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”) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Version: July 21, 2026

Table of Contents

Controller

Timon Scheper
K 4 12
68159 Mannheim, Germany

Email address: timon@timonscheper.com

Imprint: https://timonscheper.com/impressum/

Overview of Processing

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

Types of Data Processed

• Inventory data.
• Employee data.
• Contact data.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of Data Subjects

• Employees.
• Users.
• Third parties.
• Whistleblowers.

Purposes of Processing

• Communication.
• Security measures.
• Reach measurement.
• Tracking.
• Audience building.
• Organizational and administrative procedures.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Whistleblower protection.
• Public relations.

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find 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 requirements may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 (1) (a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
• Legal obligation (Art. 6 (1) (c) GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) (f) GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss DPA: This privacy notice serves both to provide information in accordance with the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss DPA, the terms used in the GDPR are “processing” of “personal data” as well as “legitimate interest” and “special categories of data”. However, the legal meaning of the terms continues to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.

The 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, input, disclosure, safeguarding of availability and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to threats to data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and privacy-friendly default settings.

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

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 this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies (which can be identified by the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this always takes place in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by the adequacy decision of the EU Commission of 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This double protection 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 DPF, the standard contractual clauses will serve as a reliable fallback option. This ensures that your data always remains adequately protected, even in the event of possible political or legal changes.

For the individual service providers, we will 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 security measures apply, in particular standard contractual clauses, explicit consents or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal bases for the processing exist. This concerns cases in which the original processing purpose ceases to apply 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 to protect 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.

If there are several indications of the retention period or deletion deadlines for a data record, the longest period is always decisive. Data that is no longer needed 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.

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

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents required for their understanding (§ 147 (1) No. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) No. 1 in conjunction with (4) HGB).
• 8 years – Accounting documents, such as invoices and expense receipts (§ 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO as well as § 257 (1) No. 4 in conjunction with (4) HGB).
• 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price markings, but also payroll documents, insofar as they are not already accounting documents and cash register receipts (§ 147 (1) No. 2, 3, 5 in conjunction with (3) AO, § 257 (1) No. 2 and 3 in conjunction with (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 usual industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Commencement of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it automatically starts 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 of the effectiveness of the termination or other termination of the legal relationship.

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 Art. 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; this also applies to profiling based on these provisions. If your personal data 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; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and to access such data and further information and a copy of the data in accordance with legal requirements.
• Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be erased immediately, or alternatively, in accordance with 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 legal requirements, or to request its transmission to another controller.
• Complaint to supervisory authority: You have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Provision of the Online Offering and Web Hosting

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

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

Further information on processing operations, procedures and services:

• Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes 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 can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidence purposes is excluded from deletion until the final clarification of the respective incident.

Use of Cookies

The term “cookies” refers to functions that store information on users’ end devices and read it out from them. Cookies can also be used for different purposes, e.g., for the functionality, security and convenience of online offerings and for the creation of analyses of visitor flows. We use cookies in accordance with legal requirements. For this purpose, we obtain, if necessary, the prior consent of the users. If consent is not necessary, we rely on our legitimate interests. This applies when the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We inform clearly about their scope and which cookies are used.

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

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, user data collected using cookies can be used for reach measurement. If we do not provide users with explicit information on the type and storage duration of cookies (e.g., as part of obtaining consent), they should assume that these are permanent and that the storage duration can be 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 the privacy settings of their browser.

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

Further information on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a consent management solution in which the consent of users to the use of cookies or to the procedures and providers mentioned in the context of the consent management solution is obtained. This procedure serves to obtain, log, manage and revoke consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on the users’ end devices. Within the framework of this procedure, the consents of the users for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the option of managing and revoking their consents. The consent declarations are stored in order to avoid a new request and to be able to provide proof of consent in accordance with legal requirements. The storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, the details of the scope of consent (e.g., relevant categories of cookies and/or service providers) as well as information about the browser, system and the end device used; Legal bases: Consent (Art. 6 (1) (a) GDPR).
• Complianz: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of information on data protection and cookies, enabling users to revoke or adjust consents; Service provider: Execution on servers and/or computers under own data protection responsibility; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/. Further information: An individual user ID, language and types of consents and the time they were given are stored server-side and in the cookie on the user’s device.

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). The data of the readers 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 the rest, we refer to the information on the processing of visitors to our publication medium within the framework of this privacy policy.

• Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and posts as well as the information concerning them, such as information on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, involved parties).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form); Provision of our online offering and user-friendliness; Security measures. Organizational and administrative procedures.
• Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
• Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures and services:

• Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we could be held liable for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right, on the basis of our legitimate interests, to process user data for the purpose of spam detection. On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes. The personal information provided in the context of comments and posts, any contact and website information as well as the content information, is stored by us permanently until the user objects; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Web Analytics, Monitoring and Optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or content are used most frequently or invite reuse. It is also possible for us to understand which areas require optimization.

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

Unless otherwise stated below, profiles, i.e., data combined for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and then read out. The collected information 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, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, within the framework of web analytics, A/B testing and optimization, no clear data of the users (such as email addresses or names) are stored, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

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

• Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, involved parties).
• 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 Storage and Deletion”. Storage of cookies of up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal bases: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Presences in Social Networks (Social Media)

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

We point out that user data may be processed outside the European Union. This can give rise to risks for users because, for example, it could make it more difficult to enforce user rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created on the basis of user behavior and resulting interests. The latter may in turn be used, for example, to place advertising within and outside the networks that is presumed to correspond to the interests of the users. Therefore, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

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

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. Should you nevertheless need help, 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 pictorial messages and posts as well as the information concerning them, such as information on authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and 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 online form). Public relations.
• Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
• Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures and services:

• Instagram: Social network, enables sharing of photos and videos, commenting on and favoriting posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
• YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Objection option (Opt-Out): https://myadcenter.google.com/personalizationoff.

Plug-ins and Embedded Functions and Content

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

The integration always requires that the third-party providers of this content process the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We endeavor to only use content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Using the “pixel tags”, information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, but may also be linked to such information from other sources.

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

• Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, involved parties).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavior-related profiling, use of cookies); Audience building; Marketing. 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 Storage and Deletion”. Storage of cookies of up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
• Legal bases: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures and services:

• Instagram plugins and content: Instagram plugins and content – This can include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of “event data” that Facebook collects or receives in the context of a transmission for the following purposes via functions of Instagram (e.g., embedding functions for content) executed on our online offering: a) Display of content and advertising information that corresponds to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improvement of the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular 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, address information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e., do not contain information on individual users and are anonymous for us), then this processing does not take place within the framework of joint responsibility, 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 to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com. Privacy policy: https://privacycenter.instagram.com/policy/.
• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) (a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Objection option (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g., consent) or other individual notification.

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

Definitions of Terms

In this section, you will receive an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, 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 employees, staff or in similar positions. An employment relationship is a legal relationship between an employer and an employee, which is established by an employment contract or agreement. It includes the employer’s obligation to pay remuneration to the employee, while the employee performs their work. The employment relationship includes various phases, including the establishment, in which the employment contract is concluded, the execution, in which the employee performs their work activity, and the termination, when the employment relationship ends, whether by dismissal, termination agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlement, health data and performance reviews.
• Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include 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 unique assignment and communication.
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not only 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 individuals or organizations. This 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.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta-data, also known as data about data, includes information describing the context, origin and structure of other data. This can include information on file size, creation date, author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission routes. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing operations.
• Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and through which paths they navigate through an application. Usage data can also include the frequency of use, time stamps of activities, IP addresses, device information and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person is considered to be identifiable who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using these personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often 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 time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for analyzing system problems, security monitoring or creating performance reports.
• Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
• Tracking: “Tracking” refers to when the behavior of users can be traced across multiple online offerings. As a rule, with regard to the online offerings used, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
• Controller: “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 or on sets of personal data, whether or not by automated means. The term is broad and covers practically any dealing with data, whether it is collecting, evaluating, storing, transmitting or deleting.
• Audience building: Audience building (English “Custom Audiences”) refers to when target groups for advertising purposes are determined, e.g., for the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be inferred that this user is interested in advertisements for similar products or the online shop in which they viewed the products. “Lookalike Audiences” (or similar target groups) refers to when content deemed suitable is displayed to users whose profiles or interests are presumably similar to the users for whom the profiles were created. For the purposes of creating Custom Audiences and Lookalike Audiences, cookies and web beacons are generally used.

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