General Terms and Conditions (GTC)


§ 1 Scope

  1. These General Terms and Conditions (hereinafter referred to as: GTC) apply to all accommodation contracts, hereinafter referred to as "Rental Agreement", between Soulmates Resorts GmbH, represented by the Managing Director Matthias Linhart, Kaiser-Friedrich-Promenade 89, 61348 Bad Homburg (hereinafter referred to as "Landlord") and the customers who rent a holiday apartment (hereinafter referred to as "Tenant").
  2. The terms and conditions apply regardless of whether the tenants are consumers, entrepreneurs or merchants.
  3. All agreements made between the landlord and the tenant in connection with the lease agreement arise in particular from these terms and conditions, the written order confirmation and the declaration of acceptance.
  4. The version of the terms and conditions valid at the time of conclusion of the contract shall apply.
  5. The landlord does not accept any differing terms and conditions of the tenant. This also applies if the landlord does not expressly object to their inclusion.
  6. If a deviation from the rental conditions is formulated in writing, this deviation takes precedence or supplements the general terms and conditions.


§ 2 General

  1. The subject of this concluded contract is the rental of holiday apartments.
  2. The apartments are intended for the number of people specified in the offer.
  3. The size, layout and furnishings of the holiday apartments are shown in the description.
  4. Dogs are allowed as pets, but only a maximum of two dogs per apartment. No other pets are permitted. Please use the dog beds in the living room.
  5. These are non-smoking apartments. Smoking is not permitted in the holiday apartments.


§ 3 Conclusion of Contract

  1. The presentation and advertising of the holiday apartments on the website or in other advertisements of the landlord does not constitute a binding offer to conclude a rental agreement.
  2. A rental agreement is only concluded upon signature by both contracting parties, or through a booking made by telephone or via other means of distance communication. A booking is binding.
  3. Receipt of the submitted order or reservation request will be confirmed immediately by email. Such an email does not yet constitute a binding acceptance of the order, unless it explicitly states acceptance in addition to confirming receipt.
  4. A contract only comes into effect when the landlord accepts the booking by issuing a declaration of acceptance.
  5. If a reservation for the desired period is not possible, for example because the holiday apartment is already rented, the landlord will refrain from issuing an acceptance. In this case, no contract is formed. The landlord will inform the tenant immediately and promptly refund any payments already received.
  6. Should the holiday apartment not be available for the booked rental period due to damage or other unforeseen events, the tenant has the right to terminate the rental agreement immediately. In this case, the tenant will receive a full refund of any payments already made. No alternative accommodation will be provided. Claims for damages due to the cancellation are excluded.


§ 4 Payment terms, set-off and right of retention

  1. All prices quoted on the website and in other advertisements by the landlord are gross prices including statutory VAT.
  2. Upon conclusion of the rental agreement for the duration of the use of the holiday apartment, the tenant undertakes to pay the contractually agreed rental price to the landlord.
  3. The payment options can be found on the invoice.
  4. The tenant has no right to changes regarding the rental start date or furnishings. A change of booking can only be made after consultation with the landlord. This requires the original rental agreement to be terminated (withdrawal) and replaced by a new rental agreement.
  5. Tenants are not entitled to offset claims against the landlord unless the counterclaims are legally established or undisputed. Tenants are also not entitled to offset claims against the landlord if they are asserting complaints about defects or counterclaims arising from the same tenancy agreement.
  6. Tenants may only exercise a right of retention if their counterclaim arises from the same lease agreement.


§ 5 Arrival and Departure

  1. Arrival is possible daily from 3 pm. On the day of departure, the holiday apartment must be vacated by 10 am at the latest.
  2. Exceeding the departure time by more than 30 minutes will result in the charge for an additional overnight stay.
  3. Other arrival and departure times can be arranged individually.
  4. If the tenant does not appear by 10:00 PM on the day of arrival without notification or prior agreement, the contract will be considered terminated after a period of 48 hours without notification to the landlord.
  5. A (partial) refund of the rent due to early departure is generally not possible.


§ 6 Cancellation

  1. 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 of the rental period. The cancellation must be made in writing via email and becomes effective upon receipt of the cancellation notice by the landlord.
  2. If the cancellation occurs less than 42 days before the agreed rental start date, a cancellation fee of 70% of the agreed rental price will be charged. The calculation is based on the total rental price for the booked period.
  3. If the cancellation occurs less than 28 days before the agreed rental start date, cancellation fees of 90% of the agreed rental price will apply. The calculation is based on the total rental price for the booked period.
  4. In the event of cancellation on the day the rental begins or if the renter fails to appear without prior cancellation, the entire rental price (100%) is due and payable by the renter.
  5. The landlord reserves the right, in the event that the cancelled holiday apartment is re-let to another tenant, to credit any costs saved by the cancellation and any revenue generated from the re-letting against the cancellation fees. The landlord will endeavor to re-let the holiday apartment in order to minimize the cancellation fees.
  6. The tenant retains the right to prove that the landlord has incurred no damage or significantly less damage than the cancellation fees mentioned in paragraphs (2) to (4).
  7. The tenant's statutory rights of withdrawal remain unaffected.
  8. Should cancellation by the landlord become necessary due to unforeseen circumstances (e.g., force majeure, natural disasters, power outages, or official measures) beyond their control, the entire amount already paid will be refunded. Further claims are excluded.
  9. Subject to availability, a rebooking for a later date may be offered. This is at the discretion of the landlord and is not a legal entitlement.
  10. (10) The landlord recommends that tenants take out travel cancellation insurance,

to protect oneself against unforeseen events.


§ 7 Rental period

  1. The rental period begins on the arrival date agreed upon by both parties and ends on the agreed end date. These dates are specified in the rental agreement.
  2. The right of both contracting parties to terminate the contract without notice remains unaffected by the contractually agreed rental period.
  3. If the tenant continues to use the rented property after the lease expires, the lease is not considered extended. Section 545 of the German Civil Code (BGB) does not apply.


§ 8 Return of the holiday apartment

  1. The tenant is obligated to return the holiday apartment in a proper, tidy, and clean condition at the end of the rental period. This includes, in particular, cleaning the kitchen, washing the dishes, emptying the trash can, and removing all personal belongings.
  2. All keys to the holiday apartment must be placed on the designated shelf inside next to the apartment door on the day of departure. The tenant is liable for the intentional or grossly negligent loss of keys and any resulting consequential costs, such as replacing locks.
  3. 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 them or their travel companions, unless such damage is due to normal wear and tear.
  4. In case of excessive soiling or failure to clean by the tenant, the landlord reserves the right to invoice the tenant for the additional costs.
  5. The landlord or a person authorized by them has the right to inspect the holiday apartment upon its return and to check for any defects or damage. If damage or significant soiling is found, the landlord reserves the right to charge the tenant for the costs of repairs or special cleaning.
  6. Should the holiday apartment not be vacated and returned by the agreed date, the landlord reserves the right to demand additional compensation for use in the amount of the agreed rental price per day. This does not affect any further claims for damages by the landlord.
  7. 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 Obligations of the tenant

  1. Tenants are obliged to treat the rented items (holiday apartment, inventory and outdoor facilities) with care.
  2. If damage occurs to the holiday apartment and/or its inventory during the rental period, the tenants are obliged to notify the provider immediately.
  3. Any defects or damage noticed upon arrival must be reported to the provider immediately.
  4. A reasonable period must be allowed for the rectification of damages and defects. Claims arising from complaints that are not reported immediately on site are excluded. Complaints received by the provider only at the end of the stay or after departure from the holiday apartment are also excluded from compensation.
  5. In the event of any service disruptions, the tenants are obliged to do everything reasonably possible within the scope of their legal obligations to contribute to remedying the disruption and to minimize any damage that may have occurred.
  6. On the day of departure, the 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.
  7. Several tenants are jointly and severally liable for any damages.
  8. When leaving the holiday apartment, the tenants are obliged to keep windows and doors closed, to turn all radiators to a low setting and to switch off lights and technical devices.
  9. The installation or attachment of decorative materials or similar items is not permitted in the holiday apartments. The tenant is liable for any damage to the rental property caused by the installation or attachment of decorations or similar items.
  10. (10) Otherwise, the provisions of the house rules apply, which can be viewed at any time on the landlord's website. The tenant confirms having read and understood the house rules and agrees to comply with them.


§ 10 Liability

  1. 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 only in accordance with the provisions of the Product Liability Act, for injury to life, body, or health, or for 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 this type of contract, unless unlimited liability applies due to injury to life, body, or health, or under the provisions of the Product Liability Act. Any further liability for damages is excluded.
  2. Essential contractual obligations are those whose fulfillment is a prerequisite for the proper execution of the contract and on whose compliance the tenant may regularly rely.
  3. The landlord is not liable for disturbances or impairments to the rented property that are outside his sphere of influence, such as those caused by force majeure, natural disasters, power outages or official measures.
  4. The landlord is only liable for the tenant's belongings, especially valuables, in cases of intent or gross negligence. It is recommended that valuables be kept securely stored or not left in the holiday apartment.
  5. The landlord accepts no liability for damages caused by improper use of the holiday apartment or by the tenant or their travel companions disregarding the house rules. The tenant is liable for all damages caused by them or their travel companions.
  6. The limitations of liability pursuant to paragraphs (1) to (5) also apply to the landlord's vicarious agents and legal representatives.
  7. The tenant's claims for damages are subject to the statutory limitation periods.


Section 11 Data Protection

  1. By accepting these terms and conditions, tenants agree that data concerning them, necessary for the execution of the rental agreement, may be stored, modified, and/or deleted. All personal data will be treated with absolute confidentiality.
  2. Furthermore, the landlord's privacy policy applies: http://editor.smoobu.com/preview/c5b56a721ced4265af432cf1f5231328?t=1741632072800


§ 12 Applicable Law and Jurisdiction

  1. The law of the Federal Republic of Germany applies.
  2. The contract language is German.
  3. Amendments and additions to this contract must be in writing. This also applies to any amendment of this written form clause.
  4. Should individual provisions of this contract be or become wholly or partially invalid, the validity of the remaining provisions shall not be affected. The invalid provision shall be replaced by a provision that most closely reflects the purpose of the contract and the intentions of the parties at the time of its conclusion. The same applies in the event of unintended gaps in the contract.

Privacy Policy

Preamble: With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing services.

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

The terms used are not gender-specific.

As of March 4, 2025


Table of Contents

  • Preamble
  • Responsible
  • Overview of processing activities
  • Relevant legal bases
  • Security measures
  • Transfer of personal data
  • International data transfers
  • General information on data storage and deletion
  • Rights of data subjects
  • Business services
  • Business processes and procedures
  • Use of online platforms for offering and sales purposes
  • Suppliers and services used in the course of business activities
  • Payment methods
  • Provision of the online service and web hosting
  • Use of cookies
  • Special notes regarding applications (apps)
  • Registration, login and user account
  • Blogs and publication media
  • Contact and inquiry management
  • Communication via Messenger
  • Push notifications
  • Video conferences, online meetings, webinars and screen sharing
  • Cloud Services
  • Newsletters and electronic notifications
  • Advertising communication via email, post, fax or telephone
  • Competitions and contests
  • Online marketing
  • Affiliate programs and affiliate links
  • Customer reviews and rating procedures
  • Presence in social networks (Social Media)
  • Plug-ins and embedded functions as well as content
  • Management, organization and support tools
  • Processing of data in the context of employment relationships
  • Changes and updates
  • Definitions of terms

Responsible

Soulmates Resorts GmbH, Kaiser-Friedrich-Promenade 89, 61348 Bad Homburg

Authorized representative: Matthias Linhart

Email Address: info@soulamtes-resorts.com

Legal notice: www.soulmates-resorts.com

Overview of processing activities

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

Types of data processed

  • Inventory data.
  • Employee data.
  • Payment details.
  • Location data.
  • Contact details.
  • Content data.
  • Contract details.
  • Usage data.
  • Metadata, communication data and process 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 philosophical beliefs.
  • Trade union membership.

Categories of affected persons

  • Recipient of services and client.
  • Employees
  • Interested parties.
  • Communication partner.
  • Users.
  • Sweepstakes and competition participants.
  • Business and contractual partners.
  • Renter.
  • People pictured.
  • Third parties.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Range measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Target group definition.
  • Affiliate tracking.
  • Organizational and administrative procedures.
  • Conducting prize draws and competitions.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online services and user-friendliness.
  • Establishment and implementation of employment relationships.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management 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 establishment. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Processing of special categories of personal data relating to health, occupation and social security (Art. 9 para. 2 lit. h) GDPR) - The processing is necessary for the purposes of preventive or occupational health care, for the assessment of the work capacity of the employee, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care schemes and services on the basis of Union or Member State law or on the basis of a contract with a health professional.

National data protection regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Relevant legal bases under the Swiss Federal Act on Data Protection: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (hereinafter referred to as the "Swiss Federal Act on Data Protection"). Unlike, for example, the GDPR, the Swiss Federal Act on Data Protection does not generally require that a legal basis for the processing of personal data be stated, and that the processing of personal data be carried out in good faith, lawfully, and proportionately (Art. 6 para. 1 and 2 of the Swiss Federal Act on Data Protection). 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 Federal Act on Data Protection).

Notice regarding the applicability of the GDPR and Swiss Federal Act on Data Protection (FADP): This privacy notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). Therefore, please note that, due to its broader geographical scope and clarity, the terms used here are those of the GDPR. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "special categories of personal data" used in the Swiss FADP, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are employed. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP when applicable.

Security measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

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

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers 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 to ensure its protection.

Data transfer within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to it. This data transfer is based on our legitimate business interests. These include, for example, improving business processes, ensuring efficient and effective internal communication, optimizing the use of our human and technological resources, and being able 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 on 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 interests or is necessary for the fulfillment of our contractual obligations, or if the data subject has given consent or if there is a legal basis for doing so.

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) and the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies, or companies, this is done only in accordance with 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 ensured by other means, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent, or in the case of a contractual or legally required transfer (Art. 49 para. 1 GDPR). We will inform you of the legal basis for the transfer to a third country with regard to the individual providers in the third country, whereby the adequacy decisions take precedence. Information on third-country transfers and existing adequacy decisions can be found on the European Commission's website: 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 European Commission has also recognized the level of data protection as adequate for certain US companies in its adequacy decision of July 10, 2023. 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 which of our service providers are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss Federal Act on Data Protection (FADP), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 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 safeguards. These may include international agreements, 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 regulations that have been recognized in advance by the FDPIC or a competent data protection authority of another country. According to Art. 16 of the FADP, exceptions for the disclosure of data abroad may be permitted if certain conditions are met, including the data subject's consent, contract performance, public interest, protection of life or physical integrity, publicly available data, or data from a legally required register. These disclosures are always made in accordance with legal requirements. Within the framework of the so-called "Data Privacy Framework" (DPF), Switzerland has recognized the level of data protection for certain US companies as adequate in its 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 which of our service providers 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 regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. 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 prosecution or for the protection of the rights of other natural or legal persons, must be archived accordingly.

Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.

If there are multiple specifications regarding the retention period or deletion deadlines for a given date, the longest period always applies.

If a time limit does not expressly begin on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.

Data that is no longer retained for the originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Further information on processing procedures, methods and services:

  • Data retention and deletion: The following general retention periods apply to data storage and archiving under German law:
  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
  • 8 years - accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
  • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years - Data required to consider potential warranty and damage claims 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 duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
  • Data retention and deletion: The following general retention periods apply to data storage 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 (OR)).
  • 10 years – Data necessary for considering potential claims for damages or similar contractual claims and rights, as well as for processing related inquiries, based on past 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 the case in certain circumstances (Art. 127, 130 of the Swiss Code of Obligations). Claims for rent, lease payments, and interest on capital, as well as other periodic payments, for the supply of food, for meals, and for innkeepers' debts, as well as for skilled trades work, retail sales of goods, medical services, professional services of lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees become time-barred after five years (Art. 128 of the Swiss Code of Obligations).

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with the legal requirements.
  • Right to lodge a complaint with a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss Data Protection Act:

As a data subject, you have 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 release or transfer: You have the right to request the release of your personal data that you have disclosed to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that your personal data be erased or destroyed.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners"), within the framework of contractual and similar 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. These include, in particular, the obligation to provide the agreed services, any update obligations, and remedying warranty claims and other service disruptions. Furthermore, we use the data to protect our rights and for the administrative tasks associated with these obligations, as well as for company organization. We also process the data based on our legitimate interests in both proper and efficient business management and security measures to protect our contractual partners and our business operations from misuse, compromise of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, such as for marketing purposes, within the scope of 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 means of special markings (e.g. colors) or symbols (e.g. stars or similar), or personally.

We delete data after the expiry of statutory warranty periods and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (for example, for tax purposes, usually ten years). Data disclosed to us by the contractual partner within the scope of a contract is deleted according to the specifications and generally after the contract has ended.

  • 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., subject matter of the contract, term, customer category).
  • Special categories of personal data: Health data.
  • Affected persons: 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 management procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Hospitality, hotel, and accommodation services: We process the information of our guests, visitors, and prospective customers (collectively referred to as "guests") in order to provide our accommodation and related tourist or gastronomic services, and to invoice for the services rendered. As part of our contractual obligations, it may be necessary for us to process special categories of data within the meaning of Article 9(1) GDPR, in particular information concerning a person's health or information relating to their religious beliefs. This processing is carried out to protect the health interests of visitors (e.g., in the case of allergy information) or otherwise to meet their physical or mental needs upon request and with their consent. Where necessary for the performance of the contract, required by law, or with the consent of guests, or based on our legitimate interests, we disclose or transmit guest data, for example, to service providers involved in the provision of our services, to authorities, billing agencies, and in the areas of IT, office, or similar services. Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 their property if this is necessary within the scope of the tenancy. 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). As part of our engagement, it may be necessary for us to process special categories of data within the meaning of Article 9(1) GDPR, in particular information concerning a person's health. This processing is carried out to protect the health interests of the tenants and otherwise only with the tenants' consent. If required for the performance of the contract, by law, or authorized by the tenants, or based on our legitimate interests, we disclose or transmit the tenants' data in connection with coverage inquiries, the conclusion and execution of contracts, e.g., to financial service providers, credit institutions, utility companies (e.g., electricity providers), or authorities. Furthermore, we process tenant data if this is necessary to fulfill legal obligations (e.g., information obligations in connection with ancillary services and ancillary costs); legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business processes and procedures

Personal data of service recipients and clients – including customers, clients, or in specific cases, clients, patients, or business partners, as well as other third parties – are 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 to design efficient operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies, and the assurance of internal accounting and financial processes. Additionally, the data supports the protection of the data controller's rights and facilitates administrative tasks and the organization of the company.

Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. Data will be deleted after the expiry of statutory retention periods or when the purpose of processing no longer applies. 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, 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); Content data (e.g., textual or image messages and posts, 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 concerning logins or data retrieval or access times); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; prospective clients; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services); employees (e.g., staff, applicants, temporary workers, and other employees).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and management 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further information on processing procedures, methods and services:

  • Contact management and maintenance: Procedures required for the organization, maintenance, and security of contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adapting contact strategies); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • General payment transactions: Procedures necessary for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creating and verifying transfers, processing direct debits, checking bank statements, monitoring incoming and outgoing payments, chargeback management, account reconciliation, cash management); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Accounting, accounts payable, accounts receivable: Processes necessary for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable (e.g., creating and verifying incoming and outgoing invoices, monitoring and managing open items, processing payments, handling dunning procedures, reconciling accounts receivable and payable, accounts payable and accounts receivable); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Processes necessary for recording, managing, and controlling financially relevant business transactions, as well as for calculating, reporting, and paying taxes (e.g., posting and booking business transactions, preparing quarterly and annual financial statements, processing payments, handling dunning procedures, reconciling accounts, providing tax advice, preparing and filing tax returns, and managing tax matters); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: Processes necessary for marketing, advertising and sales promotion (e.g., market analysis and target group definition, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade 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 para. 1 sentence 1 lit. f) GDPR).
  • Public relations: Procedures required within the framework of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of online platforms for offering 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 to the processing of payments and the methods used on the platforms for audience measurement and interest-based marketing.

  • 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., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Service recipients and clients; business and contractual partners; prospective clients; tenants.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing; business processes and operational procedures; communication; office and organizational procedures; organizational and administrative procedures; provision of our online services and user-friendliness; affiliate tracking; conversion measurement (measuring the effectiveness of marketing measures).
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Smoobu: Booking management, calendar synchronization across various channels, invoice creation, 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. f) GDPR); website: https://www.airbnb.de; privacy policy: https://www.airbnb.de/help/article/2855/datenschutzerklärung. Basis for third-country transfers: Switzerland - adequacy decision (Ireland).
  • Holiday apartments direct: Rental platform for holiday apartments.
  • Vrbo: Rental platform for vacation rentals.
  • Expedia: Rental platform for vacation rentals.

Suppliers and services used in the course of business activities

In the course of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter referred to as "Services") in compliance with legal requirements. Their use is based on our legitimate interest in the proper, lawful, and efficient management of our business operations and 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 image messages and posts, as well as related information such as authorship or date of creation); Contract data (e.g., subject matter of the contract, term, customer category).
  • Affected persons: Service recipients and clients; prospective clients; business and contractual partners. Employees (e.g., salaried 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 management procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 use additional service providers besides banks and credit institutions for this purpose (collectively "payment service providers").

The data processed by payment service providers includes master 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 necessary to process the transactions. However, the entered data is processed and stored only by the payment service providers. This means we do not receive any account or credit card information, but only confirmation or rejection of the payment. The payment service providers may transmit the data to credit reference agencies for identity and creditworthiness verification. Please refer to the terms and conditions and privacy policies of the payment service providers for further information.

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

  • 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); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Contact data (e.g., postal and email addresses or telephone numbers).
  • Affected persons: 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Mastercard: Payment services (technical integration of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 integration 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: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 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 time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); Log data (e.g., log files concerning logins or data retrieval or access times); Content data (e.g., textual or image messages and posts, as well as related information such as 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).
  • Affected persons: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
  • Purposes of processing: Provision of our online services 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web host") or otherwise obtain; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called "server log files." Server log files may contain 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, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 is exempt from deletion until the respective incident has been fully resolved.
  • Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. Please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). We therefore cannot assume any responsibility for the transmission of emails between the sender and their receipt on our server. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Smoobu: Booking management, calendar synchronization across various channels, invoice creation, 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 para. 1 sentence 1 lit. 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 information on and read it from users' devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. Where necessary, we obtain users' consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about the scope of this consent and which cookies are used.

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

Storage duration: The following types of cookies are distinguished with regard to storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved and preferred content to be displayed directly when the user revisits a website. User data collected via cookies can also be used for audience 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 these cookies are persistent and can be stored for up to two years.

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

  • Types of data processed: Metadata, communication data and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a consent management solution to obtain user consent for the use of cookies or for the processes and providers mentioned within the consent management solution. This process serves to obtain, log, manage, and revoke consent, particularly regarding the use of cookies and similar technologies that are used to store, read, and process information on users' devices. Within this process, user consent for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management process, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored to avoid repeated requests and to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to assign the consent to a specific user or their device. Unless specific information is available regarding the providers of consent management services, the following general guidelines apply: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details of the scope of consent (e.g., categories of cookies and/or service providers concerned), and information about the browser, system, and device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Special notes regarding applications (apps)

We process the data of users of our application to the extent necessary to provide users with the application and its functionalities, to monitor its security, and to further develop it. We may also contact users in accordance with legal requirements if communication is necessary for the administration or use of the application. For further information regarding the processing of user data, please refer to the data protection information in this privacy policy.

Legal basis: The processing of data necessary for providing the application's functionalities serves the purpose of fulfilling contractual obligations. This also applies if providing the functions requires user authorization (e.g., enabling device functions). If data processing is not necessary for providing the application's functionalities but serves the application's security or our business interests (e.g., collecting data for application optimization or security purposes), it is based on our legitimate interests. If users are explicitly asked for their consent to the processing of their data, the processing of the data covered by that consent is based on that consent.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, 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).
  • Affected persons: 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 services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Commercial Use: We process the data of users of our application, registered users, and any test users (hereinafter collectively referred to as "users"), in order to provide them with our contractual services and, based on legitimate interests, to ensure the security of our application and to further develop it. The required information is marked as such during the conclusion of a user agreement, order, purchase, or similar contract and may include the information required for service provision and any billing, as well as contact information to facilitate any necessary follow-up; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Device permissions for accessing functions and data: Using our application or its functionalities may require users to grant permissions to access certain functions of the devices used or to data stored on or accessible via the devices. By default, these permissions must be granted by 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 require further clarification. Please note that denying or revoking these permissions may affect the functionality of our application.

Registration, login and user account

Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and 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 action. This storage is based on our legitimate interests, as well as those of our users, in protection against misuse and other unauthorized use. We do not generally share this data with third parties unless it is necessary to pursue our legal claims or we are legally obligated to do so.

Users can be informed via email about processes 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); log data (e.g., log files relating to logins, data retrieval, or access times).
  • Affected persons: 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 services and user-friendliness.
  • Data Retention and Deletion: Deletion as described in the section "General Information on Data Storage and Deletion". Deletion after termination of the contract.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 user consent; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • No obligation to retain data: It is the users' responsibility to back up their data before the end of the contract if they have terminated their contract. We are entitled to irretrievably delete all user data stored during the contract period; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Blogs and publication media

We use blogs or similar online communication and publication tools (hereinafter referred to as "publication medium"). Reader 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. For further information regarding the processing of visitor data to our publication medium, please refer to the 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online services and user-friendliness; security measures; organizational and administrative procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves could be held liable for the comment or post and are therefore interested in the author's identity. Furthermore, we reserve the right, based on our legitimate interests, to process user data for spam detection. On the same legal basis, we reserve the right, in the case of surveys, to store users' IP addresses for the duration of the survey and to use cookies to prevent multiple voting. The personal information provided in the context of comments and posts, any contact and website information, as well as the content itself, will be stored by us permanently until the user objects; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Retrieval of WordPress Emojis and Smileys: Within our WordPress blog, graphical emojis (or smileys), i.e., small graphic files that express emotions, are used for the efficient integration of content elements. These are retrieved from external servers. The server providers collect users' IP addresses. This is necessary so that the emoji files can be transmitted to users' browsers. Service provider: Automattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 mail, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to answer the contact requests 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Communication partners.
  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: When you contact us via our contact form, email, or other communication channels, we process the personal data you provide to answer and process your request. This typically includes information such as your name, contact details, and any other information you provide that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to take note of the following information regarding the functionality of the messengers, encryption, the use of communication metadata and your options to object.

You can also contact us via alternative methods, such as by phone or email. Please use the contact options provided to you or those listed within our online services.

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 message content and attached images) is encrypted end-to-end. This means that the content of the messages is not visible, not even to the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure the encryption of message content.

However, we would also like to point out to our communication partners that while the messenger providers cannot see the content, they can find out that and when communication partners communicate with us, and that technical information about the communication partners' devices and, depending on their device settings, location information (so-called metadata) are processed.

Legal basis for communication: If we request permission from our communication partners before communicating with them via messenger, the legal basis for processing their data is their consent. Otherwise, if we do not request consent and they contact us on their own initiative, for example, we use messengers in our dealings with our contractual partners and during contract negotiations as a contractual measure. In the case of other interested parties and communication partners, we use messengers based on our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messenger. Furthermore, we would like to point out that we will not transmit the contact details you provide to the messenger service 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 the messages in accordance with our general deletion policy (i.e., 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 answered any inquiries from the communication partners, provided that no reference to a previous conversation is to be expected and that no legal retention obligations prevent deletion.

Subject to the possibility of using other communication channels: To ensure your security, we ask for your understanding that we may not be able to respond to inquiries via messenger for certain reasons. This applies to situations where, for example, contract details must be treated as particularly confidential or where a response via messenger does not meet formal requirements. In these cases, we recommend that you use more suitable communication channels.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Inventory data (e.g., full name, home address, contact information, customer number, etc.).
  • Affected persons: 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 equipment (computers, servers, etc.)).
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 through 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Instagram: Messaging via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 document collaboration, 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy statement: 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 para. 1 sentence 1 lit. 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 messaging, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 enabling users to share photos and videos, comment on and like posts, send messages, and subscribe 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 para. 1 sentence 1 lit. 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: A social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to accounts. We and TikTok are jointly responsible for collecting and transferring event data, as well as measuring and generating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, their actions, and information about the devices used (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Information regarding TikTok's processing of user data can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have entered into a specific joint controllership agreement with TikTok, which governs in particular the security measures TikTok must observe and in which TikTok has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to TikTok). The rights of users (in particular, the rights to information, deletion, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with TikTok. The joint controllership agreement 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 para. 1 sentence 1 lit. 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 us and exchange information; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 user's consent, we can send them so-called "push notifications." These are messages that appear on the user's screens, devices, or in their browsers, even when our online service is not actively being used.

To subscribe to push notifications, users must confirm their browser or device prompt to receive them. This consent process is documented and stored. This storage is necessary to identify whether users have consented to receiving push notifications and to be able to prove their consent. For these purposes, a pseudonymous browser identifier (a "push token") or the device ID of the end device is stored.

Push notifications may be necessary for fulfilling contractual obligations (e.g., providing relevant technical and organizational information for using our online services) and are otherwise sent based on user consent, unless specifically stated below. Users can change their push notification settings at any time using their browser or device's notification settings.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Communication partners.
  • Purposes of processing: Communication; provision of our online services and user-friendliness. Direct marketing (e.g., by email or post).
  • Data Retention and Deletion: Deletion as described in the section "General Information on Data Storage and Deletion". Deletion after termination of the contract.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Push notifications with advertising content: The push notifications we send may contain advertising information. These advertising push notifications are processed based on user consent. If the content of the advertising push notifications is specifically described as part of the consent process, these descriptions are decisive for the user's consent. Otherwise, our newsletters contain information about our services and our company; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Video conferences, online meetings, webinars and screen sharing

We use third-party platforms and applications (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"). We comply with legal requirements when selecting conference platforms and their services.

Data processed by conference platforms: When participating in a conference, the conference platforms process the following personal data of the participants. The scope of processing depends, firstly, on which data is required for a specific conference (e.g., providing access data or full names) and, secondly, on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the conference platforms may also process participant data for security purposes or service optimization. The processed data 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 connection, information on the participants' devices, their operating system, 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, and 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, further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recording: If text entries, participation results (e.g., from surveys) and video or audio recordings are logged, participants will be informed transparently in advance and asked for their consent if necessary.

Participant data protection measures: Please refer to the data protection notices of the conference platforms for details on how your data is processed and select the optimal security and data protection settings for yourself within the platform's settings. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of the 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.

Legal basis: If, in addition to the conference platforms, we also process user data and request users' consent to the use of the conference platforms or specific functions (e.g., consent to conference recordings), the legal basis for the processing is this consent. Furthermore, our processing may be necessary for the performance of our contractual obligations (e.g., in participant lists, in the case of processing meeting results, etc.). Otherwise, user data is processed based on our legitimate interests 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, 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); audio recordings. Log data (e.g., log files concerning logins or data retrieval or access times).
  • Affected persons: 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 document collaboration, 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy statement: 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 storing and managing content (e.g. document storage and management, exchanging documents, content and information with specific recipients or publishing content and information).

Within this framework, personal data may be processed and stored on the providers' servers, insofar as this data 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, master data and contact details of users, data relating to transactions, contracts, other processes, and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.

If we provide forms, documents, and content to other users or publicly accessible websites using cloud services, the providers may store cookies on users' devices for web analytics purposes or to remember user 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Affected persons: 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-de; Privacy statement: https://privacy.microsoft.com/de-de/privacystatement, Security information: 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") only with the recipient's consent or on the basis of a legal obligation. If the newsletter's content is specified during the registration process, this content is decisive for the user's consent. Normally, providing your email address is sufficient to register for our newsletter. However, to offer you a personalized service, we may ask for your name for a personal greeting in the newsletter or for further information if necessary for the newsletter's purpose.

Erasure 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 defending against potential claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In cases where we are obligated to permanently respect objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The registration process is logged based on our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure email 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); metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Content data (e.g., textual or image messages and posts, as well as information relating to them, such as authorship or time of creation).
  • Affected persons: 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 services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to receiving further newsletters. You will find a link to unsubscribe at the end of each newsletter, or you can use 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 a prerequisite for using free services (e.g., access to certain content or participation in specific promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
  • Order process reminder emails: If users do not complete an order, we can remind them of the process via email and send them a link to continue. This feature can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight, or forgetfulness. These emails are sent based on consent, which users can withdraw at any time; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • WhatsApp: Text messaging, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 us and exchange information; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to withdraw their consent at any time or to object to promotional communications at any time.

After revocation or objection, we store the data necessary to prove previous authorization for contacting you or sending you information for up to three years after the end of the year in which the revocation or objection occurred, based on our legitimate interests. The processing of this data is limited to the purpose of defending against potential claims. Based on our legitimate interest in permanently respecting users' revocations or objections, we also store the data necessary to prevent renewed contact (e.g., email address, telephone number, name, depending on the communication channel).

  • 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 image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
  • Affected persons: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Competitions and contests

We process personal data of participants in prize draws and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, execution and handling 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 possible recording of IP addresses when submitting prize draw entries).

If entries from participants are published as part of the competition (e.g., during voting, presentation of entries or winners, or in competition reporting), please note that participants' names may also be published in this context. Participants may 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 "online platform"), the terms of use and privacy policies of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by participants in connection with the competition and that any inquiries regarding the competition should be directed to us.

Participant data will be deleted as soon as the sweepstakes or competition has ended and the data is no longer needed to inform winners or because no further inquiries regarding the sweepstakes are expected. Generally, participant data will be deleted no later than six months after the end of the sweepstakes. Winners' data may be retained for a longer period, for example, to answer inquiries about the prizes or to fulfill prize obligations; in this case, the retention period depends on the type of prize and, for example, can be up to three years for goods or services, in order to process warranty claims. Furthermore, participant data may be stored for a longer period, for example, in the form of reports about the sweepstakes in online and offline media.

If data collected as part of the competition is also used for other purposes, 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 image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
  • Affected persons: Participants in sweepstakes and competitions.
  • Purposes of processing: Conducting prize draws and competitions.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as 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 methods are used to store user information relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical data such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this data may also be processed.

In addition, users' IP addresses are stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear 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 methods know the actual user identity, but only the information stored in their profiles.

The information contained in the profiles is typically stored in cookies or using similar methods. These cookies can later be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing provider.

In exceptional cases, it is possible to associate personal data with profiles, primarily when users are, for example, 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 giving their consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, through conversion tracking, we can analyze which of our online marketing methods have led to a conversion, i.e., a contract signed with us. Conversion tracking is used solely for the purpose of analyzing the success of our marketing activities.

Unless otherwise stated, please assume that the cookies used will be stored for a period of two years.

Information on the legal basis: If we request users' 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., our 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 cancellation and objection:

We refer you to the privacy policies of the respective providers and the opt-out options provided by those providers. If no explicit opt-out option is specified, you can disable cookies in your browser settings. However, this may limit the functionality of our website. We therefore also recommend the following opt-out options, which are offered for specific areas:

a) Europa:
https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) USA: https://www.aboutads.info/choices.

d) Across all regions: https://optout.aboutads.info.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); Event data (Facebook) ("Event data" is information sent to the provider Meta via Meta pixels (whether through 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 to create target groups for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as 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).
  • Affected persons: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
  • Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation; marketing; profiles with user-related information (creation of user profiles); conversion measurement (measuring the effectiveness of marketing measures); provision of our online services and user-friendliness; provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Facebook Ads: Placement of advertisements within the Facebook platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 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's profile on the Facebook platforms, as well as to Facebook's consent procedures and contact options for exercising rights of access and other data subject rights, as described in Facebook's privacy policy; Further information: User event data, i.e. Behavioral and interest data is processed for targeted advertising and audience segmentation purposes based on the joint controllership agreement ("Controller Addendum," https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer 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 tracking: Online marketing methods for placing content and ads within the service provider's advertising network (e.g., in search results, videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure ad conversions, i.e., whether users have taken the 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 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy Legal 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 terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
  • Instagram Advertising: Placement of advertisements within the Instagram platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 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); Opt-out option: We refer to the data protection and advertising settings in the user's profile on the Instagram platform, as well as within the framework of Instagram's consent procedure and Instagram's contact options for exercising rights of access and other data subject rights in Instagram's privacy policy; Further information: User event data, i.e. Behavioral and interest data is processed for targeted advertising and audience segmentation purposes based on the joint controllership agreement ("Controller Addendum," https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer 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 service and tracks the user's behavior and conversions, storing this information in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. 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 various channels, invoice creation, 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 para. 1 sentence 1 lit. 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

Our online services include so-called affiliate links or other references (which may include search boxes, widgets, or discount codes) to the offers and services of third-party providers (collectively referred to as "affiliate links"). If users follow the affiliate links and subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

To track whether users have taken advantage of offers via an affiliate link we have used, it is necessary for the respective third-party providers to be informed that users have followed an affiliate link within our online service. The assignment of affiliate links to the respective transactions or other actions (e.g., purchases) serves solely the purpose of commission calculation and is deleted as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are either part of the link itself or can be stored elsewhere, e.g., in a cookie. These values may include, in particular, the referring website, the time, an online identifier of the operator of the website where 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.

Information on the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is that consent. Otherwise, user data is processed based on our legitimate interests (i.e., our 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 time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Interested parties. Users (e.g., website visitors, users of online services).
  • Purpose of processing: Affiliate tracking.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 procedures

We participate in review and rating processes to evaluate, optimize, and promote our services. When users rate us through the participating rating platforms or processes, or otherwise provide feedback, the providers' terms and conditions and privacy policies also apply. As a rule, registration with the respective providers is also required to submit a rating.

To ensure that reviewers have actually used our services, we transmit the necessary data regarding the customer and the service used (including name, email address, and order number or item number) to the respective review platform with the customer's consent. 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 time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: 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 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Rating Widget: We integrate so-called "rating widgets" into our online services. A widget is a functional and content element integrated into our online services that displays dynamic information. It can be displayed, for example, as a seal or similar element, sometimes also called a "badge." While the widget's content is displayed within our online services, it is retrieved from the servers of the respective widget provider at that moment. This is the only way to ensure that the content shown is always up-to-date, especially the current rating. For this to work, a data connection must be established between the webpage accessed within our online services and the widget provider's server. The widget provider receives certain technical data (access data, including the IP address) necessary to deliver the widget's content to the user's browser. Furthermore, the widget provider receives information that users have visited our online services. This information can be stored in a cookie and used by the widget provider to identify which online services participating in the evaluation 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 para. 1 sentence 1 lit. f) GDPR).
  • Google Customer Reviews: Service for collecting and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 being reviewed are processed. For review requests sent directly to customers, the customer's email address, their country of residence, and 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 on 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 ourselves.

Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their 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 usage patterns and the resulting user interests. These profiles may then be used to display advertisements both within and outside the networks that are presumably tailored to the users' interests. Therefore, cookies are typically stored on users' computers to record their usage patterns and interests. Additionally, user profiles can also store data independent of the devices used by the users (especially if they are members of the respective platforms and logged in).

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

Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the latter have access to user data and can take appropriate action and provide information directly. Should you nevertheless require assistance, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Inventory data (e.g., full name, home address, contact information, customer number, etc.).
  • Affected persons: 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 services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe 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 sentence 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 Facebook social network - 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?" Facebook explains that it also collects and uses information to provide analytics services, known as "Page Insights," to page administrators, enabling them to gain insights into how people interact with their pages and the content associated with them. We have entered into a specific 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 comply with data subject rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). The rights of users (in particular, the rights to access, deletion, objection, and lodging a complaint with 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 by and transfer 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 transfer of data to its 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 para. 1 sentence 1 lit. 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 where Facebook users can connect with each other or with us and exchange information. In doing so, we process the personal data of our group members to the extent necessary for group use and moderation. Our group guidelines may contain further instructions and information regarding the use of the respective group. This data includes first and last names, published or privately shared content, group membership status, and group-related activities such as joining or leaving the group, as well as the timestamps of these activities. Furthermore, we 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, known as "Insights," to group administrators so 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 para. 1 sentence 1 lit. 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 are jointly responsible with LinkedIn Ireland Unlimited Company for collecting (but not further processing) visitor data used to generate "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as their actions. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, along with information from user profiles, such as job title, country, industry, hierarchical level, company size, and employment status. 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 entered into a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum) which, in particular, 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, submit requests for access or erasure directly to LinkedIn). The rights of users (in particular the right to access, erasure, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transfer 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 transfer of data to its parent company, LinkedIn Corporation, in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Legal 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.
  • Snapchat: Social network enabling users to share photos and videos, comment on and like posts, send messages, and subscribe to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 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 enabling users to share photos and videos, comment on and like posts, send messages, and subscribe 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 para. 1 sentence 1 lit. 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: A social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to accounts. We and TikTok are jointly responsible for collecting and transferring event data, as well as measuring and generating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, their actions, and information about the devices used (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Information regarding TikTok's processing of user data can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have entered into a specific joint controllership agreement with TikTok, which governs in particular the security measures TikTok must observe and in which TikTok has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to TikTok). The rights of users (in particular, the rights to information, deletion, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with TikTok. The joint controllership agreement 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 as well as content

We integrate functional and content elements into our online service 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").

The integration of third-party content always requires that these providers process users' IP addresses, as they cannot send the content to users' browsers without them. The IP address is therefore necessary for displaying this content or these functions. We strive to use only content from providers who use the IP address solely for content delivery. 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 allow information such as visitor traffic on the pages of this website to be analyzed. The pseudonymized information can also be stored in cookies on users' devices and may include, 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 services, as well as be combined with such information from other sources.

Information on the legal basis: 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., our 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 time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); location data (information on the geographic position of a device or person). Event data (Facebook) ("Event data" is information sent to the provider Meta, for example, via Meta pixels (whether through apps or other channels), relating 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 to create target groups for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as 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.).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation; marketing. Profiles with user-related information (creation of user profiles).
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 services that we retrieve from third-party servers (e.g., function libraries that we use for the presentation or user-friendliness of our online services). In doing so, the respective providers collect users' IP addresses and may process them for the purpose of transmitting the software to users' browsers, for security purposes, and for evaluating and optimizing their services. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Facebook Plugins and Content: Facebook Social Plugins and Content – This may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this website within Facebook. The list and appearance of the 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, as part of a transmission (but not the further processing), of "event data" that Facebook collects or receives through the Facebook Social Plugins (and content embedding functions) implemented on our website for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transactional messages (e.g., contacting users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information is likely to match users' interests). We have entered into a specific agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum) which, in particular, regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not occur under 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 rights to information, erasure, objection, and lodging a complaint with 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 para. 1 sentence 1 GDPR). Article 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Legal basis for third-country transfers: EU/EEA Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
  • Google Fonts (retrieved from Google servers): Fonts (and symbols) are retrieved for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their consistent display, and compliance with any applicable licensing restrictions. The user's IP address is transmitted to the font provider so that the fonts can be made available in the user's browser. Furthermore, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for providing the fonts depending on the device used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our website, users' browsers send HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then with the fonts specified in the CSS. 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 the website visitor, and the referring URL (i.e., the webpage where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, nor are they analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the specific browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the 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. According to Google, none of the information collected by Google Fonts is used to create end-user profiles or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Legal 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 para. 1 sentence 1 lit. 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 determination, distance calculations, or the provision of supplementary information about locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. 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 may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this online service within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, as part of a transfer (but not the further processing), of "event data" that Facebook collects or receives through Instagram functions (e.g., content embedding functions) implemented on our online service for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transactional messages (e.g., contacting users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information is presumably relevant to users' interests). We have concluded a special agreement with Facebook ("Addendum for Controllers", https://www.facebook.com/legal/controller_addendum), which in particular regulates which 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 data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not occur under 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 rights to information, erasure, objection, and lodging a complaint with 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 para. 1 GDPR). Article 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Legal basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
  • LinkedIn plugins and content: This may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this website within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 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 during font retrieval includes the (anonymized) identification number of the web font project, the URL of the licensed website 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 this extraction and storage of the page view count, 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 options: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad personalization: https://myadcenter.google.com/personalizationoff.
  • YouTube Videos: Our website includes embedded videos hosted on YouTube. These YouTube videos are integrated via a special domain using the "youtube-nocookie" component in so-called "enhanced privacy mode." In "enhanced privacy mode," until the video starts playing, only information such as your IP address, browser details, and device information is stored on your device in cookies or similar technologies. This information is necessary for YouTube to display, control, and optimize the video. Once you play the videos, additional information may be processed by YouTube to analyze user behavior, store it in your user profile, and personalize content and ads. The storage period for these cookies can be up to two years. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy Legal 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 – These may include content such as images, videos, or text, and buttons that allow users to share content from this online service within Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 delivering our services. We comply with legal requirements when selecting third-party providers and their services.

Within this framework, personal data may be processed and stored on the servers of third-party providers. This may involve various types of data, which we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data relating to transactions, contracts, other processes, and their content.

If users are referred to third-party providers or their software or platforms in the course of communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security, service optimization, or marketing purposes. We therefore ask you to review the privacy policies of the respective third-party providers.

  • Types of data processed: Content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved); 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).
  • Affected persons: Communication partners; users (e.g., website visitors, users of online services); business and contractual partners; prospective customers; tenants.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; provision of our online services 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 various channels, invoice creation, 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 para. 1 sentence 1 lit. 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

In the context of employment relationships, personal data is processed with the aim of effectively managing the establishment, execution, 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 management of daily working hours, the management of access rights and permissions, and the handling of personnel development measures and employee reviews. The processing also serves the purpose of payroll 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 for the evaluation and optimization of operational processes. Furthermore, data processing includes the disclosure of employee data within the framework of external communication and publication processes, where this is necessary for operational or legal purposes.

The processing of this data is always carried out in compliance with applicable legal frameworks, with the constant aim of creating and maintaining a fair and efficient working environment. This also includes respecting the data protection rights of the employees concerned, and 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 on employees and other persons in an employment relationship); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Master 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 image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Social data (data subject to social confidentiality and processed, for example, by social security institutions, social welfare agencies, or pension authorities); Log data (e.g., log files concerning logins or data retrieval or access times); Performance and behavioral data (e.g., performance and behavioral aspects such as performance reviews, feedback from supervisors, 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., base salary, bonus payments, premiums, tax bracket information, surcharges for night work/overtime, tax deductions, social security contributions, net payment amount); image and/or video recordings (e.g., photographs or video recordings of a person); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Special categories of personal data: Health data; Religious or philosophical beliefs; Trade union membership.
  • Affected persons: Employees (e.g., salaried staff, applicants, temporary workers and other employees).
  • Purposes of processing: Establishing and maintaining employment relationships (processing employee data in the context of establishing and maintaining employment relationships); business processes and procedures; provision of contractual services and fulfillment of contractual obligations; public relations; security measures; office and organizational procedures.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to healthcare, professional and social security (Art. 9 para. 2 lit. h) GDPR).

Further information on processing procedures, methods and services:

  • Time tracking: Procedures for recording employee working hours include both manual and automated methods, such as the use of time clocks, time tracking software, or mobile apps. Activities include entering arrival and departure times, break times, overtime, and absences. Verification and validation of the recorded working hours include reconciliation with duty rosters or shift schedules, verification of absences, and approval of overtime by supervisors. Reports and analyses are generated based on the recorded working hours to provide time sheets, overtime reports, and absence statistics for management and the HR department. Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Access management: Procedures required for defining, managing, and controlling access rights and user roles within a system or organization (e.g., creating access profiles, role- and access-based control, reviewing and approving access requests, regularly checking access rights, tracking and auditing user activities, creating security policies and procedures); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Special categories of personal data: Special categories of personal data are processed within the context of the employment relationship or to fulfill legal obligations. The processed special categories of personal data include data concerning the health, trade union membership, or religious affiliation of employees. This data may be disclosed to health insurance companies, processed for assessing employees' fitness for work, for occupational health management, or for providing information to the tax authorities. Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Sources of processed data: Personal data obtained during the application process and/or the employment relationship of employees is processed. In addition, personal data from other sources is collected where legally required. These may include tax authorities for tax-relevant information, the respective health insurance provider for information on incapacity for work, third parties such as employment agencies, or publicly accessible sources such as professional social networks in the context of application procedures. Legal bases: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Purposes of data processing: Employees' personal data is primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, processing this data is necessary to comply with legal obligations under 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 inter-company data, potentially including statistical data. Employee data may also be processed for the assertion of legal claims and for defense in legal disputes. Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transfer of employee data: Employee data is processed internally only by those departments that require it to fulfill operational, contractual, and legal obligations. Data is only transferred to external recipients if required by law or if the employees concerned have given their consent. Possible scenarios for this include requests for information from authorities or in the case of employee savings plans. Furthermore, the data controller may transfer personal data to other recipients to the extent necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) banks b) health insurance funds, pension insurance institutions, retirement savings providers, and other social security institutions c) authorities, courts (e.g., tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and disclosure obligations) d) tax and legal advisors e) third-party debtors in the case of wage and salary garnishments f) other bodies to which legally binding declarations must be submitted. Furthermore, data may be shared with third parties if this is necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender field of emails or letterheads, as well as the creation of profiles on external platforms; legal bases: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transfer of employee data to third countries: The transfer of employee data to third countries, i.e., countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the performance of the employment contract, required by law, or if employees have given their consent. Employees will be informed separately about the details, where required by law; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Business travel and travel expense accounting: Procedures necessary for the planning, execution, and accounting of business trips (e.g., booking travel, organizing accommodation and transportation, managing travel expense advances, submitting and reviewing travel expense reports, monitoring and recording incurred costs, complying with travel policies, and handling travel expense management); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Payroll accounting and wage processing: Procedures necessary for calculating, paying, and documenting 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, and reporting to tax authorities and social security institutions); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
  • Deletion of employee data: Employee data is deleted under German law when 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 employer's legitimate interests. The following retention and archiving obligations are observed:
  • General personnel documents – General personnel documents (such as employment contract, employment certificate, supplementary agreements) are kept for up to three years after the termination of the employment relationship (§ 195 German Civil Code). Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 German Fiscal Code, § 257 German Commercial Code). Information on wages and working hours – Information on wages and working hours for (accident) insured persons with proof of wages is kept for five years (§ 165 I 1, IV 2 German Social Code, Book VII).
  • Payroll lists including lists for special payments - Payroll lists including lists for special payments, provided that a booking document exists, are kept for ten years (§ 147 AO, § 257 HGB).
  • Payroll lists for interim, final and special payments - Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
  • Employee insurance documents - Employee insurance documents, provided that booking receipts are available, are kept for ten years (§ 147 AO, § 257 HGB).
  • Contribution statements to social security institutions – Contribution statements to social security institutions are kept for ten years (§ 165 SGB VII). Payroll accounts – Payroll accounts are kept for six years (§ 41 I 9 EStG).
  • Applicant data - will be stored 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 (§ 16 II Working Time Act (ArbZG)).
  • Application documents (following online job advertisement) - are 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 (§ 6 I Aufwendungsausgleichsgesetz (AAG)).
  • Documents relating to company pension schemes - These must be kept for 30 years (§ 18a Law on the Improvement of Company Pension Schemes (BetrAVG)).
  • Employee illness data - These are kept for twelve months after the start of the illness if the absences in one year do not exceed six weeks.
  • Documents relating to maternity protection - These are kept for two years (§ 27 para. 5 MuSchG).

Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to healthcare, professional and social security (Art. 9 para. 2 lit. h) GDPR).

  • Personnel file management: Procedures necessary for the organization, updating, and administration of employee data and documents (e.g., recording employee master data, storing employment contracts, certificates, and attestations, updating data when changes occur, compiling documents for employee reviews, archiving personnel files, and complying with data protection regulations); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, occupational health, and social security (Art. 9 para. 2 lit. h) GDPR).
  • Personnel development, performance appraisal, and employee appraisals: Procedures required for the promotion and development of employees, as well as for assessing their performance and conducting employee appraisals (e.g., needs analysis for further training, planning and implementation of training measures, preparation of performance appraisals, conducting target agreement and feedback meetings, career planning and talent management, succession planning); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, occupational health and safety (Art. 9 para. 2 lit. h) GDPR).
  • Obligation to provide data: The data controller informs employees that providing their data is necessary. This is generally the case if the data is required for establishing and carrying out the employment relationship or if its collection is legally mandated. Providing data may also be necessary if employees assert claims or are entitled to claims. The implementation of these measures or the fulfillment of services depends on the provision of this data (for example, providing data for the purpose of receiving wages). Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Publication and Disclosure of Employee Data: Employee data will only be published or disclosed to third parties if this is necessary for the performance of their duties in accordance with their employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website, or in public registers, as agreed upon or in accordance with their job description, or if their duties include representative functions. This may also be the case if the performance of duties involves public presentation or communication, such as taking photographs for public relations purposes. Otherwise, employee data will only be published with their consent or based on the employer's legitimate interests, for example, in the case of stage or group photographs taken at a public event. Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and updates

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

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, those legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Affiliate tracking: Affiliate tracking involves logging links that direct users from linking websites to websites with product or other offers. The operators of the linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). For this to work, providers need to be able to track whether users interested in specific offers subsequently take advantage of them as a result of clicking on the affiliate links. Therefore, for affiliate links to function, they must be supplemented with certain values that become part of the link itself or are stored elsewhere, such as in a cookie. These values include, in particular, the referring website, the timestamp, an online identifier of the operator of the website where the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID, and categorizations.
  • Employees: The term "employees" refers to individuals who are in an employment relationship, whether as staff members, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established through an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various phases, including its establishment, during which the employment contract is concluded; its performance, during which the employee carries out their work; and its termination, when the employment relationship ends, whether through dismissal, a mutual termination agreement, or otherwise. Employee data is all information relating to these individuals and situated within the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, leave entitlements, health data, and performance reviews.
  • Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar associations. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unambiguous identification and communication.
  • Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the content itself but also includes metadata that provides information about the content, 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 tracking: Conversion tracking (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. Typically, a cookie is stored on users' devices within the websites where the marketing measures are implemented and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Performance and behavioral data: Performance and behavioral data refers to information related to how individuals perform tasks or behave in a specific context, such as an educational, work, or social environment. This data can include metrics such as productivity, efficiency, work quality, attendance, and adherence to policies or procedures. Behavioral data might include interactions with colleagues, communication styles, decision-making processes, and reactions to various situations. These types of data are often used for performance reviews, training and development initiatives, and decision-making within organizations.
  • Metadata, communication data, and procedural data: These categories 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 modification history. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs, which are used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information, revealing how users utilize applications, which features they prefer, how long they stay on specific pages, and the paths they take through an application. Usage data can 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 referred to as "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 simply "profiling," encompasses any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Examples of such profiling include interests in specific content or products, click behavior on a website, or location. Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to generate performance reports.
  • Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience analysis, operators of online services can, for example, determine when users visit their websites and which content they are interested in. This allows them to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for audience analysis purposes to recognize returning visitors and thus obtain more accurate analyses of online service usage.
  • Location data: Location data is generated when a mobile device (or another device with the technical capabilities for location tracking) connects to a cell tower, Wi-Fi network, or similar location-determining technology. Location data indicates the geographically identifiable position of the device on Earth. It can be used, for example, to display map functions or other location-dependent information.
  • Tracking: "Tracking" refers to the process of observing user behavior across multiple online services. Typically, behavioral and interest information related to the online services 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 match their interests.
  • Controller: The term "controller" refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.
  • 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 category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include the start and end dates of the contract, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options, and special terms 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 encompasses all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction data, verification numbers, and invoice information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
  • Target group creation: Target group creation (also known as "Custom Audiences") refers to the process of defining target groups for advertising purposes, such as displaying advertisements. For example, based on a user's interest in specific products or topics online, it can be inferred that this user will be interested in advertisements for similar products or the online shop where they viewed those products. "Lookalike Audiences" (or similar target groups) are created when content deemed suitable is displayed to users whose profiles or interests are likely to match those of 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
  • Responsible
  • Overview of processing activities
  • Relevant legal bases
  • Security measures
  • Transfer of personal data
  • International data transfers
  • General information on data storage and deletion
  • Rights of data subjects
  • Business services
  • Business processes and procedures
  • Use of online platforms for offering and sales purposes
  • Suppliers and services used in the course of business activities
  • Payment methods
  • Provision of the online service and web hosting
  • Use of cookies
  • Special notes regarding applications (apps)
  • Registration, login and user account
  • Blogs and publication media
  • Contact and inquiry management
  • Communication via Messenger
  • Push notifications
  • Video conferences, online meetings, webinars and screen sharing
  • Cloud Services
  • Newsletters and electronic notifications
  • Advertising communication via email, post, fax or telephone
  • Competitions and contests
  • Online marketing
  • Affiliate programs and affiliate links
  • Customer reviews and rating procedures
  • Presence in social networks (Social Media)
  • Plug-ins and embedded functions as well as content
  • Management, organization and support tools
  • Processing of data in the context of employment relationships
  • Changes and updates
  • Definitions of terms

Responsible

Soulmates Resorts GmbH, Kaiser-Friedrich-Promenade 89, 61348 Bad Homburg

Authorized representative: Matthias Linhart

Email Address: info@soulamtes-resorts.com

Legal notice: www.soulmates-resorts.com

Overview of processing activities

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

Types of data processed

  • Inventory data.
  • Employee data.
  • Payment details.
  • Location data.
  • Contact details.
  • Content data.
  • Contract details.
  • Usage data.
  • Metadata, communication data and process 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 philosophical beliefs.
  • Trade union membership.

Categories of affected persons

  • Recipient of services and client.
  • Employees
  • Interested parties.
  • Communication partner.
  • Users.
  • Sweepstakes and competition participants.
  • Business and contractual partners.
  • Renter.
  • People pictured.
  • Third parties.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Range measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Target group definition.
  • Affiliate tracking.
  • Organizational and administrative procedures.
  • Conducting prize draws and competitions.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online services and user-friendliness.
  • Establishment and implementation of employment relationships.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management 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 establishment. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Processing of special categories of personal data relating to health, occupation and social security (Art. 9 para. 2 lit. h) GDPR) - The processing is necessary for the purposes of preventive or occupational health care, for the assessment of the work capacity of the employee, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care schemes and services on the basis of Union or Member State law or on the basis of a contract with a health professional.

National data protection regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Relevant legal bases under the Swiss Federal Act on Data Protection: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (hereinafter referred to as the "Swiss Federal Act on Data Protection"). Unlike, for example, the GDPR, the Swiss Federal Act on Data Protection does not generally require that a legal basis for the processing of personal data be stated, and that the processing of personal data be carried out in good faith, lawfully, and proportionately (Art. 6 para. 1 and 2 of the Swiss Federal Act on Data Protection). 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 Federal Act on Data Protection).

Notice regarding the applicability of the GDPR and Swiss Federal Act on Data Protection (FADP): This privacy notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). Therefore, please note that, due to its broader geographical scope and clarity, the terms used here are those of the GDPR. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "special categories of personal data" used in the Swiss FADP, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are employed. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP when applicable.

Security measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

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

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers 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 to ensure its protection.

Data transfer within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to it. This data transfer is based on our legitimate business interests. These include, for example, improving business processes, ensuring efficient and effective internal communication, optimizing the use of our human and technological resources, and being able 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 on 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 interests or is necessary for the fulfillment of our contractual obligations, or if the data subject has given consent or if there is a legal basis for doing so.

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) and the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies, or companies, this is done only in accordance with 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 ensured by other means, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent, or in the case of a contractual or legally required transfer (Art. 49 para. 1 GDPR). We will inform you of the legal basis for the transfer to a third country with regard to the individual providers in the third country, whereby the adequacy decisions take precedence. Information on third-country transfers and existing adequacy decisions can be found on the European Commission's website: 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 European Commission has also recognized the level of data protection as adequate for certain US companies in its adequacy decision of July 10, 2023. 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 which of our service providers are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss Federal Act on Data Protection (FADP), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 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 safeguards. These may include international agreements, 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 regulations that have been recognized in advance by the FDPIC or a competent data protection authority of another country. According to Art. 16 of the FADP, exceptions for the disclosure of data abroad may be permitted if certain conditions are met, including the data subject's consent, contract performance, public interest, protection of life or physical integrity, publicly available data, or data from a legally required register. These disclosures are always made in accordance with legal requirements. Within the framework of the so-called "Data Privacy Framework" (DPF), Switzerland has recognized the level of data protection for certain US companies as adequate in its 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 which of our service providers 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 regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. 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 prosecution or for the protection of the rights of other natural or legal persons, must be archived accordingly.

Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.

If there are multiple specifications regarding the retention period or deletion deadlines for a given date, the longest period always applies.

If a time limit does not expressly begin on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.

Data that is no longer retained for the originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Further information on processing procedures, methods and services:

  • Data retention and deletion: The following general retention periods apply to data storage and archiving under German law:
  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
  • 8 years - accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
  • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years - Data required to consider potential warranty and damage claims 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 duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
  • Data retention and deletion: The following general retention periods apply to data storage 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 (OR)).
  • 10 years – Data necessary for considering potential claims for damages or similar contractual claims and rights, as well as for processing related inquiries, based on past 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 the case in certain circumstances (Art. 127, 130 of the Swiss Code of Obligations). Claims for rent, lease payments, and interest on capital, as well as other periodic payments, for the supply of food, for meals, and for innkeepers' debts, as well as for skilled trades work, retail sales of goods, medical services, professional services of lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees become time-barred after five years (Art. 128 of the Swiss Code of Obligations).

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with the legal requirements.
  • Right to lodge a complaint with a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss Data Protection Act:

As a data subject, you have 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 release or transfer: You have the right to request the release of your personal data that you have disclosed to us in a commonly used electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that your personal data be erased or destroyed.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners"), within the framework of contractual and similar 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. These include, in particular, the obligation to provide the agreed services, any update obligations, and remedying warranty claims and other service disruptions. Furthermore, we use the data to protect our rights and for the administrative tasks associated with these obligations, as well as for company organization. We also process the data based on our legitimate interests in both proper and efficient business management and security measures to protect our contractual partners and our business operations from misuse, compromise of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, such as for marketing purposes, within the scope of 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 means of special markings (e.g. colors) or symbols (e.g. stars or similar), or personally.

We delete data after the expiry of statutory warranty periods and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (for example, for tax purposes, usually ten years). Data disclosed to us by the contractual partner within the scope of a contract is deleted according to the specifications and generally after the contract has ended.

  • 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., subject matter of the contract, term, customer category).
  • Special categories of personal data: Health data.
  • Affected persons: 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 management procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Hospitality, hotel, and accommodation services: We process the information of our guests, visitors, and prospective customers (collectively referred to as "guests") in order to provide our accommodation and related tourist or gastronomic services, and to invoice for the services rendered. As part of our contractual obligations, it may be necessary for us to process special categories of data within the meaning of Article 9(1) GDPR, in particular information concerning a person's health or information relating to their religious beliefs. This processing is carried out to protect the health interests of visitors (e.g., in the case of allergy information) or otherwise to meet their physical or mental needs upon request and with their consent. Where necessary for the performance of the contract, required by law, or with the consent of guests, or based on our legitimate interests, we disclose or transmit guest data, for example, to service providers involved in the provision of our services, to authorities, billing agencies, and in the areas of IT, office, or similar services. Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 their property if this is necessary within the scope of the tenancy. 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). As part of our engagement, it may be necessary for us to process special categories of data within the meaning of Article 9(1) GDPR, in particular information concerning a person's health. This processing is carried out to protect the health interests of the tenants and otherwise only with the tenants' consent. If required for the performance of the contract, by law, or authorized by the tenants, or based on our legitimate interests, we disclose or transmit the tenants' data in connection with coverage inquiries, the conclusion and execution of contracts, e.g., to financial service providers, credit institutions, utility companies (e.g., electricity providers), or authorities. Furthermore, we process tenant data if this is necessary to fulfill legal obligations (e.g., information obligations in connection with ancillary services and ancillary costs); legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business processes and procedures

Personal data of service recipients and clients – including customers, clients, or in specific cases, clients, patients, or business partners, as well as other third parties – are 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 to design efficient operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies, and the assurance of internal accounting and financial processes. Additionally, the data supports the protection of the data controller's rights and facilitates administrative tasks and the organization of the company.

Personal data may be disclosed to third parties if this is necessary to fulfill the aforementioned purposes or legal obligations. Data will be deleted after the expiry of statutory retention periods or when the purpose of processing no longer applies. 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, 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); Content data (e.g., textual or image messages and posts, 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 concerning logins or data retrieval or access times); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; prospective clients; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services); employees (e.g., staff, applicants, temporary workers, and other employees).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; business processes and management 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further information on processing procedures, methods and services:

  • Contact management and maintenance: Procedures required for the organization, maintenance, and security of contact information (e.g., setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regularly reviewing communication history, and adapting contact strategies); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • General payment transactions: Procedures necessary for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creating and verifying transfers, processing direct debits, checking bank statements, monitoring incoming and outgoing payments, chargeback management, account reconciliation, cash management); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Accounting, accounts payable, accounts receivable: Processes necessary for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable (e.g., creating and verifying incoming and outgoing invoices, monitoring and managing open items, processing payments, handling dunning procedures, reconciling accounts receivable and payable, accounts payable and accounts receivable); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Processes necessary for recording, managing, and controlling financially relevant business transactions, as well as for calculating, reporting, and paying taxes (e.g., posting and booking business transactions, preparing quarterly and annual financial statements, processing payments, handling dunning procedures, reconciling accounts, providing tax advice, preparing and filing tax returns, and managing tax matters); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: Processes necessary for marketing, advertising and sales promotion (e.g., market analysis and target group definition, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade 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 para. 1 sentence 1 lit. f) GDPR).
  • Public relations: Procedures required within the framework of public relations (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of online platforms for offering 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 to the processing of payments and the methods used on the platforms for audience measurement and interest-based marketing.

  • 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., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Service recipients and clients; business and contractual partners; prospective clients; tenants.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing; business processes and operational procedures; communication; office and organizational procedures; organizational and administrative procedures; provision of our online services and user-friendliness; affiliate tracking; conversion measurement (measuring the effectiveness of marketing measures).
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Smoobu: Booking management, calendar synchronization across various channels, invoice creation, 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. f) GDPR); website: https://www.airbnb.de; privacy policy: https://www.airbnb.de/help/article/2855/datenschutzerklärung. Basis for third-country transfers: Switzerland - adequacy decision (Ireland).
  • Holiday apartments direct: Rental platform for holiday apartments.
  • Vrbo: Rental platform for vacation rentals.
  • Expedia: Rental platform for vacation rentals.

Suppliers and services used in the course of business activities

In the course of our business activities, we use additional services, platforms, interfaces, or plug-ins from third-party providers (hereinafter referred to as "Services") in compliance with legal requirements. Their use is based on our legitimate interest in the proper, lawful, and efficient management of our business operations and 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 image messages and posts, as well as related information such as authorship or date of creation); Contract data (e.g., subject matter of the contract, term, customer category).
  • Affected persons: Service recipients and clients; prospective clients; business and contractual partners. Employees (e.g., salaried 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 management procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 use additional service providers besides banks and credit institutions for this purpose (collectively "payment service providers").

The data processed by payment service providers includes master 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 necessary to process the transactions. However, the entered data is processed and stored only by the payment service providers. This means we do not receive any account or credit card information, but only confirmation or rejection of the payment. The payment service providers may transmit the data to credit reference agencies for identity and creditworthiness verification. Please refer to the terms and conditions and privacy policies of the payment service providers for further information.

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

  • 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); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Contact data (e.g., postal and email addresses or telephone numbers).
  • Affected persons: 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Mastercard: Payment services (technical integration of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 integration 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: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 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 time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); Log data (e.g., log files concerning logins or data retrieval or access times); Content data (e.g., textual or image messages and posts, as well as related information such as 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).
  • Affected persons: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
  • Purposes of processing: Provision of our online services 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web host") or otherwise obtain; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called "server log files." Server log files may contain 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, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 is exempt from deletion until the respective incident has been fully resolved.
  • Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. Please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). We therefore cannot assume any responsibility for the transmission of emails between the sender and their receipt on our server. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Smoobu: Booking management, calendar synchronization across various channels, invoice creation, 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 para. 1 sentence 1 lit. 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 information on and read it from users' devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. Where necessary, we obtain users' consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about the scope of this consent and which cookies are used.

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

Storage duration: The following types of cookies are distinguished with regard to storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved and preferred content to be displayed directly when the user revisits a website. User data collected via cookies can also be used for audience 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 these cookies are persistent and can be stored for up to two years.

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

  • Types of data processed: Metadata, communication data and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a consent management solution to obtain user consent for the use of cookies or for the processes and providers mentioned within the consent management solution. This process serves to obtain, log, manage, and revoke consent, particularly regarding the use of cookies and similar technologies that are used to store, read, and process information on users' devices. Within this process, user consent for the use of cookies and the associated processing of information, including the specific processing activities and providers mentioned in the consent management process, is obtained. Users also have the option to manage and revoke their consent. The declarations of consent are stored to avoid repeated requests and to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to assign the consent to a specific user or their device. Unless specific information is available regarding the providers of consent management services, the following general guidelines apply: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details of the scope of consent (e.g., categories of cookies and/or service providers concerned), and information about the browser, system, and device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Special notes regarding applications (apps)

We process the data of users of our application to the extent necessary to provide users with the application and its functionalities, to monitor its security, and to further develop it. We may also contact users in accordance with legal requirements if communication is necessary for the administration or use of the application. For further information regarding the processing of user data, please refer to the data protection information in this privacy policy.

Legal basis: The processing of data necessary for providing the application's functionalities serves the purpose of fulfilling contractual obligations. This also applies if providing the functions requires user authorization (e.g., enabling device functions). If data processing is not necessary for providing the application's functionalities but serves the application's security or our business interests (e.g., collecting data for application optimization or security purposes), it is based on our legitimate interests. If users are explicitly asked for their consent to the processing of their data, the processing of the data covered by that consent is based on that consent.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, 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).
  • Affected persons: 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 services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Commercial Use: We process the data of users of our application, registered users, and any test users (hereinafter collectively referred to as "users"), in order to provide them with our contractual services and, based on legitimate interests, to ensure the security of our application and to further develop it. The required information is marked as such during the conclusion of a user agreement, order, purchase, or similar contract and may include the information required for service provision and any billing, as well as contact information to facilitate any necessary follow-up; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Device permissions for accessing functions and data: Using our application or its functionalities may require users to grant permissions to access certain functions of the devices used or to data stored on or accessible via the devices. By default, these permissions must be granted by 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 require further clarification. Please note that denying or revoking these permissions may affect the functionality of our application.

Registration, login and user account

Users can create a user account. During registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account based on contractual obligations. The processed data includes, in particular, login information (username, password, and 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 action. This storage is based on our legitimate interests, as well as those of our users, in protection against misuse and other unauthorized use. We do not generally share this data with third parties unless it is necessary to pursue our legal claims or we are legally obligated to do so.

Users can be informed via email about processes 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); log data (e.g., log files relating to logins, data retrieval, or access times).
  • Affected persons: 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 services and user-friendliness.
  • Data Retention and Deletion: Deletion as described in the section "General Information on Data Storage and Deletion". Deletion after termination of the contract.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 user consent; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • No obligation to retain data: It is the users' responsibility to back up their data before the end of the contract if they have terminated their contract. We are entitled to irretrievably delete all user data stored during the contract period; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Blogs and publication media

We use blogs or similar online communication and publication tools (hereinafter referred to as "publication medium"). Reader 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. For further information regarding the processing of visitor data to our publication medium, please refer to the 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online services and user-friendliness; security measures; organizational and administrative procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves could be held liable for the comment or post and are therefore interested in the author's identity. Furthermore, we reserve the right, based on our legitimate interests, to process user data for spam detection. On the same legal basis, we reserve the right, in the case of surveys, to store users' IP addresses for the duration of the survey and to use cookies to prevent multiple voting. The personal information provided in the context of comments and posts, any contact and website information, as well as the content itself, will be stored by us permanently until the user objects; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Retrieval of WordPress Emojis and Smileys: Within our WordPress blog, graphical emojis (or smileys), i.e., small graphic files that express emotions, are used for the efficient integration of content elements. These are retrieved from external servers. The server providers collect users' IP addresses. This is necessary so that the emoji files can be transmitted to users' browsers. Service provider: Automattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 mail, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to answer the contact requests 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Communication partners.
  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: When you contact us via our contact form, email, or other communication channels, we process the personal data you provide to answer and process your request. This typically includes information such as your name, contact details, and any other information you provide that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to take note of the following information regarding the functionality of the messengers, encryption, the use of communication metadata and your options to object.

You can also contact us via alternative methods, such as by phone or email. Please use the contact options provided to you or those listed within our online services.

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 message content and attached images) is encrypted end-to-end. This means that the content of the messages is not visible, not even to the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure the encryption of message content.

However, we would also like to point out to our communication partners that while the messenger providers cannot see the content, they can find out that and when communication partners communicate with us, and that technical information about the communication partners' devices and, depending on their device settings, location information (so-called metadata) are processed.

Legal basis for communication: If we request permission from our communication partners before communicating with them via messenger, the legal basis for processing their data is their consent. Otherwise, if we do not request consent and they contact us on their own initiative, for example, we use messengers in our dealings with our contractual partners and during contract negotiations as a contractual measure. In the case of other interested parties and communication partners, we use messengers based on our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messenger. Furthermore, we would like to point out that we will not transmit the contact details you provide to the messenger service 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 the messages in accordance with our general deletion policy (i.e., 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 answered any inquiries from the communication partners, provided that no reference to a previous conversation is to be expected and that no legal retention obligations prevent deletion.

Subject to the possibility of using other communication channels: To ensure your security, we ask for your understanding that we may not be able to respond to inquiries via messenger for certain reasons. This applies to situations where, for example, contract details must be treated as particularly confidential or where a response via messenger does not meet formal requirements. In these cases, we recommend that you use more suitable communication channels.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Inventory data (e.g., full name, home address, contact information, customer number, etc.).
  • Affected persons: 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 equipment (computers, servers, etc.)).
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 through 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
  • Instagram: Messaging via the social network Instagram; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 document collaboration, 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy statement: 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 para. 1 sentence 1 lit. 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 messaging, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 enabling users to share photos and videos, comment on and like posts, send messages, and subscribe 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 para. 1 sentence 1 lit. 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: A social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to accounts. We and TikTok are jointly responsible for collecting and transferring event data, as well as measuring and generating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, their actions, and information about the devices used (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Information regarding TikTok's processing of user data can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have entered into a specific joint controllership agreement with TikTok, which governs in particular the security measures TikTok must observe and in which TikTok has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to TikTok). The rights of users (in particular, the rights to information, deletion, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with TikTok. The joint controllership agreement 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 para. 1 sentence 1 lit. 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 us and exchange information; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 user's consent, we can send them so-called "push notifications." These are messages that appear on the user's screens, devices, or in their browsers, even when our online service is not actively being used.

To subscribe to push notifications, users must confirm their browser or device prompt to receive them. This consent process is documented and stored. This storage is necessary to identify whether users have consented to receiving push notifications and to be able to prove their consent. For these purposes, a pseudonymous browser identifier (a "push token") or the device ID of the end device is stored.

Push notifications may be necessary for fulfilling contractual obligations (e.g., providing relevant technical and organizational information for using our online services) and are otherwise sent based on user consent, unless specifically stated below. Users can change their push notification settings at any time using their browser or device's notification settings.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Communication partners.
  • Purposes of processing: Communication; provision of our online services and user-friendliness. Direct marketing (e.g., by email or post).
  • Data Retention and Deletion: Deletion as described in the section "General Information on Data Storage and Deletion". Deletion after termination of the contract.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Push notifications with advertising content: The push notifications we send may contain advertising information. These advertising push notifications are processed based on user consent. If the content of the advertising push notifications is specifically described as part of the consent process, these descriptions are decisive for the user's consent. Otherwise, our newsletters contain information about our services and our company; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Video conferences, online meetings, webinars and screen sharing

We use third-party platforms and applications (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"). We comply with legal requirements when selecting conference platforms and their services.

Data processed by conference platforms: When participating in a conference, the conference platforms process the following personal data of the participants. The scope of processing depends, firstly, on which data is required for a specific conference (e.g., providing access data or full names) and, secondly, on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the conference platforms may also process participant data for security purposes or service optimization. The processed data 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 connection, information on the participants' devices, their operating system, 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, and 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, further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recording: If text entries, participation results (e.g., from surveys) and video or audio recordings are logged, participants will be informed transparently in advance and asked for their consent if necessary.

Participant data protection measures: Please refer to the data protection notices of the conference platforms for details on how your data is processed and select the optimal security and data protection settings for yourself within the platform's settings. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of the 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.

Legal basis: If, in addition to the conference platforms, we also process user data and request users' consent to the use of the conference platforms or specific functions (e.g., consent to conference recordings), the legal basis for the processing is this consent. Furthermore, our processing may be necessary for the performance of our contractual obligations (e.g., in participant lists, in the case of processing meeting results, etc.). Otherwise, user data is processed based on our legitimate interests 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, 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); audio recordings. Log data (e.g., log files concerning logins or data retrieval or access times).
  • Affected persons: 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 document collaboration, 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy statement: 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 storing and managing content (e.g. document storage and management, exchanging documents, content and information with specific recipients or publishing content and information).

Within this framework, personal data may be processed and stored on the providers' servers, insofar as this data 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, master data and contact details of users, data relating to transactions, contracts, other processes, and their content. The cloud service providers also process usage data and metadata, which they use for security purposes and service optimization.

If we provide forms, documents, and content to other users or publicly accessible websites using cloud services, the providers may store cookies on users' devices for web analytics purposes or to remember user 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 image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Affected persons: 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/de-de; Privacy statement: https://privacy.microsoft.com/de-de/privacystatement, Security information: 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") only with the recipient's consent or on the basis of a legal obligation. If the newsletter's content is specified during the registration process, this content is decisive for the user's consent. Normally, providing your email address is sufficient to register for our newsletter. However, to offer you a personalized service, we may ask for your name for a personal greeting in the newsletter or for further information if necessary for the newsletter's purpose.

Erasure 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 defending against potential claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In cases where we are obligated to permanently respect objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The registration process is logged based on our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure email 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); metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Content data (e.g., textual or image messages and posts, as well as information relating to them, such as authorship or time of creation).
  • Affected persons: 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 services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to receiving further newsletters. You will find a link to unsubscribe at the end of each newsletter, or you can use 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 a prerequisite for using free services (e.g., access to certain content or participation in specific promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
  • Order process reminder emails: If users do not complete an order, we can remind them of the process via email and send them a link to continue. This feature can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight, or forgetfulness. These emails are sent based on consent, which users can withdraw at any time; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • WhatsApp: Text messaging, voice and video calls, sending of images, videos and documents, group chat function, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 us and exchange information; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to withdraw their consent at any time or to object to promotional communications at any time.

After revocation or objection, we store the data necessary to prove previous authorization for contacting you or sending you information for up to three years after the end of the year in which the revocation or objection occurred, based on our legitimate interests. The processing of this data is limited to the purpose of defending against potential claims. Based on our legitimate interest in permanently respecting users' revocations or objections, we also store the data necessary to prevent renewed contact (e.g., email address, telephone number, name, depending on the communication channel).

  • 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 image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
  • Affected persons: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Competitions and contests

We process personal data of participants in prize draws and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, execution and handling 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 possible recording of IP addresses when submitting prize draw entries).

If entries from participants are published as part of the competition (e.g., during voting, presentation of entries or winners, or in competition reporting), please note that participants' names may also be published in this context. Participants may 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 "online platform"), the terms of use and privacy policies of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by participants in connection with the competition and that any inquiries regarding the competition should be directed to us.

Participant data will be deleted as soon as the sweepstakes or competition has ended and the data is no longer needed to inform winners or because no further inquiries regarding the sweepstakes are expected. Generally, participant data will be deleted no later than six months after the end of the sweepstakes. Winners' data may be retained for a longer period, for example, to answer inquiries about the prizes or to fulfill prize obligations; in this case, the retention period depends on the type of prize and, for example, can be up to three years for goods or services, in order to process warranty claims. Furthermore, participant data may be stored for a longer period, for example, in the form of reports about the sweepstakes in online and offline media.

If data collected as part of the competition is also used for other purposes, 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 image messages and posts, as well as information relating to them, such as details of authorship or time of creation).
  • Affected persons: Participants in sweepstakes and competitions.
  • Purposes of processing: Conducting prize draws and competitions.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as 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 methods are used to store user information relevant to displaying the aforementioned content. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical data such as the browser used, the computer system used, and information about usage times and functions used. If users have consented to the collection of their location data, this data may also be processed.

In addition, users' IP addresses are stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear 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 methods know the actual user identity, but only the information stored in their profiles.

The information contained in the profiles is typically stored in cookies or using similar methods. These cookies can later be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing provider.

In exceptional cases, it is possible to associate personal data with profiles, primarily when users are, for example, 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 giving their consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, through conversion tracking, we can analyze which of our online marketing methods have led to a conversion, i.e., a contract signed with us. Conversion tracking is used solely for the purpose of analyzing the success of our marketing activities.

Unless otherwise stated, please assume that the cookies used will be stored for a period of two years.

Information on the legal basis: If we request users' 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., our 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 cancellation and objection:

We refer you to the privacy policies of the respective providers and the opt-out options provided by those providers. If no explicit opt-out option is specified, you can disable cookies in your browser settings. However, this may limit the functionality of our website. We therefore also recommend the following opt-out options, which are offered for specific areas:

a) Europa:
https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) USA: https://www.aboutads.info/choices.

d) Across all regions: https://optout.aboutads.info.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); Event data (Facebook) ("Event data" is information sent to the provider Meta via Meta pixels (whether through 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 to create target groups for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as 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).
  • Affected persons: Users (e.g., website visitors, users of online services); interested parties; business and contractual partners; tenants.
  • Purposes of processing: Audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation; marketing; profiles with user-related information (creation of user profiles); conversion measurement (measuring the effectiveness of marketing measures); provision of our online services and user-friendliness; provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Facebook Ads: Placement of advertisements within the Facebook platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 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's profile on the Facebook platforms, as well as to Facebook's consent procedures and contact options for exercising rights of access and other data subject rights, as described in Facebook's privacy policy; Further information: User event data, i.e. Behavioral and interest data is processed for targeted advertising and audience segmentation purposes based on the joint controllership agreement ("Controller Addendum," https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer 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 tracking: Online marketing methods for placing content and ads within the service provider's advertising network (e.g., in search results, videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We also measure ad conversions, i.e., whether users have taken the 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 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy Legal 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 terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
  • Instagram Advertising: Placement of advertisements within the Instagram platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 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); Opt-out option: We refer to the data protection and advertising settings in the user's profile on the Instagram platform, as well as within the framework of Instagram's consent procedure and Instagram's contact options for exercising rights of access and other data subject rights in Instagram's privacy policy; Further information: User event data, i.e. Behavioral and interest data is processed for targeted advertising and audience segmentation purposes based on the joint controllership agreement ("Controller Addendum," https://www.facebook.com/legal/controller_addendum). Joint controllership is limited to the collection and transfer of data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly the transfer 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 service and tracks the user's behavior and conversions, storing this information in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. 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 various channels, invoice creation, 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 para. 1 sentence 1 lit. 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

Our online services include so-called affiliate links or other references (which may include search boxes, widgets, or discount codes) to the offers and services of third-party providers (collectively referred to as "affiliate links"). If users follow the affiliate links and subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

To track whether users have taken advantage of offers via an affiliate link we have used, it is necessary for the respective third-party providers to be informed that users have followed an affiliate link within our online service. The assignment of affiliate links to the respective transactions or other actions (e.g., purchases) serves solely the purpose of commission calculation and is deleted as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented with certain values that are either part of the link itself or can be stored elsewhere, e.g., in a cookie. These values may include, in particular, the referring website, the time, an online identifier of the operator of the website where 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.

Information on the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is that consent. Otherwise, user data is processed based on our legitimate interests (i.e., our 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 time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Interested parties. Users (e.g., website visitors, users of online services).
  • Purpose of processing: Affiliate tracking.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 procedures

We participate in review and rating processes to evaluate, optimize, and promote our services. When users rate us through the participating rating platforms or processes, or otherwise provide feedback, the providers' terms and conditions and privacy policies also apply. As a rule, registration with the respective providers is also required to submit a rating.

To ensure that reviewers have actually used our services, we transmit the necessary data regarding the customer and the service used (including name, email address, and order number or item number) to the respective review platform with the customer's consent. 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 time spent on the site, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: 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 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Rating Widget: We integrate so-called "rating widgets" into our online services. A widget is a functional and content element integrated into our online services that displays dynamic information. It can be displayed, for example, as a seal or similar element, sometimes also called a "badge." While the widget's content is displayed within our online services, it is retrieved from the servers of the respective widget provider at that moment. This is the only way to ensure that the content shown is always up-to-date, especially the current rating. For this to work, a data connection must be established between the webpage accessed within our online services and the widget provider's server. The widget provider receives certain technical data (access data, including the IP address) necessary to deliver the widget's content to the user's browser. Furthermore, the widget provider receives information that users have visited our online services. This information can be stored in a cookie and used by the widget provider to identify which online services participating in the evaluation 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 para. 1 sentence 1 lit. f) GDPR).
  • Google Customer Reviews: Service for collecting and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 being reviewed are processed. For review requests sent directly to customers, the customer's email address, their country of residence, and 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 on 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 ourselves.

Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their 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 usage patterns and the resulting user interests. These profiles may then be used to display advertisements both within and outside the networks that are presumably tailored to the users' interests. Therefore, cookies are typically stored on users' computers to record their usage patterns and interests. Additionally, user profiles can also store data independent of the devices used by the users (especially if they are members of the respective platforms and logged in).

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

Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the latter have access to user data and can take appropriate action and provide information directly. Should you nevertheless require assistance, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Inventory data (e.g., full name, home address, contact information, customer number, etc.).
  • Affected persons: 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 services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe 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 sentence 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 Facebook social network - 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?" Facebook explains that it also collects and uses information to provide analytics services, known as "Page Insights," to page administrators, enabling them to gain insights into how people interact with their pages and the content associated with them. We have entered into a specific 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 comply with data subject rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). The rights of users (in particular, the rights to access, deletion, objection, and lodging a complaint with 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 by and transfer 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 transfer of data to its 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 para. 1 sentence 1 lit. 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 where Facebook users can connect with each other or with us and exchange information. In doing so, we process the personal data of our group members to the extent necessary for group use and moderation. Our group guidelines may contain further instructions and information regarding the use of the respective group. This data includes first and last names, published or privately shared content, group membership status, and group-related activities such as joining or leaving the group, as well as the timestamps of these activities. Furthermore, we 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, known as "Insights," to group administrators so 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 para. 1 sentence 1 lit. 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 are jointly responsible with LinkedIn Ireland Unlimited Company for collecting (but not further processing) visitor data used to generate "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as their actions. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, along with information from user profiles, such as job title, country, industry, hierarchical level, company size, and employment status. 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 entered into a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum) which, in particular, 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, submit requests for access or erasure directly to LinkedIn). The rights of users (in particular the right to access, erasure, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transfer 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 transfer of data to its parent company, LinkedIn Corporation, in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Legal 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.
  • Snapchat: Social network enabling users to share photos and videos, comment on and like posts, send messages, and subscribe to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 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 enabling users to share photos and videos, comment on and like posts, send messages, and subscribe 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 para. 1 sentence 1 lit. 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: A social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to accounts. We and TikTok are jointly responsible for collecting and transferring event data, as well as measuring and generating insights reports (statistics) for profile owners. This event data includes information about the types of content users view or interact with, their actions, and information about the devices used (e.g., IP addresses, operating system, browser type, language settings, cookie data) and information from the user's profile, such as country or location. Information regarding TikTok's processing of user data can be found in TikTok's privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have entered into a specific joint controllership agreement with TikTok, which governs in particular the security measures TikTok must observe and in which TikTok has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to TikTok). The rights of users (in particular, the rights to information, deletion, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with TikTok. The joint controllership agreement 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 as well as content

We integrate functional and content elements into our online service 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").

The integration of third-party content always requires that these providers process users' IP addresses, as they cannot send the content to users' browsers without them. The IP address is therefore necessary for displaying this content or these functions. We strive to use only content from providers who use the IP address solely for content delivery. 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 allow information such as visitor traffic on the pages of this website to be analyzed. The pseudonymized information can also be stored in cookies on users' devices and may include, 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 services, as well as be combined with such information from other sources.

Information on the legal basis: 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., our 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 time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); location data (information on the geographic position of a device or person). Event data (Facebook) ("Event data" is information sent to the provider Meta, for example, via Meta pixels (whether through apps or other channels), relating 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 to create target groups for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as 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.).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; audience measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); target group creation; marketing. Profiles with user-related information (creation of user profiles).
  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 services that we retrieve from third-party servers (e.g., function libraries that we use for the presentation or user-friendliness of our online services). In doing so, the respective providers collect users' IP addresses and may process them for the purpose of transmitting the software to users' browsers, for security purposes, and for evaluating and optimizing their services. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Facebook Plugins and Content: Facebook Social Plugins and Content – This may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this website within Facebook. The list and appearance of the 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, as part of a transmission (but not the further processing), of "event data" that Facebook collects or receives through the Facebook Social Plugins (and content embedding functions) implemented on our website for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transactional messages (e.g., contacting users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information is likely to match users' interests). We have entered into a specific agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum) which, in particular, regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not occur under 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 rights to information, erasure, objection, and lodging a complaint with 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 para. 1 sentence 1 GDPR). Article 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Legal basis for third-country transfers: EU/EEA Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
  • Google Fonts (retrieved from Google servers): Fonts (and symbols) are retrieved for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their consistent display, and compliance with any applicable licensing restrictions. The user's IP address is transmitted to the font provider so that the fonts can be made available in the user's browser. Furthermore, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for providing the fonts depending on the device used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our website, users' browsers send HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then with the fonts specified in the CSS. 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 the website visitor, and the referring URL (i.e., the webpage where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, nor are they analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the specific browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the 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. According to Google, none of the information collected by Google Fonts is used to create end-user profiles or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Legal 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 para. 1 sentence 1 lit. 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 determination, distance calculations, or the provision of supplementary information about locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. 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 may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this online service within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, as part of a transfer (but not the further processing), of "event data" that Facebook collects or receives through Instagram functions (e.g., content embedding functions) implemented on our online service for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transactional messages (e.g., contacting users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information is presumably relevant to users' interests). We have concluded a special agreement with Facebook ("Addendum for Controllers", https://www.facebook.com/legal/controller_addendum), which in particular regulates which 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 data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing does not occur under 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 rights to information, erasure, objection, and lodging a complaint with 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 para. 1 GDPR). Article 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Legal basis for third-country transfers: Switzerland - Adequacy Decision (Ireland).
  • LinkedIn plugins and content: This may include, for example, content such as images, videos, or text, and buttons that allow users to share content from this website within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 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 during font retrieval includes the (anonymized) identification number of the web font project, the URL of the licensed website 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 this extraction and storage of the page view count, 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 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 options: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad personalization: https://myadcenter.google.com/personalizationoff.
  • YouTube Videos: Our website includes embedded videos hosted on YouTube. These YouTube videos are integrated via a special domain using the "youtube-nocookie" component in so-called "enhanced privacy mode." In "enhanced privacy mode," until the video starts playing, only information such as your IP address, browser details, and device information is stored on your device in cookies or similar technologies. This information is necessary for YouTube to display, control, and optimize the video. Once you play the videos, additional information may be processed by YouTube to analyze user behavior, store it in your user profile, and personalize content and ads. The storage period for these cookies can be up to two years. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy Legal 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 – These may include content such as images, videos, or text, and buttons that allow users to share content from this online service within Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 delivering our services. We comply with legal requirements when selecting third-party providers and their services.

Within this framework, personal data may be processed and stored on the servers of third-party providers. This may involve various types of data, which we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data relating to transactions, contracts, other processes, and their content.

If users are referred to third-party providers or their software or platforms in the course of communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security, service optimization, or marketing purposes. We therefore ask you to review the privacy policies of the respective third-party providers.

  • Types of data processed: Content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved); 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).
  • Affected persons: Communication partners; users (e.g., website visitors, users of online services); business and contractual partners; prospective customers; tenants.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; provision of our online services 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 according to the information in the section "General information on data storage and deletion".
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. 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 various channels, invoice creation, 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 para. 1 sentence 1 lit. 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

In the context of employment relationships, personal data is processed with the aim of effectively managing the establishment, execution, 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 management of daily working hours, the management of access rights and permissions, and the handling of personnel development measures and employee reviews. The processing also serves the purpose of payroll 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 for the evaluation and optimization of operational processes. Furthermore, data processing includes the disclosure of employee data within the framework of external communication and publication processes, where this is necessary for operational or legal purposes.

The processing of this data is always carried out in compliance with applicable legal frameworks, with the constant aim of creating and maintaining a fair and efficient working environment. This also includes respecting the data protection rights of the employees concerned, and 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 on employees and other persons in an employment relationship); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Master 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 image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Social data (data subject to social confidentiality and processed, for example, by social security institutions, social welfare agencies, or pension authorities); Log data (e.g., log files concerning logins or data retrieval or access times); Performance and behavioral data (e.g., performance and behavioral aspects such as performance reviews, feedback from supervisors, 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., base salary, bonus payments, premiums, tax bracket information, surcharges for night work/overtime, tax deductions, social security contributions, net payment amount); image and/or video recordings (e.g., photographs or video recordings of a person); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Special categories of personal data: Health data; Religious or philosophical beliefs; Trade union membership.
  • Affected persons: Employees (e.g., salaried staff, applicants, temporary workers and other employees).
  • Purposes of processing: Establishing and maintaining employment relationships (processing employee data in the context of establishing and maintaining employment relationships); business processes and procedures; provision of contractual services and fulfillment of contractual obligations; public relations; security measures; office and organizational procedures.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to healthcare, professional and social security (Art. 9 para. 2 lit. h) GDPR).

Further information on processing procedures, methods and services:

  • Time tracking: Procedures for recording employee working hours include both manual and automated methods, such as the use of time clocks, time tracking software, or mobile apps. Activities include entering arrival and departure times, break times, overtime, and absences. Verification and validation of the recorded working hours include reconciliation with duty rosters or shift schedules, verification of absences, and approval of overtime by supervisors. Reports and analyses are generated based on the recorded working hours to provide time sheets, overtime reports, and absence statistics for management and the HR department. Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Access management: Procedures required for defining, managing, and controlling access rights and user roles within a system or organization (e.g., creating access profiles, role- and access-based control, reviewing and approving access requests, regularly checking access rights, tracking and auditing user activities, creating security policies and procedures); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Special categories of personal data: Special categories of personal data are processed within the context of the employment relationship or to fulfill legal obligations. The processed special categories of personal data include data concerning the health, trade union membership, or religious affiliation of employees. This data may be disclosed to health insurance companies, processed for assessing employees' fitness for work, for occupational health management, or for providing information to the tax authorities. Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Sources of processed data: Personal data obtained during the application process and/or the employment relationship of employees is processed. In addition, personal data from other sources is collected where legally required. These may include tax authorities for tax-relevant information, the respective health insurance provider for information on incapacity for work, third parties such as employment agencies, or publicly accessible sources such as professional social networks in the context of application procedures. Legal bases: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Purposes of data processing: Employees' personal data is primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, processing this data is necessary to comply with legal obligations under 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 inter-company data, potentially including statistical data. Employee data may also be processed for the assertion of legal claims and for defense in legal disputes. Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transfer of employee data: Employee data is processed internally only by those departments that require it to fulfill operational, contractual, and legal obligations. Data is only transferred to external recipients if required by law or if the employees concerned have given their consent. Possible scenarios for this include requests for information from authorities or in the case of employee savings plans. Furthermore, the data controller may transfer personal data to other recipients to the extent necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) banks b) health insurance funds, pension insurance institutions, retirement savings providers, and other social security institutions c) authorities, courts (e.g., tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and disclosure obligations) d) tax and legal advisors e) third-party debtors in the case of wage and salary garnishments f) other bodies to which legally binding declarations must be submitted. Furthermore, data may be shared with third parties if this is necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender field of emails or letterheads, as well as the creation of profiles on external platforms; legal bases: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transfer of employee data to third countries: The transfer of employee data to third countries, i.e., countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the performance of the employment contract, required by law, or if employees have given their consent. Employees will be informed separately about the details, where required by law; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Business travel and travel expense accounting: Procedures necessary for the planning, execution, and accounting of business trips (e.g., booking travel, organizing accommodation and transportation, managing travel expense advances, submitting and reviewing travel expense reports, monitoring and recording incurred costs, complying with travel policies, and handling travel expense management); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Payroll accounting and wage processing: Procedures necessary for calculating, paying, and documenting 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, and reporting to tax authorities and social security institutions); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
  • Deletion of employee data: Employee data is deleted under German law when 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 employer's legitimate interests. The following retention and archiving obligations are observed:
  • General personnel documents – General personnel documents (such as employment contract, employment certificate, supplementary agreements) are kept for up to three years after the termination of the employment relationship (§ 195 German Civil Code). Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 German Fiscal Code, § 257 German Commercial Code). Information on wages and working hours – Information on wages and working hours for (accident) insured persons with proof of wages is kept for five years (§ 165 I 1, IV 2 German Social Code, Book VII).
  • Payroll lists including lists for special payments - Payroll lists including lists for special payments, provided that a booking document exists, are kept for ten years (§ 147 AO, § 257 HGB).
  • Payroll lists for interim, final and special payments - Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
  • Employee insurance documents - Employee insurance documents, provided that booking receipts are available, are kept for ten years (§ 147 AO, § 257 HGB).
  • Contribution statements to social security institutions – Contribution statements to social security institutions are kept for ten years (§ 165 SGB VII). Payroll accounts – Payroll accounts are kept for six years (§ 41 I 9 EStG).
  • Applicant data - will be stored 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 (§ 16 II Working Time Act (ArbZG)).
  • Application documents (following online job advertisement) - are 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 (§ 6 I Aufwendungsausgleichsgesetz (AAG)).
  • Documents relating to company pension schemes - These must be kept for 30 years (§ 18a Law on the Improvement of Company Pension Schemes (BetrAVG)).
  • Employee illness data - These are kept for twelve months after the start of the illness if the absences in one year do not exceed six weeks.
  • Documents relating to maternity protection - These are kept for two years (§ 27 para. 5 MuSchG).

Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to healthcare, professional and social security (Art. 9 para. 2 lit. h) GDPR).

  • Personnel file management: Procedures necessary for the organization, updating, and administration of employee data and documents (e.g., recording employee master data, storing employment contracts, certificates, and attestations, updating data when changes occur, compiling documents for employee reviews, archiving personnel files, and complying with data protection regulations); Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, occupational health, and social security (Art. 9 para. 2 lit. h) GDPR).
  • Personnel development, performance appraisal, and employee appraisals: Procedures required for the promotion and development of employees, as well as for assessing their performance and conducting employee appraisals (e.g., needs analysis for further training, planning and implementation of training measures, preparation of performance appraisals, conducting target agreement and feedback meetings, career planning and talent management, succession planning); Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, occupational health and safety (Art. 9 para. 2 lit. h) GDPR).
  • Obligation to provide data: The data controller informs employees that providing their data is necessary. This is generally the case if the data is required for establishing and carrying out the employment relationship or if its collection is legally mandated. Providing data may also be necessary if employees assert claims or are entitled to claims. The implementation of these measures or the fulfillment of services depends on the provision of this data (for example, providing data for the purpose of receiving wages). Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Publication and Disclosure of Employee Data: Employee data will only be published or disclosed to third parties if this is necessary for the performance of their duties in accordance with their employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website, or in public registers, as agreed upon or in accordance with their job description, or if their duties include representative functions. This may also be the case if the performance of duties involves public presentation or communication, such as taking photographs for public relations purposes. Otherwise, employee data will only be published with their consent or based on the employer's legitimate interests, for example, in the case of stage or group photographs taken at a public event. Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and updates

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

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, those legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Affiliate tracking: Affiliate tracking involves logging links that direct users from linking websites to websites with product or other offers. The operators of the linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). For this to work, providers need to be able to track whether users interested in specific offers subsequently take advantage of them as a result of clicking on the affiliate links. Therefore, for affiliate links to function, they must be supplemented with certain values that become part of the link itself or are stored elsewhere, such as in a cookie. These values include, in particular, the referring website, the timestamp, an online identifier of the operator of the website where the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, partner ID, and categorizations.
  • Employees: The term "employees" refers to individuals who are in an employment relationship, whether as staff members, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established through an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various phases, including its establishment, during which the employment contract is concluded; its performance, during which the employee carries out their work; and its termination, when the employment relationship ends, whether through dismissal, a mutual termination agreement, or otherwise. Employee data is all information relating to these individuals and situated within the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, leave entitlements, health data, and performance reviews.
  • Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar associations. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unambiguous identification and communication.
  • Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the content itself but also includes metadata that provides information about the content, 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 tracking: Conversion tracking (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. Typically, a cookie is stored on users' devices within the websites where the marketing measures are implemented and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Performance and behavioral data: Performance and behavioral data refers to information related to how individuals perform tasks or behave in a specific context, such as an educational, work, or social environment. This data can include metrics such as productivity, efficiency, work quality, attendance, and adherence to policies or procedures. Behavioral data might include interactions with colleagues, communication styles, decision-making processes, and reactions to various situations. These types of data are often used for performance reviews, training and development initiatives, and decision-making within organizations.
  • Metadata, communication data, and procedural data: These categories 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 modification history. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs, which are used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information, revealing how users utilize applications, which features they prefer, how long they stay on specific pages, and the paths they take through an application. Usage data can 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 referred to as "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 simply "profiling," encompasses any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Examples of such profiling include interests in specific content or products, click behavior on a website, or location. Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to generate performance reports.
  • Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience analysis, operators of online services can, for example, determine when users visit their websites and which content they are interested in. This allows them to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for audience analysis purposes to recognize returning visitors and thus obtain more accurate analyses of online service usage.
  • Location data: Location data is generated when a mobile device (or another device with the technical capabilities for location tracking) connects to a cell tower, Wi-Fi network, or similar location-determining technology. Location data indicates the geographically identifiable position of the device on Earth. It can be used, for example, to display map functions or other location-dependent information.
  • Tracking: "Tracking" refers to the process of observing user behavior across multiple online services. Typically, behavioral and interest information related to the online services 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 match their interests.
  • Controller: The term "controller" refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.
  • 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 category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include the start and end dates of the contract, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options, and special terms 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 encompasses all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction data, verification numbers, and invoice information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
  • Target group creation: Target group creation (also known as "Custom Audiences") refers to the process of defining target groups for advertising purposes, such as displaying advertisements. For example, based on a user's interest in specific products or topics online, it can be inferred that this user will be interested in advertisements for similar products or the online shop where they viewed those products. "Lookalike Audiences" (or similar target groups) are created when content deemed suitable is displayed to users whose profiles or interests are likely to match those of the users for whom the profiles were created. Cookies and web beacons are typically used to create Custom Audiences and Lookalike Audiences.