are not gender-specific.
As of: March 4, 2025
Table of Contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Business processes and procedures
- Use of online platforms for offer and sales purposes
- Providers and services used in the course of business activities
- Payment methods
- Provision of the online service and web hosting
- Use of cookies
- Special notes on applications (apps)
- Registration, login and user account
- Blogs and publication media
- Contact and inquiry management
- Communication via Messenger
- Push notifications
- Video conferencing, online meetings, webinars and screen sharing
- Cloud Services
- Newsletters and electronic notifications
- Advertising communication via email, post, fax or telephone
- Sweepstakes and competitions
- Online marketing
- Affiliate programs and affiliate links
- Customer reviews and rating processes
- Presence in social networks (Social Media)
- Plug-ins and embedded functions and content
- Management, organization and support tools
- Processing of data in the context of employment relationships
- Change and update
- Definitions of terms
Person responsible
Soulmates Resorts GmbH, Kaiser-Friedrich-Promenade 89, 61348 Bad Homburg
Authorized representatives: Matthias Linhart
Email Address: info@soulamtes-resorts.com
Imprint: www.soulmates-resorts.com
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Employee data.
- Payment details.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Social data.
- Image and/or video recordings.
- Sound recordings.
- Event data (Facebook).
- Log data.
- Performance and behavioral data.
- Working time data.
- Salary data.
Special categories of data
- Health data.
- Religious or ideological beliefs.
- Trade union membership.
Categories of data subjects
- Service recipient and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Sweepstakes and competition participants.
- Business and contractual partners.
- Renter.
- People depicted.
- Third parties.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target group formation.
- Affiliate tracking.
- Organizational and administrative procedures.
- Conducting prize draws and competitions.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Establishment and implementation of employment relationships.
- Information technology infrastructure.
- Financial and payment management.
- Public relations.
- Sales promotion.
- Business processes and business procedures.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find 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 or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) (f) GDPR) - processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require protection of personal data do not prevail.
- Processing of special categories of personal data relating to healthcare, occupation and social security (Article 9 (2) (h) GDPR) - Processing is necessary for the purposes of preventive healthcare or occupational medicine, for assessing the employee's capacity to work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social systems and services on the basis of Union or Member State law or on the basis of a contract with a healthcare professional.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, 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, state data protection laws of individual federal states may apply.
Relevant legal bases under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Data Protection Act (short "Swiss DSG"). Unlike, for example, the GDPR, the Swiss DSG does not generally require a legal basis for the processing of personal data to be stated and requires that the processing of personal data is carried out in good faith, lawful, and proportionate (Art. 6 para. 1 and 2 of the Swiss DSG). Furthermore, we only collect personal data for a specific purpose that is recognizable to the data subject and only process it in a manner compatible with that purpose (Art. 6 para. 3 of the Swiss DSG).
Note on the applicability of the GDPR and the Swiss Data Protection Act: This privacy policy serves to provide information in accordance with both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that, due to their broader geographical application and clarity, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "particularly sensitive personal data" used in the Swiss Data Protection Act, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss Data Protection Act within the scope of the Swiss Data Protection Act.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures 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 the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.
Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled 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
As part of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the group: Data transfer within the group: We may transfer personal data to other companies within our group or grant them access to it. This data transfer is based on our legitimate business and commercial interests. This includes, for example, improving business processes, ensuring efficient and effective internal communication, making optimal use of our human and technological resources, and enabling us to make informed business decisions. In certain cases, data transfer may also be necessary to fulfill our contractual obligations, or it may be based on the consent of the data subject or legal permission.
Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and operational interests, or it is necessary to fulfill our contractual obligations, or if the data subject's consent or legal permission exists.
International data transfers
Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 (1) GDPR). We will also inform you of the basis for third-country transfers from the individual providers in the third country, with the adequacy decisions taking precedence. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In the privacy policy, we inform you which service providers we use are certified under the Data Privacy Framework.
Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (FADP), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures. These may include international treaties, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection rules approved in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss FADP, exceptions to the disclosure of data abroad may be permitted if certain conditions are met, including the consent of the data subject, contract execution, public interest, protection of life or physical integrity, publicly disclosed data, or data from a legally prescribed register. These disclosures are always made in accordance with legal requirements. Within the framework of the so-called "Data Privacy Framework" (DPF), the Swiss Federal Office for Information Security has recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of June 7, 2024. The list of certified companies and further information on the DPF can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). We inform you in our privacy policy about which service providers we use are certified under the Data Privacy Framework.
General information on data storage and deletion
We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there are no further legal grounds for processing. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist 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 on the retention and deletion of data that applies specifically to certain processing operations.
If there are multiple details regarding the retention period or deletion period for a given date, the longest period always applies.
If a period does not explicitly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the effective date of the termination or other termination of the legal relationship.
We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons only for the reasons that justify its storage.
Further information on processing procedures, methods and services:
- 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) No. 1 in conjunction with Section 3 AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with Section 4 HGB).
- 8 years - accounting documents, such as invoices and cost receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 Sentence 1 AO and Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 HGB).
- 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating statements, calculation documents, price labels, but also payroll documents insofar as they are not already accounting documents and cash register slips (Section 147 (1) Nos. 2, 3, 5 in conjunction with Section 3 AO, Section 257 (1) Nos. 2 and 3 in conjunction with Section 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
- Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:
- 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years - Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as to process related inquiries based on previous business experience and standard industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is applicable in specific cases (Art. 127, 130 of the Swiss Code of Obligations). Claims for rent, lease, and capital interest, as well as other periodic payments, from the delivery of food, catering, and landlord debts, as well as from craft work, retail sales of goods, medical care, professional work by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees (Art. 128 of the Swiss Code of Obligations), expire after five years.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to a supervisory authority: In accordance with the statutory provisions 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 in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of data subjects under the Swiss DSG:
As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to exercise your rights under this law and to ensure transparent data processing.
- Right to data disclosure or transfer: You have the right to request the disclosure of your personal data that you have provided to us in a common electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to objection, deletion and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be deleted or destroyed.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), within the framework of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.
We use this data to fulfill our contractual obligations. This includes, in particular, the obligation to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. Furthermore, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as for corporate organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse and the endangerment of their data, secrets, information, and rights (e.g., the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on contractual partners' data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed of other forms of processing, such as for marketing purposes, in this privacy policy.
We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., contract subject matter, term, customer category).
- Special categories of personal data: health data.
- Data subjects: Service recipients and clients; interested parties; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and operational procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance 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 procedures, methods and services:
- Hospitality, hotel, and accommodation services: We process the information of our guests, visitors, and interested parties (collectively referred to as "guests") to provide our accommodation and related services of a tourist or gastronomic nature, as well as to bill for the services provided. Within the scope of our engagement, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) GDPR, in particular information about a person's health or information related to their religious beliefs. The processing is carried out to protect the health interests of visitors (e.g., in the case of information about allergies) or otherwise to meet their physical or mental needs upon request and with their consent. If required for the performance of the contract or by law, or with the consent of guests, or based on our legitimate interests, we will disclose or transmit guest data, for example, to the service providers involved in the performance of our services, or to authorities, billing centers, or in the area of IT, office, or similar services. Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- Rental services: We process the data of our tenants and prospective tenants in accordance with the underlying rental agreement. We may also process information about the characteristics and circumstances of individuals or property belonging to them if this is necessary within the scope of the rental agreement. This may include, for example, information about personal circumstances, movable or immovable property, financial situation, and the use of ancillary services (such as water or energy supply). Within the scope of our engagement, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) GDPR, in particular information about a person's health. This processing is carried out in order to protect the health interests of the tenants and otherwise only with the consent of the tenants. If necessary for the performance of the contract, legally required, or approved by the tenants, or based on our legitimate interests, we will disclose or transmit tenants' data as part of coverage inquiries, the conclusion and processing of contracts, e.g. to financial service providers, credit institutions, utilities (e.g. electricity), or authorities. We also process tenant data if this is necessary to fulfill legal obligations (e.g., information obligations in connection with additional services and additional costs); legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Business processes and procedures
Personal data of service recipients and clients – including customers, clients, or in special cases, clients, patients, business partners, and 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 collected data serves to fulfill contractual obligations and streamline operational processes. This includes processing business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal accounting and financial processes. In addition, the data supports the protection of the controller's rights and supports administrative tasks and the organization of the company.
Personal data may be transferred to third parties if this is necessary to fulfill the stated purposes or legal obligations. After the expiration of statutory retention periods or if 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: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); contract data (e.g., subject matter of the contract, term, customer category); log data (e.g., log files relating to logins or data retrieval or access times); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services); employees (e.g., employees, applicants, temporary workers, and other staff).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and administrative procedures; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance 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 procedures, methods and services:
- Contact management and contact maintenance: Procedures required to organize, maintain, and secure 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, backing up and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adapting contact strategies); Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts, and the control of payment flows (e.g., preparation and verification of transfers, processing of direct debit transactions, checking account statements, monitoring incoming and outgoing payments, direct debit management, account reconciliation, cash management); Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for the recording, processing, and control of business transactions in the area of accounts payable and accounts receivable accounting (e.g., creation and review of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation within the scope of receivables and liabilities, accounts payable and accounts receivable accounting); Legal basis: Contractual 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, administration, and control of financially relevant business 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, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Marketing, advertising, and sales promotion: Processes required within the scope of marketing, advertising, and sales promotion (e.g., market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair 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: Procedures required within the scope of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, preparation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, maintenance of corporate branding); Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for reach measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., contract subject matter, term, customer category); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Affected persons: Service recipients and clients; business and contractual partners; interested parties; tenants.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing; Business processes and administrative procedures; Communication; Office and organizational procedures; Organizational and administrative procedures; Provision of our online offering and user-friendliness; Affiliate tracking. Conversion measurement (measurement of the effectiveness of marketing measures).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
- Booking.com Partner Program: Affiliate marketing partner program; Service provider: Booking.com BV, Herengracht 597, 1017 CE Amsterdam, Netherlands; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.booking.com; Privacy Policy: https://www.booking.com/content/privacy.de.html. Basis for third-country transfers: Switzerland - Adequacy Decision (Netherlands).
- AirBnB: Rental and booking of accommodations, experiences, and discoveries; management of reservations; communication between hosts and guests; payment processing; Service provider: Airbnb Ireland UC, 8 Hanover Quay, D02 DP23 Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.airbnb.de; Privacy policy: https://www.airbnb.de/help/article/2855/datenschutzschutzerklärung. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- Ferienwohnungen-direkt: Rental platform for holiday apartments.
- Vrbo: Vacation rental platform.
- Expedia: Vacation rental platform.
Providers and services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter "Services") in compliance with legal requirements. Their use is based on our interest in the proper, lawful, and economical management of our business operations and our internal organization.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); contract data (e.g., subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; interested parties; business and contractual partners; employees (e.g., employees, applicants, temporary workers, and other staff).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures. Business processes and operational procedures.
- Storage 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, methods and services:
- DATEV: Software for accounting, communication with tax advisors and authorities, and document storage; Service provider: DATEV eG, Paumgartnerstr. 6-14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Payment methods
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, we use other service providers for this purpose (collectively "payment service providers").
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount, and recipient-related information. This information is required to process the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contract data (e.g., contract subject matter, term, customer category); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); contact data (e.g., postal and email addresses or telephone numbers).
- Data subjects: Service recipients and clients; business and contractual partners; interested parties.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and operational procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.mastercard.de/de-de.html; Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html. Basis for third-country transfers: Switzerland - Adequacy Decision (Belgium).
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. Basis for third-country transfers: Switzerland - Adequacy Decision (Luxembourg).
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.visa.de; Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html. Basis for third-country transfers: EU/EEA - Adequacy Decision (UK), Switzerland - Adequacy Decision (UK).
Provision of the online service and web hosting
We process user data 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 length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); protocol data (e.g. log files relating to logins or the retrieval of data or access times); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures; provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures. Organizational and administrative procedures.
- Storage 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, methods and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent from a corresponding server provider (also called a "web host") or obtain from other sources; 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, notification of successful access, 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 can be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization 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 needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
- Email sending and hosting: The web hosting services we use also include the sending, receiving, and storing of emails. For these purposes, the addresses of the recipients and senders, as well as other information regarding the email sending (e.g., the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that emails are generally not sent encrypted over the Internet. Emails are generally encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of emails between the sender and the recipient on our server; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Use of cookies
The term "cookies" refers to functions that store and retrieve information from users' end devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows. We use cookies in accordance with legal regulations. Where necessary, we obtain user consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and retrieving information is essential to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.
Notes on 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 processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, including by using the privacy settings of their browser.
- Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons 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 procedures, methods and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers named within the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and similar 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 operations and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. Consent declarations are saved to avoid repeated queries and to be able to provide evidence of consent in accordance with legal requirements. The data is stored on the server and/or in a cookie (so-called opt-in cookie) or using similar technologies in order to be able to assign consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used. Legal basis: Consent (Art. 6 (1) (a) GDPR).
Special notes on applications (apps)
We process the data of our application users to the extent necessary to provide the application and its functionalities to users, to monitor its security, and to further develop it. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administering or using the application. Furthermore, with regard to the processing of user data, we refer to the data protection information in this privacy policy.
Legal basis: The processing of data required to provide the application's functionalities serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g., enabling device functions). If the processing of data is not necessary to provide the application's functionalities, but serves the security of the application or our business interests (e.g., collecting data for the purpose of optimizing the application or for security purposes), it is based on our legitimate interests. If users are expressly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on their consent.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of the contract, term, customer category).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; provision of our online offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Commercial use: We process the data of our application users, registered users, and any test users (hereinafter referred to collectively as "users") in order to provide them with our contractual services, as well as on the basis of legitimate interests, to ensure the security of our application and to further develop it. The required information is marked as such within the scope of the user agreement, order, or similar contract conclusion and may include the information required for service provision and any billing, as well as contact information for any follow-up consultations. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- Device permissions for access to functions and data: The use of our application or its functionalities may require users to grant permissions to access certain functions of the devices used or to the data stored on the devices or accessible through the devices. By default, these permissions must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they need clarification. We point out that denying or revoking the respective permissions may affect the functionality of our application.
Registration, login and user account
Users can create a user account. During registration, users are provided with the required mandatory information and processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and an email address).
When you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. This data is generally not shared with third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); log data (e.g., log files relating to logins or data retrieval or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures; provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the "General Information on Data Storage and Deletion" section. Deletion after termination.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation, or consent of the user; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- No obligation to retain data: It is the responsibility of the user to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract. Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the framework of this privacy policy.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures; organizational and administrative procedures.
- Storage 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, methods and services:
- Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests. On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting. The personal information provided in the comments and contributions, any contact and website information, as well as the content information, will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Access to WordPress emojis and smileys: Access to WordPress emojis and smileys - Within our WordPress blog, graphic emojis (or smileys), i.e., small graphic files that express emotions, are used for the purpose of efficiently integrating content elements. The server providers collect the users' IP addresses. This is necessary so that the emoji files can be transmitted to the users' browsers; Service provider: Aut O'Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Contact and inquiry management
When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: communication partners.
- Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Storage 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). Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Further information on processing procedures, methods and services:
- Contact form: When you contact us via our contact form, by email, or other communication channels, we process the personal data you provide to answer and process your request. This generally includes information such as your name, contact information, and, if applicable, other information that is provided to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; legal bases: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.
You can also contact us via alternative means, such as telephone or email. Please use the contact options provided or those provided within our online offering.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure the encryption of the message content.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot see the content, they can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in our relationship with our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilling the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.
Revocation, objection, and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete messages in accordance with our general deletion guidelines (e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have responded to any inquiries from the communication partners, provided no reference to a previous conversation is expected and there are no statutory retention periods that prevent deletion.
Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that for certain reasons we may not be able to respond to inquiries via Messenger. This applies to situations where, for example, contract details must be treated with particular confidentiality or a response via Messenger does not meet formal requirements. In these cases, we recommend using more appropriate communication channels.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as the information relating to them, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); inventory data (e.g., full name, home address, contact information, customer number, etc.).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing: Communication; direct marketing (e.g., by email or post); marketing; provision of our online services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 (1) (a) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Apple iMessage: Send and receive text messages, voice messages, and video calls. Conduct group conversations. Share files, photos, videos, and locations. Secure communication with end-to-end encryption. Synchronize messages across multiple devices. Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Instagram: Sending messages via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- Facebook Messenger: Send and receive text messages, make voice and video calls, create group chats, share files and media, transmit location information, synchronize contacts, encrypt messages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Microsoft Teams: Chat, audio and video conferencing, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Snapchat: Snapchat Messenger with end-to-end encryption; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.snapchat.com/l/de-de; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy; Data processing agreement: https://www.snap.com/de-DE/terms/data-processing-agreement. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://www.snap.com/de-DE/terms/data-processing-agreement), Switzerland - Standard Contractual Clauses (https://www.snap.com/de-DE/terms/data-processing-agreement).
- WhatsApp: Text messages, voice and video calls, sending images, videos, and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- TikTok: Social network, enables the sharing of photos and videos, commenting on and favorite posts, sending messages, and subscribing to accounts; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy. Basis for third country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- TikTok Business: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to accounts - We and TikTok are jointly responsible for the collection and transmission of event data as well as for measuring and creating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have concluded a special agreement on joint controllership with TikTok, which specifically regulates the security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct information or deletion requests directly to TikTok). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with TikTok. The agreement on joint controllership can be found in TikTok's "Jurisdiction Specific Terms": https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- WhatsApp groups: We use the WhatsApp platform to create interest groups within which WhatsApp users can contact each other or with us and exchange information. Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Push notifications
With the consent of the users, we can send so-called "push notifications." These are messages that are displayed on the users' screens, devices, or browsers, even when our online service is not actively being used.
To subscribe to push notifications, users must confirm their browser or device's request to receive push notifications. This consent process is documented and stored. This data storage is necessary to determine whether users have consented to receive push notifications and to verify consent. For these purposes, a pseudonymous browser identifier (so-called "push token") or the device ID of a device is stored.
On the one hand, push notifications may be necessary for the fulfillment of contractual obligations (e.g., technical and organizational information relevant to the use of our online offering) and, unless specifically stated below, are otherwise sent based on user consent. Users can change the receipt of push notifications at any time using the notification settings of their respective browsers or devices.
- Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: communication partners.
- Purposes of processing: Communication; provision of our online services and user-friendliness. Direct marketing (e.g., by email or post).
- Retention and deletion: Deletion in accordance with the information in the "General Information on Data Storage and Deletion" section. Deletion after termination.
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Push messages with advertising content: The push notifications we send may contain advertising information. Advertising push messages are processed based on user consent. If the content of advertising push messages is specifically described as part of consent to receive them, these descriptions are decisive for user consent. Our newsletters also contain information about our services and us; legal basis: consent (Art. 6 (1) (a) GDPR).
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications from third-party providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as "conferences"). When selecting conference platforms and their services, we comply with legal requirements.
Data processed by conference platforms: When participating in a conference, the conference platforms process the personal data of participants listed below. The scope of processing depends on which data is required for a specific conference (e.g., providing access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' data may also be processed by the conference platforms for security purposes or to optimize the service. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content of the communication processes, i.e., entries in chats as well as audio and video data, as well as the use of other available functions (e.g., surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users on the conference platforms, additional data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, participants will be transparently informed of this in advance and, where necessary, asked for their consent.
Participant data protection measures: Please refer to the conference platforms' privacy policies for details on how your data is processed and select the optimal security and data protection settings for you within the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g., by informing roommates, locking doors, and using the background blur function, where technically possible). Links to the conference rooms and access data must not be shared with unauthorized third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to use the conference platforms or certain functions (e.g., consent to recording conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g., in participant lists, in the case of processing discussion results, etc.). Furthermore, user data is processed based on our legitimate interest in efficient and secure communication with our communication partners.
- Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Protocol data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects: communication partners; users (e.g., website visitors, users of online services). Depicted persons.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
- Storage 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, methods and services:
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Cloud Services
We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the storage and management of content (e.g., document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
Within this framework, personal data may be processed and stored on the providers' servers if it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize their services.
If we use cloud services to provide forms, documents, and content to other users or publicly accessible websites, the providers may store cookies on users' devices for web analysis purposes or to remember users' settings (e.g., in the case of media control).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects: interested parties; communication partners; business and contractual partners.
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage 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, methods and services:
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services, and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security Notices: https://www.microsoft.com/de-de/trustcenter; Data Processing Agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or based on a legal basis. If the newsletter content is mentioned when registering for the newsletter, this content is decisive for the user's consent. Providing your email address is normally sufficient to register for our newsletter. However, in order to offer you a personalized service, we may ask you to provide your name so that we can address you personally 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 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 previous 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 on a block list (so-called "block list") for this purpose alone.
The registration process is logged based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g., by email or post); provision of contractual services and fulfillment of contractual obligations; communication; provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
- Opt-out: You can unsubscribe from our newsletter at any time, i.e., revoke 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 by using one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Prerequisite for using free services: Consent to receive mailings may be made a condition for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
- Reminder emails regarding the order process: If users fail to complete an order process, we can remind users of the order process via email and send them a link to continue. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight, or forgetfulness. Emails are sent based on consent, which users can revoke at any time. Legal basis: Consent (Art. 6 (1) (a) GDPR).
- WhatsApp: Text messages, voice and video calls, sending images, videos, and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- WhatsApp groups: We use the WhatsApp platform to create interest groups within which WhatsApp users can contact each other or with us and exchange information. Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as email, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to advertising communication at any time.
After revocation or objection, we will store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on our legitimate interest in permanently respecting the user's revocation or objection, we also store the data necessary to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts as well as related information, such as authorship or time of creation).
- Data subjects: communication partners.
- Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Sweepstakes and competitions
We only process personal data of participants in prize draws and competitions in compliance with the relevant data protection regulations, provided that the processing is contractually necessary for the provision, implementation and processing of the prize draw, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through the possible collection of IP addresses when submitting prize draw entries).
If entries from participants are published as part of the competition (e.g., as part of a vote or presentation of the competition entries or winners, or in the reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or social network (e.g., Facebook or Instagram, hereinafter referred to as the "Online Platform"), the terms of use and privacy policy of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants during the competition, and any inquiries regarding the competition should be directed to us.
Participants' data will be deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because no further queries regarding the prize draw are expected. Participants' data will generally be deleted no later than six months after the end of the prize draw. Winners' data may be retained for longer, for example, to answer queries about the prizes or to fulfill the prize-winning services. In this case, the retention period depends on the type of prize and is up to three years for items or services, for example, in order to process warranty claims. Participants' data may also be stored for longer, for example, in the form of competition reporting in online and offline media.
If data was collected for other purposes as part of the competition, its processing and retention period are governed by the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts as well as related information, such as authorship or time of creation).
- Data subjects: Participants in prize draws and competitions.
- Purposes of processing: Conducting prize draws and competitions.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Online marketing
We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on potential user interests and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used to store the user information relevant to the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing processes know the actual user identity, only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to profiles, primarily if, for example, the users are members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by providing consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
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 permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Information on revocation and objection:
We refer to the privacy policies of the respective providers and the opt-out options provided for each provider. If no explicit opt-out option has been provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offering. We therefore recommend the following additional opt-out options, which are summarized for each area:
a) Europa:
https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-territory: https://optout.aboutads.info.
- Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); Event Data (Facebook) ("Event Data" is information that is sent, for example, via meta pixels (whether via apps or other channels) to the provider Meta and relates to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. Event Data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event Data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. "Event Data" is deleted by Meta after a maximum of two years, and the resulting target groups disappear when our Meta user accounts are deleted.); Inventory Data (e.g., full name, home address, contact information, customer number, etc.); Payment Data (e.g., bank details, invoices, payment history); Contact Data (e.g., postal and email addresses or phone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group formation; marketing; profiles with user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures); provision of our online offering and user-friendliness; provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures. Organizational and administrative procedures.
- Retention and Deletion: Deletion as described in the "General Information on Data Retention and Deletion" section. Cookies are stored for up to two 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 basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Facebook advertisements: Placing advertisements within the Facebook platform and evaluating the ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Opt-out option: We refer to the data protection and advertising settings in the user profile on the Facebook platforms as well as to Facebook's consent procedures and contact options for exercising information and other data subject rights, as described in Facebook's privacy policy; Further information: Event data of users, i.e. Behavioral and interest information is processed for the purposes of targeted advertising and audience building on the basis of the joint controller agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and conversion measurement: Online marketing methods for placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure the conversion of the ads, i.e., whether users have used them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate Interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
- Instagram advertisements: Placing advertisements within the Instagram platform and evaluating the ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Possibility of objection (opt-out): We refer to the data protection and advertising settings in the user profile on the Instagram platform as well as within the framework of Instagram's consent process and Instagram's contact options for exercising information and other data subject rights in Instagram's privacy policy; Further information: Event data of users, i.e. Behavioral and interest information is processed for the purposes of targeted advertising and audience building on the basis of the joint controller agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions and saves them in a profile (possible purposes: measuring campaign performance, optimizing ad delivery, building user-defined and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Data processing agreement: https://www.linkedin.com/legal/l/dpa; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Affiliate programs and affiliate links
We integrate so-called affiliate links or other references (which may include, for example, search masks, widgets, or discount codes) to offers and services from third-party providers (collectively referred to as "affiliate links") into our online offering. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").
In order to track whether users have taken advantage of the offers of an affiliate link we use, it is necessary for the respective third-party providers to know that users have followed an affiliate link used within our online offering. The assignment of the affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission settlement and is canceled as soon as it is no longer necessary for this purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are part of the link or can be stored otherwise, e.g., in a cookie. These values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: interested parties. Users (e.g., website visitors, users of online services).
- Purposes of processing: Affiliate tracking.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Booking.com Partner Program: Affiliate marketing partner program; Service provider: Booking.com BV, Herengracht 597, 1017 CE Amsterdam, Netherlands; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.booking.com; Privacy Policy: https://www.booking.com/content/privacy.de.html. Basis for third-country transfers: Switzerland - Adequacy Decision (Netherlands).
Customer reviews and rating processes
We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the providers' general terms and conditions of use and privacy policies also apply. Typically, the rating also requires registration with the respective providers.
To ensure that the reviewers have actually used our services, we transmit, with the customer's consent, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or item number). This data is used solely to verify the user's authenticity.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Service recipients and clients. Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Rating widget: We integrate so-called "rating widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can be displayed, for example, in the form of a seal or similar element, sometimes also called a "badge." Although the corresponding content of the widget is displayed within our online offering, it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always display the most current content, especially the most recent rating. For this to happen, a data connection must be established from the website accessed within our online offering to the widget provider's server, and the widget provider receives certain technical data (access data, including the IP address) necessary to deliver the widget content to the user's browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to identify which online offerings participating in the rating process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Google Customer Reviews: Service for collecting and/or presenting customer satisfaction and opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Further information: When collecting customer reviews, an identification number and the time of the business transaction to be evaluated are processed; for review requests sent directly to customers, the customer's email address and their country of residence, as well as the review details themselves, are processed. Further information on the types of processing and the data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information about the services, data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Presence in social networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This could pose risks for users, for example, because it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. Therefore, cookies are generally stored on users' computers, in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by users (particularly if they are members of the respective platforms and are logged in there).
For a detailed description of the respective processing methods and the options for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the latter have access to user data and can directly take appropriate measures and provide information. Should you still need assistance, please contact us.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as the information relating to them, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); inventory data (e.g., full name, home address, contact information, customer number, etc.).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; feedback (e.g., collecting feedback via online form); public relations; marketing. Provision of our online offering and user-friendliness.
- Storage 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). Consent (Art. 6 (1) (a) GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Facebook Pages: Profiles within the social network Facebook - We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As described in the Facebook Data Policy under "How do we use this information?" As explained above, Facebook also collects and uses information to provide analytics services, so-called "Page Insights," to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information about Page Insights," https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Facebook Groups: We use the "Groups" feature of the Facebook platform to create interest groups within which Facebook users can contact each other or with us and exchange information. In doing so, we process personal data of our group users to the extent necessary for the purpose of group use and moderation. Our guidelines within the groups may contain further specifications and information regarding the use of the respective group. This data includes information about first and last names, published or privately shared content, values regarding group membership status or group-related activities, such as joining or leaving, as well as the time information for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Insights," to group operators so that they can gain insights into how people interact with their groups and the content associated with them. Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- LinkedIn: Social Network - We, together with LinkedIn Ireland Unlimited Company, are responsible for collecting (but not further processing) visitor data used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. We also collect details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information regarding LinkedIn's processing of user data can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, address 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 controllership is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based 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 Place, Dublin 2, Ireland; Legal basis: 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: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Snapchat: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.snapchat.com/; Privacy policy: https://www.snap.com/de-DE/privacy/privacy-policy. Basis for third country transfers: EU/EEA - Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses), Switzerland - Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses).
- TikTok: Social network, enables the sharing of photos and videos, commenting on and favorite posts, sending messages, and subscribing to accounts; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy. Basis for third country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- TikTok Business: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to accounts - We and TikTok are jointly responsible for the collection and transmission of event data as well as for measuring and creating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have concluded a special agreement on joint controllership with TikTok, which specifically regulates the security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct information or deletion requests directly to TikTok). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with TikTok. The agreement on joint controllership can be found in TikTok's "Jurisdiction Specific Terms": https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://x.com; Privacy policy: https://x.com/de/privacy. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: https://myadcenter.google.com/personalizationoff.
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.xing.com/; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
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 city maps (hereinafter collectively referred to as "content").
Integration always requires that the third-party providers of this content process the user's IP address, since without an IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address 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. These "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit, and other information about the use of our online offering, but may also be 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 permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); location data (information on the geographical position of a device or person). Event Data (Facebook) ("Event Data" is information that is sent to the provider Meta, for example, via meta pixels (whether via apps or other channels) and relates to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. Event Data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event Data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. "Event Data" is deleted by Meta after a maximum of two years, and the resulting target groups disappear when our Meta user accounts are deleted.)
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of recurring visitors); tracking (e.g., interest/behavior-based profiling, use of cookies); target group formation; marketing. Profiles with user-related information (creation of user profiles).
- Retention and Deletion: Deletion as described in the "General Information on Data Retention and Deletion" section. Cookies are stored for up to two years (unless otherwise stated, 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 procedures, methods and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or user-friendliness our online offering). In doing so, the respective providers collect the IP address of the users and can process this for the purposes of transmitting the software to the user's browser as well as for security purposes and to evaluate and optimize their offering. - We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or user-friendliness our online offering). In doing so, the respective providers collect the IP address of the users and can process this for the purposes of transmitting the software to the user's browser as well as for security purposes and to evaluate and optimize their offering; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Facebook plugins and content: Facebook social plugins and content - This can include, for example, content such as images, videos, or text and buttons that users can use to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during transmission (but not the further processing) of "event data" that Facebook collects or receives during transmission using the Facebook social plugins (and content embedding functions) that run on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users' interests). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum). 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 Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Google Fonts (obtained from Google servers): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their consistent presentation, and consideration of possible licensing restrictions. The font provider is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for providing the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the 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 website visitors, and the referring URL (i.e., the web page where the Google font should 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 referring URL). Access to this data is limited and tightly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. The Google Fonts Web API requires the user agent to customize the font generated for each browser type. The user agent is logged primarily 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 Google Fonts Analytics page. Finally, the referring URL is logged so that the data can be used for production maintenance and to generate an aggregated report on top integrations based on the number of font requests. Google states that 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: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate maps from the "Google Maps" service provided by Google. The data processed may include, in particular, users' IP addresses and location data. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland. Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Google Maps APIs and SDKs: Interfaces to Google's map and location services, which allow, for example, the addition of address entries, location determinations, distance calculations, or the provision of additional information on stands and other locations. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland. Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Instagram plugins and content: Instagram plugins and content - This can include, for example, content such as images, videos, or texts and buttons that users can use to share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during a transmission (but not the further processing) of "event data" that Facebook collects using Instagram functions (e.g., embedding functions for content) that are executed on our online offering or receives during a transmission for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum). 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 Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- LinkedIn plugins and content: LinkedIn plugins and content - This can include, for example, content such as images, videos or texts and buttons that users can use to share content from this online service within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- MyFonts: Fonts; data processed as part of font retrieval: the web font project identification number (anonymized), the URL of the licensed website, which is linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; Service provider: Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.myfonts.co. Privacy policy: https://www.myfonts.com/info/legal/#Privacy.
- YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 (1) (a) GDPR); website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
- 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 the so-called "extended data protection mode." In "extended data protection mode," until the video starts, only information such as your IP address and information about your browser and device can be stored on your device in cookies or using comparable processes that YouTube needs to display, control, and optimize the video. As soon as you play the videos, additional information can be processed by YouTube to analyze usage behavior, store it in your user profile, and personalize content and ads. Cookies can be stored for 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: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=,turn-on-privacy-enhanced-mode,erweiterten-datenschutzmodus-aktivieren.
- Xing plugins and buttons: Xing plugins and buttons – This can include, for example, content such as images, videos, or texts and buttons that users can use to share content from this online offering within Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third-country transfers: Switzerland – Adequacy Decision (Germany).
Management, organization and support tools
We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning, and providing our services. We comply with legal requirements when selecting third-party providers and their services.
In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their content.
If users are referred to third-party providers or their software or platforms as part of their communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to observe the privacy policies of the respective third-party providers.
- Types of data processed: Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: communication partners; users (e.g., website visitors, users of online services); business and contractual partners; interested parties; tenants.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); communication; organizational and administrative procedures.
- Storage 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, methods and services:
- Adobe Document Cloud: Cloud storage, cloud infrastructure services, and cloud-based application software for creating, editing, signing, and sharing PDF documents; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.adobe.com/de/creativecloud.html; Privacy Policy: https://www.adobe.com/de/privacy.html; Data processing agreement: Provided by the service provider. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Processing of data in the context of employment relationships
Within the framework of employment relationships, personal data is processed with the aim of effectively managing the establishment, implementation, and termination of such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.
Data processing encompasses various aspects, ranging from contract initiation to contract termination. This includes the organization and administration of daily working hours, the management of access rights and authorizations, and the handling of personnel development measures and employee interviews. Processing also serves the accounting and administration of wage and salary payments, which are critical aspects of contract execution.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring workplace safety or collecting performance data to evaluate and optimize operational processes. Furthermore, data processing includes the disclosure of employee data as part of external communication and publication processes where this is necessary for operational or legal purposes.
This data is always processed in compliance with the applicable legal framework, with the goal of creating and maintaining a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, anonymizing or deleting data after the processing purpose has been fulfilled or in accordance with statutory retention periods.
- Types of data processed: Employee data (information about employees and other persons in an employment relationship); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject of the contract, term, customer category); Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as authorship or time of creation); Social data (data subject to social secrecy and processed, for example, by social insurance providers, social assistance providers or welfare authorities); Log data (e.g. log files relating to logins or the retrieval of data or access times); Performance and behavior data (e.g. performance and behavior aspects such as performance evaluations, feedback from superiors, training participation, compliance with company policies, self-assessments and behavioral assessments). Working time data (e.g. start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, premiums, tax class information, surcharges for night work/overtime, tax deductions, social security contributions, net payout amount); image and/or video recordings (e.g. photographs or video recordings of a person); usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
- Special categories of personal data: Health data; Religious or philosophical beliefs; Trade union membership.
- Data subjects: Employees (e.g. employees, applicants, temporary workers and other staff).
- Purposes of processing: Establishment and implementation of employment relationships (processing of employee data in the context of establishing and implementing employment relationships); business processes and administrative procedures; provision of contractual services and fulfillment of contractual obligations; public relations; security measures; office and organizational procedures.
- Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR); Processing of special categories of personal data relating to healthcare, employment, and social security (Art. 9 (2) (h) GDPR).
Further information on processing procedures, methods and services:
- Time recording: Procedures for recording employee working hours include both manual and automated methods, such as the use of time clocks, time recording software, or mobile apps. Activities such as entering arrival and departure times, break times, overtime, and absences are performed. The review and validation of recorded working hours includes comparing them with deployment or shift schedules, reviewing absences, and having overtime approved by supervisors. Reports and analyses are created based on the recorded working hours to provide timesheets, overtime reports, and absence statistics for management and the human resources department. Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Authorization management: Procedures required to define, manage, and control access rights and user roles within a system or organization (e.g., creation of authorization profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Special categories of personal data: Special categories of personal data are processed within the framework of the employment relationship or to fulfill legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data can, for example, be passed on to health insurance companies or processed to assess the employees' ability to work or for company health management or to provide information to the tax office; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Sources of processed data: Personal data obtained as part of the application and/or employment relationship with employees is processed. In addition, personal data is collected from other sources if required by law. These may include tax authorities for tax-relevant information, the respective health insurance company for information on incapacity to work, third parties such as employment agencies, or publicly accessible sources such as professional social networks in the context of application processes. Legal basis: Legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Purposes of data processing: Employees' personal data is primarily processed to establish, implement, and terminate the employment relationship. Furthermore, the processing of this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfill regulatory and supervisory requirements, to optimize electronic data processing processes, and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed to assert legal claims and to defend against legal disputes; legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Transfer of employee data: Employee data is only processed internally by those departments that need it to fulfill operational, contractual, and legal obligations. Data is only passed on to external recipients if required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller can forward personal data to other recipients if this is necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) banks b) health insurance companies, pension insurance providers, retirement provision providers, and other social insurance providers c) authorities, courts (e.g. tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and information obligations) d) tax and legal advisors e) third-party debtors in the event of wage and salary garnishments f) other bodies to whom legally binding declarations must be made. Furthermore, data may be shared with third parties if necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender area of emails or letterheads, as well as the creation of profiles on external platforms. Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Transfer of employee data to third countries: Employee data will only be transferred to third countries, i.e., countries outside the European Union (EU) and the European Economic Area (EEA), if this is necessary to fulfill the employment relationship, is required by law, or if employees have given their consent. Employees will be informed separately of the details, where required by law; legal basis: legitimate interests (Article 6 (1) (f) GDPR).
- Business trips and travel expense accounting: Procedures required for the planning, implementation, and accounting of business trips (e.g., booking trips, organizing accommodation and transportation, managing travel expense advances, submitting and reviewing travel expense reports, monitoring and recording costs incurred, adhering to travel guidelines, and managing travel expenses); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Payroll accounting: Procedures required for the calculation, payment, and documentation of wages, salaries, and other remuneration of employees (e.g., recording working hours, calculating deductions and bonuses, paying taxes and social security contributions, preparing payroll statements, maintaining payroll accounts, reporting to tax authorities and social security institutions); Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR).
- Deletion of employee data: Under German law, employee data will be deleted if it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer. The following retention and archiving obligations must be observed:
- General personnel documents - General personnel documents (such as employment contracts, employment references, and supplementary agreements) are retained for up to three years after the end of the employment relationship (Section 195 of the German Civil Code). Tax-relevant documents - Tax-relevant documents in the personnel file are retained for six years (Section 147 of the German Fiscal Code, Section 257 of the German Commercial Code). Information on wages and working hours - Information on wages and working hours for (accident) insured persons with wage statements is retained for five years (Section 165 I 1, IV 2 of the German Social Code, Book VII).
- Payroll lists including lists for special payments - Payroll lists including lists for special payments, if a booking document exists, are kept for ten years (Section 147 AO, Section 257 HGB).
- Payroll lists for interim, final and special payments - Payroll lists for interim, final and special payments are kept for six years (Section 147 AO, Section 257 HGB).
- Employee insurance documents - Employee insurance documents, if accounting records exist, are kept for ten years (§ 147 AO, § 257 HGB).
- Contribution statements to social insurance institutions - Contribution statements to social insurance institutions are retained for ten years (Section 165 of the German Social Code, Book VII). Wage accounts - Wage accounts are retained for six years (Section 41 I 9 of the German Income Tax Act).
- Applicant data - Will be retained for a maximum of six months from receipt of the rejection.
- Working time records (for more than 8 hours on working days) - are kept for two years (Section 16 II of the Working Hours Act (ArbZG)).
- Application documents (after online job advertisement) - Will be kept for three to a maximum of six months after receipt of the rejection (§ 26
- Federal Data Protection Act (BDSG) nF, Section 15 IV General Equal Treatment Act (AGG)).
- Certificates of incapacity for work (AU) - are kept for up to five years (Section 6 I of the Expenditure Compensation Act (AAG)).
- Documents relating to company pension schemes - are retained for 30 years (Section 18a of the Act to Improve Company Pension Schemes (BetrAVG)).
- Employee sickness data - Retained for twelve months after the onset of the illness if absences do not exceed six weeks in a year.
- Maternity protection documents - are kept for two years (Section 27 (5) MuSchG).
Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to healthcare, profession and social security (Art. 9 (2) (h) GDPR).
- Personnel file management: Procedures required for the organization, updating, and management of employee data and records (e.g., recording personnel master data, storing employment contracts, certificates, and attestations, updating data in the event of changes, compiling documents for employee interviews, archiving personnel files, compliance with data protection regulations); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to healthcare, occupation, and social security (Art. 9 (2) (h) GDPR).
- Personnel development, performance evaluation and employee interviews: Procedures that are necessary in the area of the promotion and further development of employees as well as in the assessment of their performance and in the context of employee interviews (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, implementation of target agreement and feedback discussions, career planning and talent management, succession planning); Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to healthcare, occupation and social security (Art. 9 (2) (h) GDPR).
- Obligation to provide data: The controller informs employees that the provision of their data is necessary. This is generally the case if the data is required to establish and carry out the employment relationship or if its collection is prescribed by law. The provision of data may also be necessary if employees assert claims or are entitled to claims. The implementation of these measures or the provision of services depends on the provision of this data (for example, the provision of data for the purpose of receiving wages); legal bases: 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).
- Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if, on the one hand, this is necessary to perform the work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website, or in public registers after consultation or an agreed job description, or if the area of responsibility includes representative functions. This can also be the case if, as part of the performance of their duties, representation or communication with the public takes place, such as photographs being taken as part of public relations work. Otherwise, employee data will only be published with their consent or on the basis of the employer's legitimate interests, for example, in the case of stage or group photo shoots at a public event; legal bases: fulfillment of the contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
Change and update
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, the legal definitions apply. The following explanations, however, are intended primarily to facilitate understanding.
- Affiliate tracking: Affiliate tracking involves logging links that link websites to websites with product or other offers. The operators of the linked websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g., purchase goods or use services). To do this, the providers must be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. For affiliate links to function properly, they must be supplemented with certain values that become part of the link or are stored elsewhere, e.g., in a cookie. These values include, in particular, the source website (referrer), the time, an online identifier for the operator of the website on which the affiliate link was located, an online identifier for the respective offer, an online identifier for the user, and tracking-specific values, such as: B. Advertising ID, partner ID and categorizations
- Employees: Employees are individuals who are employed, whether as employees, staff, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, defined by an employment contract or agreement. It entails the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various stages, including the inception of the employment contract, the implementation of the contract, during which the employee performs their work, and the termination when the employment relationship ends, whether through resignation, termination agreement, or otherwise. Employee data is all information relating to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and banking details, working hours, vacation entitlements, health data, and performance appraisals.
- Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and unique identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unambiguous assignment and communication.
- Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can 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 itself, such as tags, descriptions, author information, and publication dates.
- Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
- Performance and behavior data: Performance and behavior data refers to information related to how individuals perform tasks or behave in a specific context, such as an educational, work, or social setting. This data can include metrics such as productivity, efficiency, work quality, attendance, and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes, and responses to various situations. This type of data is often used for performance evaluations, training and development efforts, and decision-making within organizations.
- Metadata, communication data, and procedural data: Metadata, communication data, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across different channels, such as email traffic, call logs, social media messages, and chat histories, including the people involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review events.
- Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a broad range of information, including how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. 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 the use of this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
- Log data: Log data is information about events or activities logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about a system's usage or operation. Log data is often used to analyze system problems, for security monitoring, or for generating performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interests 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 what content they are interested in. This allows them to, for example, better adapt website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- Location data: Location data is generated when a mobile device (or other device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical means and functions for location determination. Location data is used to indicate the geographically identifiable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: "Tracking" refers to the tracking of user behavior across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The "controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
- Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.
- Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged, or sold. This data category 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 can include contract start and end dates, the type of agreed services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
- Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is critical 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.
- Target group creation: Target group creation (English "custom audiences") refers to the creation of target groups for advertising purposes, e.g., the display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. "Lookalike audiences" (or similar target groups), on the other hand, refer to content deemed suitable and displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are typically used to create custom audiences and lookalike audiences.
our services as well as 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.
As of: March 4, 2025
Table of Contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Business processes and procedures
- Use of online platforms for offer and sales purposes
- Providers and services used in the course of business activities
- Payment methods
- Provision of the online service and web hosting
- Use of cookies
- Special notes on applications (apps)
- Registration, login and user account
- Blogs and publication media
- Contact and inquiry management
- Communication via Messenger
- Push notifications
- Video conferencing, online meetings, webinars and screen sharing
- Cloud Services
- Newsletters and electronic notifications
- Advertising communication via email, post, fax or telephone
- Sweepstakes and competitions
- Online marketing
- Affiliate programs and affiliate links
- Customer reviews and rating processes
- Presence in social networks (Social Media)
- Plug-ins and embedded functions and content
- Management, organization and support tools
- Processing of data in the context of employment relationships
- Change and update
- Definitions of terms
Person responsible
Soulmates Resorts GmbH, Kaiser-Friedrich-Promenade 89, 61348 Bad Homburg
Authorized representatives: Matthias Linhart
Email Address: info@soulamtes-resorts.com
Imprint: www.soulmates-resorts.com
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Employee data.
- Payment details.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Social data.
- Image and/or video recordings.
- Sound recordings.
- Event data (Facebook).
- Log data.
- Performance and behavioral data.
- Working time data.
- Salary data.
Special categories of data
- Health data.
- Religious or ideological beliefs.
- Trade union membership.
Categories of data subjects
- Service recipient and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Sweepstakes and competition participants.
- Business and contractual partners.
- Renter.
- People depicted.
- Third parties.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target group formation.
- Affiliate tracking.
- Organizational and administrative procedures.
- Conducting prize draws and competitions.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Establishment and implementation of employment relationships.
- Information technology infrastructure.
- Financial and payment management.
- Public relations.
- Sales promotion.
- Business processes and business procedures.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find 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 or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
- Legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary to fulfill a legal obligation to which the controller is subject.
- Legitimate interests (Article 6 (1) (f) GDPR) - processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require protection of personal data do not prevail.
- Processing of special categories of personal data relating to healthcare, occupation and social security (Article 9 (2) (h) GDPR) - Processing is necessary for the purposes of preventive healthcare or occupational medicine, for assessing the employee's capacity to work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social systems and services on the basis of Union or Member State law or on the basis of a contract with a healthcare professional.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, 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, state data protection laws of individual federal states may apply.
Relevant legal bases under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Data Protection Act (short "Swiss DSG"). Unlike, for example, the GDPR, the Swiss DSG does not generally require a legal basis for the processing of personal data to be stated and requires that the processing of personal data is carried out in good faith, lawful, and proportionate (Art. 6 para. 1 and 2 of the Swiss DSG). Furthermore, we only collect personal data for a specific purpose that is recognizable to the data subject and only process it in a manner compatible with that purpose (Art. 6 para. 3 of the Swiss DSG).
Note on the applicability of the GDPR and the Swiss Data Protection Act: This privacy policy serves to provide information in accordance with both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that, due to their broader geographical application and clarity, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "particularly sensitive personal data" used in the Swiss Data Protection Act, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss Data Protection Act within the scope of the Swiss Data Protection Act.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures 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 the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.
Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled 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
As part of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the group: Data transfer within the group: We may transfer personal data to other companies within our group or grant them access to it. This data transfer is based on our legitimate business and commercial interests. This includes, for example, improving business processes, ensuring efficient and effective internal communication, making optimal use of our human and technological resources, and enabling us to make informed business decisions. In certain cases, data transfer may also be necessary to fulfill our contractual obligations, or it may be based on the consent of the data subject or legal permission.
Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and operational interests, or it is necessary to fulfill our contractual obligations, or if the data subject's consent or legal permission exists.
International data transfers
Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 (1) GDPR). We will also inform you of the basis for third-country transfers from the individual providers in the third country, with the adequacy decisions taking precedence. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In the privacy policy, we inform you which service providers we use are certified under the Data Privacy Framework.
Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (FADP), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative security measures. These may include international treaties, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection rules approved in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss FADP, exceptions to the disclosure of data abroad may be permitted if certain conditions are met, including the consent of the data subject, contract execution, public interest, protection of life or physical integrity, publicly disclosed data, or data from a legally prescribed register. These disclosures are always made in accordance with legal requirements. Within the framework of the so-called "Data Privacy Framework" (DPF), the Swiss Federal Office for Information Security has recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of June 7, 2024. The list of certified companies and further information on the DPF can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). We inform you in our privacy policy about which service providers we use are certified under the Data Privacy Framework.
General information on data storage and deletion
We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there are no further legal grounds for processing. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist 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 on the retention and deletion of data that applies specifically to certain processing operations.
If there are multiple details regarding the retention period or deletion period for a given date, the longest period always applies.
If a period does not explicitly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the effective date of the termination or other termination of the legal relationship.
We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons only for the reasons that justify its storage.
Further information on processing procedures, methods and services:
- 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) No. 1 in conjunction with Section 3 AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with Section 4 HGB).
- 8 years - accounting documents, such as invoices and cost receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 Sentence 1 AO and Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 HGB).
- 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating statements, calculation documents, price labels, but also payroll documents insofar as they are not already accounting documents and cash register slips (Section 147 (1) Nos. 2, 3, 5 in conjunction with Section 3 AO, Section 257 (1) Nos. 2 and 3 in conjunction with Section 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
- Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:
- 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years - Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as to process related inquiries based on previous business experience and standard industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years applies, which is applicable in specific cases (Art. 127, 130 of the Swiss Code of Obligations). Claims for rent, lease, and capital interest, as well as other periodic payments, from the delivery of food, catering, and landlord debts, as well as from craft work, retail sales of goods, medical care, professional work by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees (Art. 128 of the Swiss Code of Obligations), expire after five years.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent at any time.
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to a supervisory authority: In accordance with the statutory provisions 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 in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of data subjects under the Swiss DSG:
As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to exercise your rights under this law and to ensure transparent data processing.
- Right to data disclosure or transfer: You have the right to request the disclosure of your personal data that you have provided to us in a common electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to objection, deletion and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be deleted or destroyed.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), within the framework of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.
We use this data to fulfill our contractual obligations. This includes, in particular, the obligation to provide the agreed services, any update obligations, and remedy in the event of warranty and other service disruptions. Furthermore, we use the data to protect our rights and for the purposes of the administrative tasks associated with these obligations, as well as for corporate organization. Furthermore, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse and the endangerment of their data, secrets, information, and rights (e.g., the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on contractual partners' data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed of other forms of processing, such as for marketing purposes, in this privacy policy.
We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., contract subject matter, term, customer category).
- Special categories of personal data: health data.
- Data subjects: Service recipients and clients; interested parties; business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and operational procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance 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 procedures, methods and services:
- Hospitality, hotel, and accommodation services: We process the information of our guests, visitors, and interested parties (collectively referred to as "guests") to provide our accommodation and related services of a tourist or gastronomic nature, as well as to bill for the services provided. Within the scope of our engagement, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) GDPR, in particular information about a person's health or information related to their religious beliefs. The processing is carried out to protect the health interests of visitors (e.g., in the case of information about allergies) or otherwise to meet their physical or mental needs upon request and with their consent. If required for the performance of the contract or by law, or with the consent of guests, or based on our legitimate interests, we will disclose or transmit guest data, for example, to the service providers involved in the performance of our services, or to authorities, billing centers, or in the area of IT, office, or similar services. Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- Rental services: We process the data of our tenants and prospective tenants in accordance with the underlying rental agreement. We may also process information about the characteristics and circumstances of individuals or property belonging to them if this is necessary within the scope of the rental agreement. This may include, for example, information about personal circumstances, movable or immovable property, financial situation, and the use of ancillary services (such as water or energy supply). Within the scope of our engagement, it may be necessary for us to process special categories of data within the meaning of Art. 9 (1) GDPR, in particular information about a person's health. This processing is carried out in order to protect the health interests of the tenants and otherwise only with the consent of the tenants. If necessary for the performance of the contract, legally required, or approved by the tenants, or based on our legitimate interests, we will disclose or transmit tenants' data as part of coverage inquiries, the conclusion and processing of contracts, e.g. to financial service providers, credit institutions, utilities (e.g. electricity), or authorities. We also process tenant data if this is necessary to fulfill legal obligations (e.g., information obligations in connection with additional services and additional costs); legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Business processes and procedures
Personal data of service recipients and clients – including customers, clients, or in special cases, clients, patients, business partners, and 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 collected data serves to fulfill contractual obligations and streamline operational processes. This includes processing business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal accounting and financial processes. In addition, the data supports the protection of the controller's rights and supports administrative tasks and the organization of the company.
Personal data may be transferred to third parties if this is necessary to fulfill the stated purposes or legal obligations. After the expiration of statutory retention periods or if 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: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); contract data (e.g., subject matter of the contract, term, customer category); log data (e.g., log files relating to logins or data retrieval or access times); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services); employees (e.g., employees, applicants, temporary workers, and other staff).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and administrative procedures; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance 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 procedures, methods and services:
- Contact management and contact maintenance: Procedures required to organize, maintain, and secure 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, backing up and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adapting contact strategies); Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts, and the control of payment flows (e.g., preparation and verification of transfers, processing of direct debit transactions, checking account statements, monitoring incoming and outgoing payments, direct debit management, account reconciliation, cash management); Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for the recording, processing, and control of business transactions in the area of accounts payable and accounts receivable accounting (e.g., creation and review of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation within the scope of receivables and liabilities, accounts payable and accounts receivable accounting); Legal basis: Contractual 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, administration, and control of financially relevant business 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, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Marketing, advertising, and sales promotion: Processes required within the scope of marketing, advertising, and sales promotion (e.g., market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair 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: Procedures required within the scope of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, preparation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, maintenance of corporate branding); Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for reach measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., contract subject matter, term, customer category); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Affected persons: Service recipients and clients; business and contractual partners; interested parties; tenants.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing; Business processes and administrative procedures; Communication; Office and organizational procedures; Organizational and administrative procedures; Provision of our online offering and user-friendliness; Affiliate tracking. Conversion measurement (measurement of the effectiveness of marketing measures).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
- Booking.com Partner Program: Affiliate marketing partner program; Service provider: Booking.com BV, Herengracht 597, 1017 CE Amsterdam, Netherlands; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.booking.com; Privacy Policy: https://www.booking.com/content/privacy.de.html. Basis for third-country transfers: Switzerland - Adequacy Decision (Netherlands).
- AirBnB: Rental and booking of accommodations, experiences, and discoveries; management of reservations; communication between hosts and guests; payment processing; Service provider: Airbnb Ireland UC, 8 Hanover Quay, D02 DP23 Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.airbnb.de; Privacy policy: https://www.airbnb.de/help/article/2855/datenschutzschutzerklärung. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- Ferienwohnungen-direkt: Rental platform for holiday apartments.
- Vrbo: Vacation rental platform.
- Expedia: Vacation rental platform.
Providers and services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter "Services") in compliance with legal requirements. Their use is based on our interest in the proper, lawful, and economical management of our business operations and our internal organization.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); contract data (e.g., subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; interested parties; business and contractual partners; employees (e.g., employees, applicants, temporary workers, and other staff).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures. Business processes and operational procedures.
- Storage 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, methods and services:
- DATEV: Software for accounting, communication with tax advisors and authorities, and document storage; Service provider: DATEV eG, Paumgartnerstr. 6-14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Payment methods
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, we use other service providers for this purpose (collectively "payment service providers").
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount, and recipient-related information. This information is required to process the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.
Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contract data (e.g., contract subject matter, term, customer category); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); contact data (e.g., postal and email addresses or telephone numbers).
- Data subjects: Service recipients and clients; business and contractual partners; interested parties.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and operational procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.mastercard.de/de-de.html; Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html. Basis for third-country transfers: Switzerland - Adequacy Decision (Belgium).
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. Basis for third-country transfers: Switzerland - Adequacy Decision (Luxembourg).
- Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.visa.de; Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html. Basis for third-country transfers: EU/EEA - Adequacy Decision (UK), Switzerland - Adequacy Decision (UK).
Provision of the online service and web hosting
We process user data 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 length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); protocol data (e.g. log files relating to logins or the retrieval of data or access times); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures; provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures. Organizational and administrative procedures.
- Storage 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, methods and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent from a corresponding server provider (also called a "web host") or obtain from other sources; 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, notification of successful access, 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 can be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization 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 needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
- Email sending and hosting: The web hosting services we use also include the sending, receiving, and storing of emails. For these purposes, the addresses of the recipients and senders, as well as other information regarding the email sending (e.g., the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that emails are generally not sent encrypted over the Internet. Emails are generally encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of emails between the sender and the recipient on our server; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Use of cookies
The term "cookies" refers to functions that store and retrieve information from users' end devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows. We use cookies in accordance with legal regulations. Where necessary, we obtain user consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and retrieving information is essential to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.
Notes on 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 processes.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, including by using the privacy settings of their browser.
- Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons 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 procedures, methods and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers named within the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and similar 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 operations and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. Consent declarations are saved to avoid repeated queries and to be able to provide evidence of consent in accordance with legal requirements. The data is stored on the server and/or in a cookie (so-called opt-in cookie) or using similar technologies in order to be able to assign consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used. Legal basis: Consent (Art. 6 (1) (a) GDPR).
Special notes on applications (apps)
We process the data of our application users to the extent necessary to provide the application and its functionalities to users, to monitor its security, and to further develop it. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administering or using the application. Furthermore, with regard to the processing of user data, we refer to the data protection information in this privacy policy.
Legal basis: The processing of data required to provide the application's functionalities serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g., enabling device functions). If the processing of data is not necessary to provide the application's functionalities, but serves the security of the application or our business interests (e.g., collecting data for the purpose of optimizing the application or for security purposes), it is based on our legitimate interests. If users are expressly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on their consent.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of the contract, term, customer category).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; provision of our online offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Commercial use: We process the data of our application users, registered users, and any test users (hereinafter referred to collectively as "users") in order to provide them with our contractual services, as well as on the basis of legitimate interests, to ensure the security of our application and to further develop it. The required information is marked as such within the scope of the user agreement, order, or similar contract conclusion and may include the information required for service provision and any billing, as well as contact information for any follow-up consultations. Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- Device permissions for access to functions and data: The use of our application or its functionalities may require users to grant permissions to access certain functions of the devices used or to the data stored on the devices or accessible through the devices. By default, these permissions must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users can contact us if they need clarification. We point out that denying or revoking the respective permissions may affect the functionality of our application.
Registration, login and user account
Users can create a user account. During registration, users are provided with the required mandatory information and processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and an email address).
When you use our registration and login functions, as well as your user account, we store your IP address and the time of each user action. This storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. This data is generally not shared with third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); log data (e.g., log files relating to logins or data retrieval or access times).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures; provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the "General Information on Data Storage and Deletion" section. Deletion after termination.
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation, or consent of the user; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
- No obligation to retain data: It is the responsibility of the user to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract. Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the framework of this privacy policy.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures; organizational and administrative procedures.
- Storage 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, methods and services:
- Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests. On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting. The personal information provided in the comments and contributions, any contact and website information, as well as the content information, will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Access to WordPress emojis and smileys: Access to WordPress emojis and smileys - Within our WordPress blog, graphic emojis (or smileys), i.e., small graphic files that express emotions, are used for the purpose of efficiently integrating content elements. The server providers collect the users' IP addresses. This is necessary so that the emoji files can be transmitted to the users' browsers; Service provider: Aut O'Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Contact and inquiry management
When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: communication partners.
- Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Storage 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). Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Further information on processing procedures, methods and services:
- Contact form: When you contact us via our contact form, by email, or other communication channels, we process the personal data you provide to answer and process your request. This generally includes information such as your name, contact information, and, if applicable, other information that is provided to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; legal bases: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.
You can also contact us via alternative means, such as telephone or email. Please use the contact options provided or those provided within our online offering.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure the encryption of the message content.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot see the content, they can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in our relationship with our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilling the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.
Revocation, objection, and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete messages in accordance with our general deletion guidelines (e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have responded to any inquiries from the communication partners, provided no reference to a previous conversation is expected and there are no statutory retention periods that prevent deletion.
Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that for certain reasons we may not be able to respond to inquiries via Messenger. This applies to situations where, for example, contract details must be treated with particular confidentiality or a response via Messenger does not meet formal requirements. In these cases, we recommend using more appropriate communication channels.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as the information relating to them, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); inventory data (e.g., full name, home address, contact information, customer number, etc.).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing: Communication; direct marketing (e.g., by email or post); marketing; provision of our online services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 (1) (a) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Apple iMessage: Send and receive text messages, voice messages, and video calls. Conduct group conversations. Share files, photos, videos, and locations. Secure communication with end-to-end encryption. Synchronize messages across multiple devices. Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Instagram: Sending messages via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- Facebook Messenger: Send and receive text messages, make voice and video calls, create group chats, share files and media, transmit location information, synchronize contacts, encrypt messages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Microsoft Teams: Chat, audio and video conferencing, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Snapchat: Snapchat Messenger with end-to-end encryption; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.snapchat.com/l/de-de; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy; Data processing agreement: https://www.snap.com/de-DE/terms/data-processing-agreement. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://www.snap.com/de-DE/terms/data-processing-agreement), Switzerland - Standard Contractual Clauses (https://www.snap.com/de-DE/terms/data-processing-agreement).
- WhatsApp: Text messages, voice and video calls, sending images, videos, and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- TikTok: Social network, enables the sharing of photos and videos, commenting on and favorite posts, sending messages, and subscribing to accounts; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy. Basis for third country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- TikTok Business: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to accounts - We and TikTok are jointly responsible for the collection and transmission of event data as well as for measuring and creating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have concluded a special agreement on joint controllership with TikTok, which specifically regulates the security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct information or deletion requests directly to TikTok). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with TikTok. The agreement on joint controllership can be found in TikTok's "Jurisdiction Specific Terms": https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- WhatsApp groups: We use the WhatsApp platform to create interest groups within which WhatsApp users can contact each other or with us and exchange information. Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Push notifications
With the consent of the users, we can send so-called "push notifications." These are messages that are displayed on the users' screens, devices, or browsers, even when our online service is not actively being used.
To subscribe to push notifications, users must confirm their browser or device's request to receive push notifications. This consent process is documented and stored. This data storage is necessary to determine whether users have consented to receive push notifications and to verify consent. For these purposes, a pseudonymous browser identifier (so-called "push token") or the device ID of a device is stored.
On the one hand, push notifications may be necessary for the fulfillment of contractual obligations (e.g., technical and organizational information relevant to the use of our online offering) and, unless specifically stated below, are otherwise sent based on user consent. Users can change the receipt of push notifications at any time using the notification settings of their respective browsers or devices.
- Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: communication partners.
- Purposes of processing: Communication; provision of our online services and user-friendliness. Direct marketing (e.g., by email or post).
- Retention and deletion: Deletion in accordance with the information in the "General Information on Data Storage and Deletion" section. Deletion after termination.
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Push messages with advertising content: The push notifications we send may contain advertising information. Advertising push messages are processed based on user consent. If the content of advertising push messages is specifically described as part of consent to receive them, these descriptions are decisive for user consent. Our newsletters also contain information about our services and us; legal basis: consent (Art. 6 (1) (a) GDPR).
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications from third-party providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as "conferences"). When selecting conference platforms and their services, we comply with legal requirements.
Data processed by conference platforms: When participating in a conference, the conference platforms process the personal data of participants listed below. The scope of processing depends on which data is required for a specific conference (e.g., providing access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' data may also be processed by the conference platforms for security purposes or to optimize the service. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content of the communication processes, i.e., entries in chats as well as audio and video data, as well as the use of other available functions (e.g., surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users on the conference platforms, additional data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, participants will be transparently informed of this in advance and, where necessary, asked for their consent.
Participant data protection measures: Please refer to the conference platforms' privacy policies for details on how your data is processed and select the optimal security and data protection settings for you within the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g., by informing roommates, locking doors, and using the background blur function, where technically possible). Links to the conference rooms and access data must not be shared with unauthorized third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to use the conference platforms or certain functions (e.g., consent to recording conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g., in participant lists, in the case of processing discussion results, etc.). Furthermore, user data is processed based on our legitimate interest in efficient and secure communication with our communication partners.
- Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Protocol data (e.g. log files relating to logins or the retrieval of data or access times).
- Data subjects: communication partners; users (e.g., website visitors, users of online services). Depicted persons.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
- Storage 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, methods and services:
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Cloud Services
We use software services accessible via the Internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the storage and management of content (e.g., document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
Within this framework, personal data may be processed and stored on the providers' servers if it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize their services.
If we use cloud services to provide forms, documents, and content to other users or publicly accessible websites, the providers may store cookies on users' devices for web analysis purposes or to remember users' settings (e.g., in the case of media control).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects: interested parties; communication partners; business and contractual partners.
- Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage 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, methods and services:
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services, and cloud-based application software; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security Notices: https://www.microsoft.com/de-de/trustcenter; Data Processing Agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or based on a legal basis. If the newsletter content is mentioned when registering for the newsletter, this content is decisive for the user's consent. Providing your email address is normally sufficient to register for our newsletter. However, in order to offer you a personalized service, we may ask you to provide your name so that we can address you personally 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 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 previous 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 on a block list (so-called "block list") for this purpose alone.
The registration process is logged based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); content data (e.g., textual or visual messages and contributions as well as related information, such as authorship or time of creation).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g., by email or post); provision of contractual services and fulfillment of contractual obligations; communication; provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
- Opt-out: You can unsubscribe from our newsletter at any time, i.e., revoke 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 by using one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
- Prerequisite for using free services: Consent to receive mailings may be made a condition for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
- Reminder emails regarding the order process: If users fail to complete an order process, we can remind users of the order process via email and send them a link to continue. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight, or forgetfulness. Emails are sent based on consent, which users can revoke at any time. Legal basis: Consent (Art. 6 (1) (a) GDPR).
- WhatsApp: Text messages, voice and video calls, sending images, videos, and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- WhatsApp groups: We use the WhatsApp platform to create interest groups within which WhatsApp users can contact each other or with us and exchange information. Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Advertising communication via email, post, fax or telephone
We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as email, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to advertising communication at any time.
After revocation or objection, we will store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on our legitimate interest in permanently respecting the user's revocation or objection, we also store the data necessary to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts as well as related information, such as authorship or time of creation).
- Data subjects: communication partners.
- Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Sweepstakes and competitions
We only process personal data of participants in prize draws and competitions in compliance with the relevant data protection regulations, provided that the processing is contractually necessary for the provision, implementation and processing of the prize draw, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through the possible collection of IP addresses when submitting prize draw entries).
If entries from participants are published as part of the competition (e.g., as part of a vote or presentation of the competition entries or winners, or in the reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or social network (e.g., Facebook or Instagram, hereinafter referred to as the "Online Platform"), the terms of use and privacy policy of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants during the competition, and any inquiries regarding the competition should be directed to us.
Participants' data will be deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because no further queries regarding the prize draw are expected. Participants' data will generally be deleted no later than six months after the end of the prize draw. Winners' data may be retained for longer, for example, to answer queries about the prizes or to fulfill the prize-winning services. In this case, the retention period depends on the type of prize and is up to three years for items or services, for example, in order to process warranty claims. Participants' data may also be stored for longer, for example, in the form of competition reporting in online and offline media.
If data was collected for other purposes as part of the competition, its processing and retention period are governed by the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
- Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts as well as related information, such as authorship or time of creation).
- Data subjects: Participants in prize draws and competitions.
- Purposes of processing: Conducting prize draws and competitions.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Online marketing
We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on potential user interests and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used to store the user information relevant to the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing processes know the actual user identity, only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to profiles, primarily if, for example, the users are members of a social network whose online marketing methods we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by providing consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
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 permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Information on revocation and objection:
We refer to the privacy policies of the respective providers and the opt-out options provided for each provider. If no explicit opt-out option has been provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offering. We therefore recommend the following additional opt-out options, which are summarized for each area:
a) Europa:
https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-territory: https://optout.aboutads.info.
- Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); Event Data (Facebook) ("Event Data" is information that is sent, for example, via meta pixels (whether via apps or other channels) to the provider Meta and relates to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. Event Data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event Data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. "Event Data" is deleted by Meta after a maximum of two years, and the resulting target groups disappear when our Meta user accounts are deleted.); Inventory Data (e.g., full name, home address, contact information, customer number, etc.); Payment Data (e.g., bank details, invoices, payment history); Contact Data (e.g., postal and email addresses or phone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
- Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group formation; marketing; profiles with user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures); provision of our online offering and user-friendliness; provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures. Organizational and administrative procedures.
- Retention and Deletion: Deletion as described in the "General Information on Data Retention and Deletion" section. Cookies are stored for up to two 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 basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Facebook advertisements: Placing advertisements within the Facebook platform and evaluating the ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Opt-out option: We refer to the data protection and advertising settings in the user profile on the Facebook platforms as well as to Facebook's consent procedures and contact options for exercising information and other data subject rights, as described in Facebook's privacy policy; Further information: Event data of users, i.e. Behavioral and interest information is processed for the purposes of targeted advertising and audience building on the basis of the joint controller agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and conversion measurement: Online marketing methods for placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure the conversion of the ads, i.e., whether users have used them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate Interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
- Instagram advertisements: Placing advertisements within the Instagram platform and evaluating the ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Possibility of objection (opt-out): We refer to the data protection and advertising settings in the user profile on the Instagram platform as well as within the framework of Instagram's consent process and Instagram's contact options for exercising information and other data subject rights in Instagram's privacy policy; Further information: Event data of users, i.e. Behavioral and interest information is processed for the purposes of targeted advertising and audience building on the basis of the joint controller agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions and saves them in a profile (possible purposes: measuring campaign performance, optimizing ad delivery, building user-defined and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Cookie Policy: https://www.linkedin.com/legal/cookie_policy; Data processing agreement: https://www.linkedin.com/legal/l/dpa; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Affiliate programs and affiliate links
We integrate so-called affiliate links or other references (which may include, for example, search masks, widgets, or discount codes) to offers and services from third-party providers (collectively referred to as "affiliate links") into our online offering. If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").
In order to track whether users have taken advantage of the offers of an affiliate link we use, it is necessary for the respective third-party providers to know that users have followed an affiliate link used within our online offering. The assignment of the affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission settlement and is canceled as soon as it is no longer necessary for this purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are part of the link or can be stored otherwise, e.g., in a cookie. These values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: interested parties. Users (e.g., website visitors, users of online services).
- Purposes of processing: Affiliate tracking.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Booking.com Partner Program: Affiliate marketing partner program; Service provider: Booking.com BV, Herengracht 597, 1017 CE Amsterdam, Netherlands; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.booking.com; Privacy Policy: https://www.booking.com/content/privacy.de.html. Basis for third-country transfers: Switzerland - Adequacy Decision (Netherlands).
Customer reviews and rating processes
We participate in review and rating processes to evaluate, optimize, and promote our services. If users rate us via the participating rating platforms or processes or otherwise provide feedback, the providers' general terms and conditions of use and privacy policies also apply. Typically, the rating also requires registration with the respective providers.
To ensure that the reviewers have actually used our services, we transmit, with the customer's consent, the necessary data regarding the customer and the service used to the respective review platform (including name, email address, and order number or item number). This data is used solely to verify the user's authenticity.
- Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Service recipients and clients. Users (e.g., website visitors, users of online services).
- Purposes of processing: Feedback (e.g., collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods and services:
- Rating widget: We integrate so-called "rating widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can be displayed, for example, in the form of a seal or similar element, sometimes also called a "badge." Although the corresponding content of the widget is displayed within our online offering, it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always display the most current content, especially the most recent rating. For this to happen, a data connection must be established from the website accessed within our online offering to the widget provider's server, and the widget provider receives certain technical data (access data, including the IP address) necessary to deliver the widget content to the user's browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to identify which online offerings participating in the rating process have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Google Customer Reviews: Service for collecting and/or presenting customer satisfaction and opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Further information: When collecting customer reviews, an identification number and the time of the business transaction to be evaluated are processed; for review requests sent directly to customers, the customer's email address and their country of residence, as well as the review details themselves, are processed. Further information on the types of processing and the data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information about the services, data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Presence in social networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This could pose risks for users, for example, because it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. Therefore, cookies are generally stored on users' computers, in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by users (particularly if they are members of the respective platforms and are logged in there).
For a detailed description of the respective processing methods and the options for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the latter have access to user data and can directly take appropriate measures and provide information. Should you still need assistance, please contact us.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as the information relating to them, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); inventory data (e.g., full name, home address, contact information, customer number, etc.).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; feedback (e.g., collecting feedback via online form); public relations; marketing. Provision of our online offering and user-friendliness.
- Storage 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). Consent (Art. 6 (1) (a) GDPR).
Further information on processing procedures, methods and services:
- Instagram: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Facebook Pages: Profiles within the social network Facebook - We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As described in the Facebook Data Policy under "How do we use this information?" As explained above, Facebook also collects and uses information to provide analytics services, so-called "Page Insights," to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information about Page Insights," https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Facebook Groups: We use the "Groups" feature of the Facebook platform to create interest groups within which Facebook users can contact each other or with us and exchange information. In doing so, we process personal data of our group users to the extent necessary for the purpose of group use and moderation. Our guidelines within the groups may contain further specifications and information regarding the use of the respective group. This data includes information about first and last names, published or privately shared content, values regarding group membership status or group-related activities, such as joining or leaving, as well as the time information for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Insights," to group operators so that they can gain insights into how people interact with their groups and the content associated with them. Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- LinkedIn: Social Network - We, together with LinkedIn Ireland Unlimited Company, are responsible for collecting (but not further processing) visitor data used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. We also collect details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information regarding LinkedIn's processing of user data can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, address 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 controllership is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based 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 Place, Dublin 2, Ireland; Legal basis: 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: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Snapchat: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.snapchat.com/; Privacy policy: https://www.snap.com/de-DE/privacy/privacy-policy. Basis for third country transfers: EU/EEA - Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses), Switzerland - Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses).
- TikTok: Social network, enables the sharing of photos and videos, commenting on and favorite posts, sending messages, and subscribing to accounts; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/de/privacy-policy. Basis for third country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- TikTok Business: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to accounts - We and TikTok are jointly responsible for the collection and transmission of event data as well as for measuring and creating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Data protection information on the processing of user data by TikTok can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have concluded a special agreement on joint controllership with TikTok, which specifically regulates the security measures TikTok must observe and in which TikTok has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct information or deletion requests directly to TikTok). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with TikTok. The agreement on joint controllership can be found in TikTok's "Jurisdiction Specific Terms": https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms), Switzerland - Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).
- X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://x.com; Privacy policy: https://x.com/de/privacy. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: https://myadcenter.google.com/personalizationoff.
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.xing.com/; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
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 city maps (hereinafter collectively referred to as "content").
Integration always requires that the third-party providers of this content process the user's IP address, since without an IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address 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. These "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit, and other information about the use of our online offering, but may also be 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 permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); location data (information on the geographical position of a device or person). Event Data (Facebook) ("Event Data" is information that is sent to the provider Meta, for example, via meta pixels (whether via apps or other channels) and relates to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. Event Data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that Event Data does not include actual content such as written comments, login information, or contact information such as names, email addresses, or phone numbers. "Event Data" is deleted by Meta after a maximum of two years, and the resulting target groups disappear when our Meta user accounts are deleted.)
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of recurring visitors); tracking (e.g., interest/behavior-based profiling, use of cookies); target group formation; marketing. Profiles with user-related information (creation of user profiles).
- Retention and Deletion: Deletion as described in the "General Information on Data Retention and Deletion" section. Cookies are stored for up to two years (unless otherwise stated, 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 procedures, methods and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or user-friendliness our online offering). In doing so, the respective providers collect the IP address of the users and can process this for the purposes of transmitting the software to the user's browser as well as for security purposes and to evaluate and optimize their offering. - We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or user-friendliness our online offering). In doing so, the respective providers collect the IP address of the users and can process this for the purposes of transmitting the software to the user's browser as well as for security purposes and to evaluate and optimize their offering; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
- Facebook plugins and content: Facebook social plugins and content - This can include, for example, content such as images, videos, or text and buttons that users can use to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during transmission (but not the further processing) of "event data" that Facebook collects or receives during transmission using the Facebook social plugins (and content embedding functions) that run on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users' interests). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum). 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 Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Google Fonts (obtained from Google servers): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their consistent presentation, and consideration of possible licensing restrictions. The font provider is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for providing the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the 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 website visitors, and the referring URL (i.e., the web page where the Google font should 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 referring URL). Access to this data is limited and tightly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. The Google Fonts Web API requires the user agent to customize the font generated for each browser type. The user agent is logged primarily 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 Google Fonts Analytics page. Finally, the referring URL is logged so that the data can be used for production maintenance and to generate an aggregated report on top integrations based on the number of font requests. Google states that 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: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate maps from the "Google Maps" service provided by Google. The data processed may include, in particular, users' IP addresses and location data. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland. Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Google Maps APIs and SDKs: Interfaces to Google's map and location services, which allow, for example, the addition of address entries, location determinations, distance calculations, or the provision of additional information on stands and other locations. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland. Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Instagram plugins and content: Instagram plugins and content - This can include, for example, content such as images, videos, or texts and buttons that users can use to share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during a transmission (but not the further processing) of "event data" that Facebook collects using Instagram functions (e.g., embedding functions for content) that are executed on our online offering or receives during a transmission for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which specifically regulates the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum). 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 Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
- LinkedIn plugins and content: LinkedIn plugins and content - This can include, for example, content such as images, videos or texts and buttons that users can use to share content from this online service within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- MyFonts: Fonts; data processed as part of font retrieval: the web font project identification number (anonymized), the URL of the licensed website, which is linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; Service provider: Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.myfonts.co. Privacy policy: https://www.myfonts.com/info/legal/#Privacy.
- YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 (1) (a) GDPR); website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Opt-out option: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
- 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 the so-called "extended data protection mode." In "extended data protection mode," until the video starts, only information such as your IP address and information about your browser and device can be stored on your device in cookies or using comparable processes that YouTube needs to display, control, and optimize the video. As soon as you play the videos, additional information can be processed by YouTube to analyze usage behavior, store it in your user profile, and personalize content and ads. Cookies can be stored for 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: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=,turn-on-privacy-enhanced-mode,erweiterten-datenschutzmodus-aktivieren.
- Xing plugins and buttons: Xing plugins and buttons – This can include, for example, content such as images, videos, or texts and buttons that users can use to share content from this online offering within Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third-country transfers: Switzerland – Adequacy Decision (Germany).
Management, organization and support tools
We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning, and providing our services. We comply with legal requirements when selecting third-party providers and their services.
In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their content.
If users are referred to third-party providers or their software or platforms as part of their communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to observe the privacy policies of the respective third-party providers.
- Types of data processed: Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: communication partners; users (e.g., website visitors, users of online services); business and contractual partners; interested parties; tenants.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); communication; organizational and administrative procedures.
- Storage 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, methods and services:
- Adobe Document Cloud: Cloud storage, cloud infrastructure services, and cloud-based application software for creating, editing, signing, and sharing PDF documents; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.adobe.com/de/creativecloud.html; Privacy Policy: https://www.adobe.com/de/privacy.html; Data processing agreement: Provided by the service provider. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
- Smoobu: Booking management, calendar synchronization across multiple channels, invoice generation, guest communication, provision of a booking portal, and analysis of rental data; Service provider: Smoobu GmbH, Wönnichstr. 68/70, 10317 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.smoobu.com/de/; Privacy policy: https://www.smoobu.com/de/datenschutz/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy Decision (Germany).
Processing of data in the context of employment relationships
Within the framework of employment relationships, personal data is processed with the aim of effectively managing the establishment, implementation, and termination of such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.
Data processing encompasses various aspects, ranging from contract initiation to contract termination. This includes the organization and administration of daily working hours, the management of access rights and authorizations, and the handling of personnel development measures and employee interviews. Processing also serves the accounting and administration of wage and salary payments, which are critical aspects of contract execution.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring workplace safety or collecting performance data to evaluate and optimize operational processes. Furthermore, data processing includes the disclosure of employee data as part of external communication and publication processes where this is necessary for operational or legal purposes.
This data is always processed in compliance with the applicable legal framework, with the goal of creating and maintaining a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, anonymizing or deleting data after the processing purpose has been fulfilled or in accordance with statutory retention periods.
- Types of data processed: Employee data (information about employees and other persons in an employment relationship); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject of the contract, term, customer category); Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as authorship or time of creation); Social data (data subject to social secrecy and processed, for example, by social insurance providers, social assistance providers or welfare authorities); Log data (e.g. log files relating to logins or the retrieval of data or access times); Performance and behavior data (e.g. performance and behavior aspects such as performance evaluations, feedback from superiors, training participation, compliance with company policies, self-assessments and behavioral assessments). Working time data (e.g. start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, premiums, tax class information, surcharges for night work/overtime, tax deductions, social security contributions, net payout amount); image and/or video recordings (e.g. photographs or video recordings of a person); usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
- Special categories of personal data: Health data; Religious or philosophical beliefs; Trade union membership.
- Data subjects: Employees (e.g. employees, applicants, temporary workers and other staff).
- Purposes of processing: Establishment and implementation of employment relationships (processing of employee data in the context of establishing and implementing employment relationships); business processes and administrative procedures; provision of contractual services and fulfillment of contractual obligations; public relations; security measures; office and organizational procedures.
- Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legal obligation (Art. 6 (1) (c) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR); Processing of special categories of personal data relating to healthcare, employment, and social security (Art. 9 (2) (h) GDPR).
Further information on processing procedures, methods and services:
- Time recording: Procedures for recording employee working hours include both manual and automated methods, such as the use of time clocks, time recording software, or mobile apps. Activities such as entering arrival and departure times, break times, overtime, and absences are performed. The review and validation of recorded working hours includes comparing them with deployment or shift schedules, reviewing absences, and having overtime approved by supervisors. Reports and analyses are created based on the recorded working hours to provide timesheets, overtime reports, and absence statistics for management and the human resources department. Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Authorization management: Procedures required to define, manage, and control access rights and user roles within a system or organization (e.g., creation of authorization profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Special categories of personal data: Special categories of personal data are processed within the framework of the employment relationship or to fulfill legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data can, for example, be passed on to health insurance companies or processed to assess the employees' ability to work or for company health management or to provide information to the tax office; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Sources of processed data: Personal data obtained as part of the application and/or employment relationship with employees is processed. In addition, personal data is collected from other sources if required by law. These may include tax authorities for tax-relevant information, the respective health insurance company for information on incapacity to work, third parties such as employment agencies, or publicly accessible sources such as professional social networks in the context of application processes. Legal basis: Legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Purposes of data processing: Employees' personal data is primarily processed to establish, implement, and terminate the employment relationship. Furthermore, the processing of this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfill regulatory and supervisory requirements, to optimize electronic data processing processes, and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed to assert legal claims and to defend against legal disputes; legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Transfer of employee data: Employee data is only processed internally by those departments that need it to fulfill operational, contractual, and legal obligations. Data is only passed on to external recipients if required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller can forward personal data to other recipients if this is necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) banks b) health insurance companies, pension insurance providers, retirement provision providers, and other social insurance providers c) authorities, courts (e.g. tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and information obligations) d) tax and legal advisors e) third-party debtors in the event of wage and salary garnishments f) other bodies to whom legally binding declarations must be made. Furthermore, data may be shared with third parties if necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender area of emails or letterheads, as well as the creation of profiles on external platforms. Legal bases: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Transfer of employee data to third countries: Employee data will only be transferred to third countries, i.e., countries outside the European Union (EU) and the European Economic Area (EEA), if this is necessary to fulfill the employment relationship, is required by law, or if employees have given their consent. Employees will be informed separately of the details, where required by law; legal basis: legitimate interests (Article 6 (1) (f) GDPR).
- Business trips and travel expense accounting: Procedures required for the planning, implementation, and accounting of business trips (e.g., booking trips, organizing accommodation and transportation, managing travel expense advances, submitting and reviewing travel expense reports, monitoring and recording costs incurred, adhering to travel guidelines, and managing travel expenses); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
- Payroll accounting: Procedures required for the calculation, payment, and documentation of wages, salaries, and other remuneration of employees (e.g., recording working hours, calculating deductions and bonuses, paying taxes and social security contributions, preparing payroll statements, maintaining payroll accounts, reporting to tax authorities and social security institutions); Legal basis: Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR).
- Deletion of employee data: Under German law, employee data will be deleted if it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer. The following retention and archiving obligations must be observed:
- General personnel documents - General personnel documents (such as employment contracts, employment references, and supplementary agreements) are retained for up to three years after the end of the employment relationship (Section 195 of the German Civil Code). Tax-relevant documents - Tax-relevant documents in the personnel file are retained for six years (Section 147 of the German Fiscal Code, Section 257 of the German Commercial Code). Information on wages and working hours - Information on wages and working hours for (accident) insured persons with wage statements is retained for five years (Section 165 I 1, IV 2 of the German Social Code, Book VII).
- Payroll lists including lists for special payments - Payroll lists including lists for special payments, if a booking document exists, are kept for ten years (Section 147 AO, Section 257 HGB).
- Payroll lists for interim, final and special payments - Payroll lists for interim, final and special payments are kept for six years (Section 147 AO, Section 257 HGB).
- Employee insurance documents - Employee insurance documents, if accounting records exist, are kept for ten years (§ 147 AO, § 257 HGB).
- Contribution statements to social insurance institutions - Contribution statements to social insurance institutions are retained for ten years (Section 165 of the German Social Code, Book VII). Wage accounts - Wage accounts are retained for six years (Section 41 I 9 of the German Income Tax Act).
- Applicant data - Will be retained for a maximum of six months from receipt of the rejection.
- Working time records (for more than 8 hours on working days) - are kept for two years (Section 16 II of the Working Hours Act (ArbZG)).
- Application documents (after online job advertisement) - Will be kept for three to a maximum of six months after receipt of the rejection (§ 26
- Federal Data Protection Act (BDSG) nF, Section 15 IV General Equal Treatment Act (AGG)).
- Certificates of incapacity for work (AU) - are kept for up to five years (Section 6 I of the Expenditure Compensation Act (AAG)).
- Documents relating to company pension schemes - are retained for 30 years (Section 18a of the Act to Improve Company Pension Schemes (BetrAVG)).
- Employee sickness data - Retained for twelve months after the onset of the illness if absences do not exceed six weeks in a year.
- Maternity protection documents - are kept for two years (Section 27 (5) MuSchG).
Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to healthcare, profession and social security (Art. 9 (2) (h) GDPR).
- Personnel file management: Procedures required for the organization, updating, and management of employee data and records (e.g., recording personnel master data, storing employment contracts, certificates, and attestations, updating data in the event of changes, compiling documents for employee interviews, archiving personnel files, compliance with data protection regulations); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to healthcare, occupation, and social security (Art. 9 (2) (h) GDPR).
- Personnel development, performance evaluation and employee interviews: Procedures that are necessary in the area of the promotion and further development of employees as well as in the assessment of their performance and in the context of employee interviews (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, implementation of target agreement and feedback discussions, career planning and talent management, succession planning); Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to healthcare, occupation and social security (Art. 9 (2) (h) GDPR).
- Obligation to provide data: The controller informs employees that the provision of their data is necessary. This is generally the case if the data is required to establish and carry out the employment relationship or if its collection is prescribed by law. The provision of data may also be necessary if employees assert claims or are entitled to claims. The implementation of these measures or the provision of services depends on the provision of this data (for example, the provision of data for the purpose of receiving wages); legal bases: 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).
- Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if, on the one hand, this is necessary to perform the work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website, or in public registers after consultation or an agreed job description, or if the area of responsibility includes representative functions. This can also be the case if, as part of the performance of their duties, representation or communication with the public takes place, such as photographs being taken as part of public relations work. Otherwise, employee data will only be published with their consent or on the basis of the employer's legitimate interests, for example, in the case of stage or group photo shoots at a public event; legal bases: fulfillment of the contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).
Change and update
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, the legal definitions apply. The following explanations, however, are intended primarily to facilitate understanding.
- Affiliate tracking: Affiliate tracking involves logging links that link websites to websites with product or other offers. The operators of the linked websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g., purchase goods or use services). To do this, the providers must be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. For affiliate links to function properly, they must be supplemented with certain values that become part of the link or are stored elsewhere, e.g., in a cookie. These values include, in particular, the source website (referrer), the time, an online identifier for the operator of the website on which the affiliate link was located, an online identifier for the respective offer, an online identifier for the user, and tracking-specific values, such as: B. Advertising ID, partner ID and categorizations
- Employees: Employees are individuals who are employed, whether as employees, staff, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, defined by an employment contract or agreement. It entails the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various stages, including the inception of the employment contract, the implementation of the contract, during which the employee performs their work, and the termination when the employment relationship ends, whether through resignation, termination agreement, or otherwise. Employee data is all information relating to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and banking details, working hours, vacation entitlements, health data, and performance appraisals.
- Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and unique identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unambiguous assignment and communication.
- Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can 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 itself, such as tags, descriptions, author information, and publication dates.
- Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
- Performance and behavior data: Performance and behavior data refers to information related to how individuals perform tasks or behave in a specific context, such as an educational, work, or social setting. This data can include metrics such as productivity, efficiency, work quality, attendance, and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes, and responses to various situations. This type of data is often used for performance evaluations, training and development efforts, and decision-making within organizations.
- Metadata, communication data, and procedural data: Metadata, communication data, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across different channels, such as email traffic, call logs, social media messages, and chat histories, including the people involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review events.
- Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a broad range of information, including how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. 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 the use of this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
- Log data: Log data is information about events or activities logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about a system's usage or operation. Log data is often used to analyze system problems, for security monitoring, or for generating performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interests 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 what content they are interested in. This allows them to, for example, better adapt website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- Location data: Location data is generated when a mobile device (or other device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical means and functions for location determination. Location data is used to indicate the geographically identifiable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: "Tracking" refers to the tracking of user behavior across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The "controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
- Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.
- Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged, or sold. This data category 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 can include contract start and end dates, the type of agreed services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
- Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is critical 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.
- Target group creation: Target group creation (English "custom audiences") refers to the creation of target groups for advertising purposes, e.g., the display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. "Lookalike audiences" (or similar target groups), on the other hand, refer to content deemed suitable and displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are typically used to create custom audiences and lookalike audiences.