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Privacy policy

This is an English translation of our German privacy policy.

Preamble

With the following privacy policy, we would like to inform you which types of your personal data (hereinafter also referred to as “data”) we process, for which 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.

Last updated: 23 September 2026

Controller

New Digitals GmbH
Zaubzerstr. 40
81677 Munich, Germany

Authorised representatives: Quirin Stiegler (Managing Director)

Email address: info@newdigitals.com

Legal notice: https://www.newdigitals.com/en/legal-notice/

Contact details of the data protection officer

BAY GmbH Wirtschaftsprüfungsgesellschaft Rechtsanwaltsgesellschaft, Silke Bay
Luitpoldpark, Uferweg 11
88131 Lindau, Germany

Phone: +49 (8382) 27 30 79-12
Email: silke.bay@bay-gmbh.com

Overview of processing operations

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

Types of data processed

  • Master data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Metadata, communication and process data.
  • Image and/or video recordings.
  • Audio recordings.
  • Log data.

Categories of data subjects

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

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Office and organisational procedures.
  • Organisational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.

Relevant legal bases under the GDPR: Below is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection provisions may apply in your or our country of residence or registered office. Should more specific legal bases be relevant in individual cases, we will inform you of these in this privacy policy.

  • Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains in particular special provisions on 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 transmission, as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Security measures

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

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input, disclosure, securing the availability and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the erasure of data and responses to threats to the data. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

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

Transfer of personal data

In the course of our processing of personal data, it may happen that such data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of such data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which is apparent from the postal address of the respective provider or where this privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

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

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

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

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en

General information on data retention and deletion

We delete the personal data we process in accordance with the legal provisions as soon as the underlying consents are withdrawn or no further legal bases for the processing exist. This concerns cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise or defence of legal claims or for the protection of the rights of other natural or legal persons, must be archived accordingly.

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

Where there are several statements on the retention period or deletion deadlines for an item of data, the longest period shall always prevail. Data that is no longer retained for its originally intended purpose, but on the basis of legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, the opening balance sheet and the working instructions and other organisational documents required to understand them (§ 147(1) no. 1 in conjunction with (3) of the German Fiscal Code (AO), § 257(1) no. 1 in conjunction with (4) of the German Commercial Code (HGB)).
  • 8 years - Accounting vouchers, such as invoices and expense vouchers (§ 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO, § 14b(1) of the German VAT Act (UStG) and § 257(1) no. 4 in conjunction with (4) HGB).
  • 6 years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting vouchers, and till receipts (§ 147(1) nos. 2, 3, 5 in conjunction with (3) AO, § 257(1) nos. 2 and 3 in conjunction with (4) HGB).
  • 3 years - Data required to take into account potential warranty and damages claims or similar contractual claims and rights and to process related enquiries, based on previous business experience and customary industry practice, is stored for the duration of the standard limitation period of three years (§§ 195, 199 of the German Civil Code (BGB)).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and amounts to at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the time at which the termination or other ending of the legal relationship takes effect.

Rights of data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not 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 the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, in accordance with the legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. The complaint may be lodged in particular with a supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.

Business services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively “contractual partners”), for the initiation, performance and handling of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken on request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular the fulfilment of our primary and ancillary contractual obligations. These include the provision of the agreed services, any obligations to update and inform, the handling of warranty claims and other performance disruptions, the processing of withdrawals, terminations of continuing obligations, reversals, refunds and the handling of other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.

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

In addition, we process the data to safeguard our rights and to comply with legal obligations. This includes in particular retention obligations under commercial and tax law, documentation obligations and, where applicable, obligations to provide evidence and accountability. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners against misuse and threats to data, secrets and other legally protected interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other agents, insofar as this is necessary for the performance of the contract or to comply with legal obligations.

Personal data is disclosed to third parties only insofar as this is necessary for the performance of the contract, for carrying out pre-contractual measures, for safeguarding legitimate interests or for complying with legal obligations. We provide separate information on any processing beyond this, in particular for marketing purposes, within this privacy policy.

We inform contractual partners of which data is required in the individual case when the data is collected, for example in online forms by means of appropriate marking or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. We delete data transmitted in the context of a specific assignment after completion of the assignment and expiry of any retention periods, unless further legal or contractual obligations to store it exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and for the performance of the respective contractual relationship, and Art. 6(1)(c) GDPR for compliance with legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Insofar as the processing is based on Art. 6(1)(f) GDPR, it serves to safeguard our legitimate interests in proper and efficient business organisation, the internal administration and documentation of business transactions, the enforcement and defence of legal claims, ensuring IT and data security, the prevention of misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in preserving our entrepreneurial capacity to act.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Communication; Office and organisational procedures; Organisational and administrative procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of software and platforms: We process the data of our customers and users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them and, on the basis of legitimate interests, to ensure the security of our services and to develop them further. The required information is identified as such in the context of concluding the assignment, order or comparable contract and includes the information required for service provision and billing, as well as contact information in order to be able to hold any necessary consultations; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

  • IT services: We process the data of our customers and clients in order to enable the planning, implementation and support of IT solutions and related services for them. The required information is identified as such in the context of concluding the assignment, project or comparable contract and includes the information required for service provision and billing, as well as contact information in order to be able to hold any necessary consultations. Insofar as we obtain access to information of end customers, employees or other persons, we process it in accordance with the legal and contractual requirements.
    The processing operations include, among others, project administration and documentation, covering all phases from the initial requirements analysis to the completion of the project. This includes creating and managing project schedules, budgets and resource allocations. The data processing also supports change management, in which changes in the course of the project are documented and tracked in order to ensure compliance and transparency.

    A further process is customer relationship management (CRM), which involves recording and analysing customer interactions and feedback in order to improve the quality of service and to address individual customer needs efficiently. In addition, the processing includes technical support and troubleshooting, which covers the recording and handling of support requests, error correction and regular maintenance.

    Furthermore, reporting and performance analysis are carried out, whereby key performance indicators are recorded and evaluated in order to assess and continuously optimise the effectiveness of the IT solutions provided. All of these processes are aimed at ensuring a high level of customer satisfaction and compliance with all relevant requirements; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

  • Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, acquire or commission the chosen services or works and related activities, as well as their payment and provision, execution or performance.

    The required information is identified as such in the context of concluding the assignment, order or comparable contract and includes the information required for service provision and billing, as well as contact information in order to be able to hold any necessary consultations. Insofar as we obtain access to information of end customers, employees or other persons, we process it in accordance with the legal and contractual requirements; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR).

  • Management consulting: We process the data of our customers, clients, prospective customers and other principals or contractual partners (uniformly referred to as “customers”) in order to be able to provide our contractual or pre-contractual services to them, in particular consulting services. The data processed, and the nature, scope, purpose and necessity of its processing, are determined by the underlying contractual and business relationship.

    Insofar as this is necessary for the performance of our contract or required by law, or the customers have given their consent, we disclose or transmit the customers’ data to third parties or agents, such as authorities, courts or providers in the field of IT, office or comparable services, in compliance with the rules of professional conduct; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR).

Business processes and procedures

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

The data collected serves to fulfil contractual obligations and to make operational processes efficient. This includes the handling of business transactions, the management of customer relationships, the optimisation of sales strategies and ensuring internal accounting and financial processes. In addition, the data supports the safeguarding of the controller’s rights and facilitates administrative tasks and the organisation of the company.

Personal data may be disclosed to third parties insofar as this is necessary to fulfil the stated purposes or legal obligations. The data is deleted after the expiry of statutory retention periods or when the purpose of the processing no longer applies. This also includes data that must be stored for longer due to tax and other statutory obligations to provide evidence.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation); Contract data (e.g. subject matter of the contract, term, customer category); Log data (e.g. log files relating to logins or the retrieval of data or access times); Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partners; Business and contractual partners; Third parties; Users (e.g. website visitors, users of online services). Customers.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Office and organisational procedures; Business processes and business 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.)).
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR); Legitimate interests (Art. 6(1)(f) GDPR). Legal obligation (Art. 6(1)(c) GDPR).

Further information on processing operations, procedures and services:

  • Customer management and customer relationship management (CRM): Procedures required in the context of customer management and customer relationship management (CRM) (e.g. customer acquisition in compliance with data protection requirements, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with due regard to data protection, data management and analysis to support the customer relationship, administration of CRM systems, secure account management, customer segmentation and target group definition); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Contact management and contact maintenance: Procedures required in the context of organising, maintaining and securing contact information (e.g. setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restorations of contact data, training employees in the effective use of contact management software, regular review of the communication history and adjustment of contact strategies); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • General payment transactions: Procedures required for carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. preparing and checking bank transfers, processing direct debits, checking bank statements, monitoring incoming and outgoing payments, managing returned direct debits, account reconciliation, cash management); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. preparing and checking incoming and outgoing invoices, monitoring and managing open items, carrying out payment transactions, handling dunning, account reconciliation in connection with receivables and liabilities, accounts payable and accounts receivable); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Financial accounting and taxes: Procedures required for recording, managing and controlling finance-related business transactions and for calculating, reporting and paying taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, carrying out payment transactions, handling dunning, account reconciliation, tax advice, preparation and submission of tax returns, handling of tax matters); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Purchasing: Procedures required for the procurement of goods, raw materials or services (e.g. supplier selection and evaluation, price negotiations, placing and monitoring orders, checking and controlling deliveries, invoice verification, order management, warehouse management, preparation and maintenance of purchasing guidelines); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Sales: Procedures required for planning, carrying out and controlling measures for the marketing and sale of products or services (e.g. customer acquisition, preparing and following up quotations, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Marketing, advertising and sales promotion: Procedures required in the context of 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 programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and execution of PR campaigns, preparation and distribution of press releases, maintaining media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Providers and services used in the course of business

In the course of our business, we use, in compliance with the legal requirements, additional services, platforms, interfaces or plug-ins from third-party providers (in short, “services”). Their use is based on our interests in the proper, lawful and economical management of our business operations and our internal organisation.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other personnel).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Office and organisational procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

Provision of the online services and web hosting

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

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

Further information on processing operations, procedures 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 or otherwise obtain from a corresponding server provider (also referred to as a “web host”); Legal bases: Legitimate interests (Art. 6(1)(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”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volumes of data transferred, notification of successful access, browser type and version, the user’s operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to prevent overloading of the servers (in particular in the event of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • Content delivery network: We use a “content delivery network” (CDN). A CDN is a service with the help of which the content of online services, in particular large media files such as graphics or program scripts, can be delivered faster and more securely by means of regionally distributed servers connected via the internet; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Hostinger: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Hostinger International Ltd, 61 Lordou Vironos Str., 6023 Larnaca, Cyprus; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hostinger.de. Privacy policy: https://www.hostinger.de/legal/datenschutz-bestimmungen.

Use of cookies

The term “cookies” refers to functions that store information on users’ devices and read information from them. Cookies may also be used for various purposes, for example for the functionality, security and convenience of online services and for the analysis of visitor flows. We use cookies in accordance with the legal provisions. For this purpose, we obtain the prior consent of users where required. Where consent is not necessary, we rely on our legitimate interests. This applies where the storage of and access to information is strictly necessary in order to provide expressly requested content and functions. These include, for example, the storage of settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about its scope and which cookies are used.

Information on legal bases under data protection law: Whether we process personal data by means of 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 period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device has been closed. For example, the login status can be saved and preferred content displayed directly when the user visits a website again. Likewise, user data collected by means of cookies may be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), they should assume that the cookies are persistent and that the storage period may be up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw any consent they have given at any time and can also object to the processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

  • Types of data processed: Metadata, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the information provided by the enquiring persons is processed insofar as this is necessary to answer the contact enquiries and any requested measures.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation); Metadata, communication and process data (e.g. IP addresses, times, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; Organisational and administrative procedures; Feedback (e.g. collecting feedback via an online form); Provision of our online services and user-friendliness; Direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When you contact us via our contact form, by email or other communication channels, we process the personal data transmitted to us in order to answer and handle the respective request. This usually includes information such as name, contact information and, where applicable, further information that is communicated to us and is necessary for appropriate handling. We use this data exclusively for the stated purpose of establishing contact and communication; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Brevo: Email sending and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.brevo.com/; Privacy policy: https://www.brevo.com/legal/privacypolicy/. Data processing agreement: Provided by the service provider.
  • WhatsApp: A communication service that enables the sending and receiving of text messages, voice messages, images, videos and documents, as well as voice and video calls, via the internet. Communication takes place using end-to-end encryption, which means that content is only accessible to the communication partners involved. To provide the service, the platform processes metadata (e.g. telephone numbers, times, device information) and may use it to improve functionality, for security and to optimise its services; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.whatsapp.com/. Privacy policy: https://www.whatsapp.com/legal/privacy-policy-eea.
  • Slack: Messenger and conferencing software; Service provider: Slack Technologies Limited, Level 1, Block A Nova Atria North, Sandyford Business District, Dublin 18, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://slack.com/intl/de-de/; Privacy policy: https://slack.com/intl/de-de/legal; Data processing agreement: https://slack.com/intl/de-de/terms-of-service/data-processing. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://slack.com/intl/de-de/terms-of-service/data-processing).

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants listed below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g. provision of access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal details (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.

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

Data protection measures of participants: For details of the processing of your data by the conference platforms, please refer to their privacy notices and choose the security and privacy settings that are best for you within the settings of the conference platforms. Please also ensure data protection and the protection of personal rights in the background of your recording for the duration of a video conference (e.g. by notifying housemates, locking doors and, where technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.

Information on legal bases: Insofar as, in addition to the conference platforms, we also process users’ data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in participant lists, in the case of follow-up of meeting results, etc.). Otherwise, users’ data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Image and/or video recordings (e.g. photographs or video recordings of a person); Audio recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times).
  • Data subjects: Communication partners; Users (e.g. website visitors, users of online services). Persons depicted.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Communication. Office and organisational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

Cloud services

We use software services accessible via the internet and executed on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients, or publication of content and information).

In this context, personal data may be processed and stored on the providers’ servers insofar as it forms 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 data of users, data on transactions, contracts, other processes and their content. The providers of the cloud services also process usage data and metadata, which they use for security purposes and for service optimisation.

If we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g. in the case of media control).

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Prospective customers; Communication partners; Business and contractual partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

Web analytics, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online services and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online services or their functions or content are used most frequently, or invite users to return. We are also able to understand which areas require optimisation.

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

Unless otherwise stated below, profiles, i.e. data combined for a usage session, may be created for these purposes, and information may be stored in and read from a browser or device. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data vis-à-vis us or the providers of the services we use, the processing of location data is also possible.

In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no directly identifying user data (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation; pseudonyms are used instead. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication and process data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Pirsch Analytics: Cookieless reach measurement. Pirsch neither stores information on users’ devices nor reads information from them; neither cookies nor comparable storage technologies are used. To distinguish between visits, a hash value is generated from the IP address, the browser identifier (user agent), the date and a character string randomly generated for our website. The IP address itself is neither stored nor logged. Because the date is part of the hash value, users can only be recognised for a maximum of 24 hours. The data processed comprises the pages accessed, the referring website (referrer), campaign parameters (UTM), language setting, time of the visit, browser, operating system, device type, screen size, and the country and city derived from the IP address. We also record interactions with our online services, such as loading the appointment calendar, completed appointment bookings, submitting the contact form, clicks on buttons, opening questions in the FAQ section and scroll depth. The data is processed on servers of Hetzner Online GmbH in Germany; no transfer to third countries takes place. In deviation from the general information in this section, when Pirsch is used, no IP addresses are stored or shortened, no user profiles are created over a period of more than 24 hours and no consent is obtained; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Data processing agreement: Provided by the service provider; Service provider: Emvi Software GmbH, Nickelstraße 1b, 33378 Rheda-Wiedenbrück, Germany; Website: https://pirsch.io. Privacy policy: https://pirsch.io/privacy.

Presences on social networks (social media)

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

We would like to point out that user data may be processed outside the territory of the European Union. This may result in risks for users, for example because it could make it more difficult to enforce users’ rights.

Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created on the basis of users’ usage behaviour and the resulting interests. These, in turn, may be used, for example, to place advertisements inside and outside the networks that presumably correspond to the users’ interests. For this reason, cookies are usually stored on users’ computers in which the usage behaviour and interests of the users are stored. In addition, data may also be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the options to object (opt-out), please refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for access and the exercise of data subjects’ rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures 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 visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via an online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job function, country, industry, seniority, company size and employment status. Privacy information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy
    We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send requests for access or erasure directly to LinkedIn). The rights of users (in particular the right of access, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of the data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.linkedin.com/legal/privacy-policy). Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Management, organisation and auxiliary tools

We use services, platforms and software of other providers (hereinafter referred to as “third-party providers”) for the purposes of organising, managing, planning and providing our services. When selecting the third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may concern various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.

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

  • Types of data processed: Content data (e.g. textual or visual messages and contributions, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Metadata, communication and process data (e.g. IP addresses, times, identification numbers, persons involved); Master data (e.g. full name, residential address, contact information, customer number, etc.). Contact data (e.g. postal and email addresses or telephone numbers).
  • Data subjects: Communication partners; Users (e.g. website visitors, users of online services); Prospective customers. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Office and organisational procedures; Communication. Organisational and administrative procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data retention and deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Miro: Online whiteboard and collaboration platform; Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite 1100, San Francisco, California 94105, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://miro.com/; Privacy policy: https://miro.com/legal/privacy-policy/; Data processing agreement: https://miro.com/legal/vendor-data-processing-addendum/. Basis for third-country transfers: Standard contractual clauses (https://miro.com/legal/vendor-data-processing-addendum/).
  • Trello: Project management tool; Service provider: Atlassian Pty Ltd, 350 Bush Street, Floor 13, San Francisco, CA 94104, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://trello.com/; Privacy policy: https://www.atlassian.com/legal/privacy-policy; Data processing agreement: https://www.atlassian.com/legal/data-processing-addendum. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.atlassian.com/legal/data-processing-addendum#europe-uk-switzerland).
  • Cal.com: Scheduling platform that enables online bookings, calendar integrations and automated reminders and offers functions such as team scheduling and video conferencing integrations, processing personal data in order to organise and manage appointments; Service provider: Cal.com, Inc., 2261 Market Street #4368, 94114 San Francisco, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://cal.com/; Privacy policy: https://cal.com/privacy; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Standard contractual clauses (provided by the service provider).
  • Appointment booking on our website: The Cal.com booking calendar is embedded in our website, but is only loaded when users expressly request it via the “Load calendar” button; no connection to Cal.com is established before then. After loading, the IP address and technical information about the browser are transmitted to Cal.com, and Cal.com stores information in the browser’s storage (localStorage) in order to provide the calendar; this takes place in accordance with § 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG), as it is necessary for the service expressly requested. When a booking is made, the name, email address, company, optional details about the request and the selected appointment are processed; appointments are synchronised with our Google Calendar, and the meeting takes place via Google Meet. Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR).

Changes and updates

We ask you to check the content of our privacy policy regularly. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require action on your part (e.g. consent) or other individual notification.

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

Supervisory authority responsible for us:

Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht – BayLDA)
Promenade 18
91522 Ansbach, Germany
https://www.lda.bayern.de

Definitions

This section provides an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Employees: Employees are persons 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 that is established by an employment contract or agreement. It involves the employer’s obligation to pay remuneration to the employee, while the employee performs their work. The employment relationship comprises various phases, including its establishment, in which the employment contract is concluded, its performance, in which the employee carries out their work, and its termination, when the employment relationship ends, whether by notice of termination, termination agreement or otherwise. Employee data is all information relating to these persons and connected with their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
  • Master data: Master data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, facilities or systems by enabling unambiguous assignment and communication.
  • Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Metadata, communication and process data: Metadata, communication and process data are categories containing information about the way in which data is processed, transmitted and managed. Metadata, also known as data about data, comprises information describing the context, origin and structure of other data. It may include details of file size, date of creation, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Process data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages and which paths they take to navigate through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Furthermore, usage data plays a decisive role in identifying trends, preferences and possible problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, comprises any form of automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online service and may include the behaviour or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online services can, for example, recognise at what time users visit their web pages and what content they are interested in. This enables them, for example, to better adapt the content of the web pages to the needs of their visitors.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is decisive for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and invoice information. Payment data may also include information on payment status, chargebacks, authorisations and fees.